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Berks Community Development Office text

Mission Statement:  "In order to make Berks County a better place to live, the Community Development Office provides access to federal, state, and local funds for community and economic development and housing eforts."

Established by the Berks County Board of Commissioners in 1988, the Community Development Office engages in the administration of grants from various federal, state and local programs.
 
CONTACT 


  
  
  
 Community Development Office Berks  
 County Services Center
 633 Court Street, Floor 14
 Reading, PA 19601
 Hours: Mon-Fri, 8 a.m. to 5 p.m.
 Phone: 610.478.6325
 Fax: 610.478.6326
E-mail 
communitydev@countyofberks.com
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Berks County Community Development Office
CDO Office Handbook
A Public Information Handbook Prepared by Berks County Community Development Office   

 

      Purpose of Handbook | Schedule | The CDBG Program | The CDBG Program
      Allocation Policy | CDBG Program Eligible Activities| | CDBG Program
      Ineligible Activities| CDBG Program National Objectives| The HOME
      Program | The ESG Program | The Affordable Housing Program | Citizen
      Participation Program | Anti-Displacement and Relocation Assistance


  I. PURPOSE OF HANDBOOK

      This document introduces a new consolidated process that replaces all
      current requirements for planning and submission of 3 basic programs
      provided to Berks County through the U.S. Department of Housing and
      Urban Development (HUD). The three formula programs are: Community
      Development Block Grant (CDBG) Program; Home Investment Partnerships
      (HOME) Program; and Emergency Shelter Grants (ESG) Program. The new
      document resulting from the consolidated process is called the
      Consolidated Plan. The Plan is submitted annually to HUD and serves as a
      planning document of the County as well as the application for funding
      under the CDBG, ESG, and HOME Programs. It also addresses how the County
      will allocate its local Affordable Housing Program funded by an increase
      in the fees for recording deeds and mortgages.

      The consolidated process is a collaborative process whereby the County
      establishes a unified vision for community development actions.
      Consolidating the submission requirements offers the County a better
      chance to shape the various programs into effective, coordinated
      neighborhood and community development strategies. It also creates the
      opportunity for strategic planning and citizen participation to take
      place in a comprehensive context, and to reduce duplication of effort at
      the County level.
  -------------------------------

II. SCHEDULE
available printed in the CD Office Newsletter; CD News, and posted to our section of the County website as a Public Notice. The schedule typically details the following dates and/or deadlines; 

  • letters to municipalities & non-profits
  • applications advertisement
  • advertisement for “needs” hearing
  • “needs” hearing at BCTV studios
  • all funding request due
  • letters to adjacent municipalities
  • review of requests
  • publish advertisement for hearing and publish proposed Plan
  • “proposed Plan” hearing at BCTV studios
  • finalize Plan and summarize citizen comments
  • board approval
  • submission of Plan to HUD
  • HUD review starts
  • begin Program Year


      III. THE CDBG PROGRAM

      The CDBG Program provides eligible metropolitan cities and urban
      counties (called “entitlement communities”) with annual direct grants
      that they can use to revitalize neighborhoods, expand affordable housing
      and economic opportunities, and/or improve community facilities and
      services, principally to benefit low- and moderate-income persons. Since
      1974 the CDBG Program has been the backbone of improvement efforts in
      many communities, providing a flexible source of annual grant funds for
      local governments nationwide—funds that they, with the participation of
      local citizens, can devote to the activities that best serve their own
      particular development priorities, provided that these projects either
      (1) benefit low- and moderate-income families; (2) prevent or eliminate
      slums or blight; or (3) meet other urgent community development needs.
      The CDBG Entitlement Communities program ensures that almost 1000 of the
      largest and most distressed localities are able to share in this Federal
      assistance.

      As the Nation's eighth largest Federal grant program, the impact of
      CDBG-funded projects can be seen in the housing stock, the business
      environment, the streets and the public facilities of these entitlement
      communities. Although the rehabilitation of affordable housing has
      traditionally been the largest single use of CDBG Program funds, the
      program is also an increasingly important catalyst for economic
      development activities that expand job and business opportunities for
      lower income families and neighborhoods.


      IV. THE CDBG PROGRAM ALLOCATION POLICY

      General Information | Community Projects | City of Reading |
      County-Sponsored Activities & Initiatives | Planning Activities | AZIP |
      Economic Development
                        

      General Information
      Since 1975, the County of Berks has received an annual entitlement grant
      from the Federal Community Development Block Grant Program. For the
      FFY2000 Program Year, the grant was $3,127,000.00. Based on this past
      level of funding and considering current funding proposals in Congress
      for the CDBG Program, the County anticipates that its annual grant for
      the Program for the next three years will average $3,125,000.00 per
      year.

      It is the stated policy of the County of Berks that each participating
      municipality, excluding the City of Reading, will receive a basic grant
      during the three year cycle. This grant will enable the municipality to
      implement a project or projects that will meet local needs as well as
      basic eligibility and fundability requirements of the CDBG Program. The
      County intends to continue funding programs and activities which are
      County-wide in scope, meet an identified community development need,
      improve the housing stock of the County, revitalize the County’s
      communities, and implement the County's Comprehensive Plan. Finally, the
      County will allocate sufficient funds to insure the proper planning and
      administration of its CDBG Program.

      Based on these guidelines, the County of Berks will utilize funding of
      the FFY2000-2002 cycle generally as follows:

Community Projects (74 municipalities)  

 35%

County-Sponsored Activities & Initiatives 

50%

Planning and Administration 

15% 


                    
     Any activity funded by the County's CDBG Program shall be consistent
      with the goals and objectives of the County's Comprehensive Plan.
                       


      Community Projects
      Title I of the Housing and Community Development Act of 1974 states:
      “the primary objective of this title is the development of viable urban
      communities, by providing decent housing and a suitable living
      environment and expanding economic opportunities, principally for
      persons of low and moderate income.” In implementing this policy, the
      County of Berks will recognize this purpose by awarding 3 year grants to
      participating municipalities. The standard allocation for a municipality
      shall be based on the 1996 estimate of municipal population from the
      U.S. Census. From 40 persons to 2,032 persons, the standard allocation
      is $30,000.00. From 2,033 persons to 3,565 persons, the standard
      allocation is $40,000.00. From 3,566 persons to 25,0000 persons, the
      standard allocation is $50,000.00. Based upon the above formula,
      standard allocations are as follows (click here):


       City of Reading

      The City of Reading is an entitlement community for the CDBG Program and
      as such, receives funding directly from HUD. In the past, the County has
      provided CDBG Program funds to organizations for projects located within
      the City. The regulations for the CDBG Program do not prevent an
      entitlement community from expending funds for a project which is
      located within another entitlement community, however, the project must
      benefit residents outside as well as those in the City. The County has
      established a policy for such projects.

      The County shall evaluate and may provide funding for projects located
      within the City of Reading provided the following:

        A. The project shall reasonably benefit residents of the County living
           outside of as well as those living within the City of Reading.
        B. The project shall receive funding from the City of Reading equal to
           or more than the amount of funding provided by the County. Such
           funding may be for physical improvements, social services,
           planning, administration, etc.
        C. As stated in this allocation policy, the project must be consistent
           with the goals and objectives of the County's Comprehensive Plan
           and must further the purposes of the Housing and Community
           Development Act and the County’s community development objectives.
                           


      County-Sponsored Activities & Initiatives

      As previously stated, the County will allocate approximately 50% of the
      CDBG Program funding during the 3 year cycle to projects that are
      implemented by the departments of County government or for projects that
      support a major goal of the County’s Comprehensive as follows:

           A. Infrastructure Improvements

           1. Water and sewer service ranks foremost among the Community
           Facilities Plan provisions that interact with the Land Use Plan of

           the County's Comprehensive Plan. While sewer and water systems
           greatly influence growth, they also represent the single largest
           capital investment for most municipalities. In addition, the
           connection costs for public water and sewer can create a financial
           burden on low and moderate income property owners. Therefore, the
           County will allocate an additional $150,000.00 during the 3 year
           funding cycle to any municipality which utilizes its CDBG Program
           allocation for the acquisition, construction, reconstruction,
           rehabilitation or installation of public water and sanitary sewer
           systems which are consistent with the land use portion of the
           County Comprehensive Plan..

           2. The County encourages the consolidation of existing, small,
           privately-owned water companies, or the purchase of these companies
           by municipalities or authorities. Therefore, the County will
           allocate an additional $100,000.00 during the 3 year funding cycle
           to any municipality which utilizes its CDBG Program allocation for
           the acquisition of private water companies.

           B. Multi-Municipal/Regional Projects - The County encourages and
           desires to foster multi-municipal activities and activities that
           have a regional impact. Therefore, the County will allocate up to
           an additional $200,000.00 during the 3 year funding cycle for any
           project that involves the cooperation of two or more
           municipalities, coordination of two or more municipalities, or has
           a positive impact on two or more municipalities. Examples include:
           the rehabilitation of a road which runs through two municipalities;
           the construction or rehabilitation of a wastewater treatment plant
           that serves two or more municipalities; the construction of or
           improve to a park which serves the residents of two or more
           municipalities; or the construction or rehabilitation of a sanitary
           sewerage collection system.

           C. Municipal Consolidation - As part of its overall
           intergovernmental cooperation policy, the County encourages
           municipal consolidation. Municipal government is becoming more and
           more complex. While all county municipalities are doing an adequate
           job of serving their residents, in certain situations, the
           consolidation of two or more would sometimes provide better
           services for all citizens. To encourage the consolidation of
           municipalities where it is feasible, the County will allocate up to
           $25,000.00 towards the cost of studies necessary for the
           consolidation. Studies include but are not limited to: financial
           impact analysis, service impact analysis; infrastructure surveys;
           resource studies, etc. Upon a consolidation the allocation for the
           remaining municipality shall be those funds remaining from the
           municipal allocations of the current 3 year cycle and the
           combination of municipal allocations during the next 3 year cycle.

           D. Economic Development Activities - The County will allocate an
           additional $100,000.00 during the 3 year cycle to any municipality
           which undertakes an economic development activity which creates or
           retains at least 51% of the resulting jobs for low and moderate
           income persons.

           E. County Departments - Should the Board of County Commissioners
           decide to provide CDBG Program funding for such a project, an
           interdepartmental agreement shall be executed which outlines the
           departments involved, general information concerning the project, a
           schedule, a budget, and the duties of each department.

           F. Comprehensive Plan Consistency - The County will allocate an
           additional $25,000.00 during any 3 year funding cycle to a
           municipality which whose new or current comprehensive plan is
           generally consistent with the County Comprehensive Plan.


       Planning Activities
      The following shall constitute the policy of the Berks County Board of
      Commissioners. It shall be applied to all requests for planning funds
      from the CDBG Program. The goal of this policy is to encourage the
      implementation of the principles of the County Comprehensive Plan when
      using County CDBG Program funds for planning activities. The objectives
      of the policy are as follows::

           A. To identify and encourage regional cooperative planning efforts.

           B. To encourage the development of plans in municipalities that are
           most in need of planning.

           C. To create greater dialogue during the local comprehensive
           planning process between local municipalities and the County.

           D. To improve the quality of local comprehensive plans and make the
           local comprehensive planning process more meaningful to local
           government.

           E. To operate within the constraints of the 20% limitation of the
           CDBG Program for planning and administration with first priority
           for planning funds to go to County planning activities.

      The County shall use the following priorities when allocating CDBG
      Program funds for planning:

           A. All planning and administration needs of the County will first
           be met before any local planning activities are considered.

           B. Priority for funds that remain will be given to funding local
           comprehensive plans. In accordance with the Municipalities Planning
           Code, these plans will be generally consistent with the County
           Comprehensive Plan.

           C. Priority for the funding of local comprehensive plans will be
           given to municipalities that engage in joint municipal planning
           efforts.

      The County desires to increase its involvement in local planning efforts
      through the following:

           A. The County Planning staff will have a greater role in the
           ongoing development of CDBG Program funded local comprehensive
           plans and other local planning studies. Periodic meetings and
           dialogue between the municipality and the Planning staff during
           plan preparation will be strongly encouraged.

           B. The County Planning staff will administer the procurement
           process for all professional planning services provided by the CDBG
           Program. The Planning staff and the municipality will work together
           to develop the initial work program and request for proposals. The
           selection of the consultant will be a joint decision of the
           municipality and the County.

           C. The County Planning staff will jointly monitor and administer
           all professional service planning contracts in partnership with the
           local governments that are involved.

      To foster multi-municipal planning efforts, the County has established
      the following new initiatives:

           A. The County directs that a Local Planning Partnership Fund be
           established to be used by the County to encourage local planning
           activities of exceptional value and importance. This fund will be
           used to promote joint municipal planning, intergovernmental and
           regional cooperation, innovative land development techniques,
           agricultural preservation planning, and other principles described
           in the County Comprehensive Plan. The amount in the fund shall be
           established by subtracting all County planning and administration
           requirements from the 20% limitation of the CDBG Program. The
           remainder shall be available for the Local Planning Partnership
           Fund.

           B. The County directs the Planning staff to conduct an analysis of
           local plans and to target municipalities that might present good
           opportunities for the use of the Local Planning Partnership Fund.
           The Planning staff, in their analysis, shall consider age and
           quality of local plans, areas experiencing strong development
           pressure, and opportunities for regional joint planning efforts.

      To allow for local planning other than multi-municipal efforts, the
      County will use CDBG Program funds as follows:

           A. In the event that funds are available after meeting the
           requirements of the Local Planning Partnership Fund, individual
           municipal comprehensive plans can be funded. In these cases, the
           municipality must be unable to participate in a joint plan.

           B. Municipalities that are unwilling to consider joint municipal
           plans will not be considered.

           C. Funds will be granted on a 50/50 matching basis provided the
           municipality is willing to allow the involvement of County Planning
           staff as previously described under County Involvement.

           D. To minimize demand on the 20% limitation, first priority will be
           given to municipalities that can make an exchange of local funds
           for CDBG Program funds. (e.g. A comprehensive plan is estimated to
           cost $20,000. The CDBG Program share would be $10,000. If the
           municipality can use $10,000 on a local infrastructure project and
           pay for the entire plan with its own local funds, this arrangement
           is preferred. Under this mechanism, the $10,000 of CDBG Program
           funds is provided to the municipality but does not count against
           the planning and administration limitation.)


 
Economic Development

      The County recognizes that, in accordance with the requirements of 24
      CFR part 570.501, it is responsible for ensuring that CDBG Program funds
      are used in accordance with all program requirements. The County
      realizes that the use of designated public agencies, subrecipients, or
      contractors does not relieve it of this responsibility. Therefore, in
      carrying out special economic development activities, the County will
      insure compliance with all program regulations and guidelines whether
      the activity is implemented by a public agency, a subrecipient, or a
      contractor.

      The County recognizes the need to distinguish between the terms
      “economic development” and “special economic development” as used in the
      CDBG Program. The former term can be interpreted very broadly to include
      all endeavors aimed at sustaining or increasing the level of business
      activity. As such, most CDBG activities could be viewed as “economic
      development”. In contrast, the term “special economic development” is
      used in the CDBG Program to identify the types of activities noted in
      this Policy and identified at 24 CFR Part 570.203 (a) and (b).

      Special economic development activities are a permitted use in the CDBG
      Program as noted at 24 CFR Part 570.203. These activities may be carried
      out by the County, a public or private non-profit entity, or by a
      private for profit business. In this regard, the County has
      distinguished between the three types of recipient, i.e. the County
      itself, a public or private non-profit agency, and a private for profit
      business.

           A. County-Sponsored Projects

           In accordance with applicable regulations, the County may utilize
           CDBG Program funds in support of a special economic development
           activity implemented by a County agency involving the acquisition,
           construction, reconstruction, rehabilitation or installation of
           commercial or industrial buildings, structures, and other real
           property equipment and improvements (24 CFR 570.203(a)).

           The County will evaluate proposals from any County department or
           office for funding of an activity noted above to determine the
           appropriateness of such activity, to insure its eligibility, and to
           determine that it meets a national objective. Special economic
           development activities will be considered for funding only after
           financial obligations to community participants and other
           activities such as housing rehabilitation and administration are
           funded as outlined in this policy.

           In situations involving County sponsored special economic
           development projects, the funds provided are not expected to be
           recaptured and the primary consideration for funding will be
           related to the potential for job creation or the removal of a
           blighting influence that impedes economic development.

           B. Public or Private Non-profit Subrecipients

           The policy for funding public or private non-profit subrecipients
           for special economic development activities parallels that for
           County sponsored projects. However, the County may fund a special
           economic activity requested by a private or public non-profit when
           specifically endorsed by a participating jurisdiction and said
           jurisdiction agrees to the utilization of its guaranteed allocation
           for such activity. Such funding will depend on the County's
           evaluation of the activity to insure that all program requirements
           are satisfied including the eligibility and fundability of such
           activity.

           In addition, the County will execute a subrecipient agreement
           directly with the private or public non-profit entity. This
           subrecipient agreement will outline the specific justification for
           providing assistance to the non-profit entity for the special
           economic development activity.

           In the case of loan assistance provided for the acquisition and/or
           the rehabilitation of real estate, a permanent lien will be
           attached to the property and repayment of the loan will be required
           at the time of transfer of said real estate to another entity or
           other terms as agreed upon.

           If the justification for the special economic development activity
           is the creation of jobs for low-moderate income persons, the
           following conditions will apply and will be included in the
           agreement:

           1. At least one permanent full time equivalent job is created or
           retained for each $10,000 of the CDBG assistance provided;

           2. at least 51% of all full time equivalent jobs are available to
           or retained by low/moderate income persons;

           3. the non-profit entity must meet the low-mod job creation
           requirement within three years of the award of assistance;

           4. a lien will be placed on the property requiring loan repayment
           if the non- profit entity does not meet the low-moderate income job
           creation provision within the three year performance period.
           Otherwise, the loan will be repaid at the time of transfer of the
           property to a third party or other terms as mutually agreed upon;

           5. the County may request the non-profit to pay interest on the
           loan based on a percentage of income received by the non-profit
           through use or rental of the property in excess of the maintenance
           and operation costs of the property. Such percentage will be
           negotiated on a case by case basis based on initial pro-forma
           information provided by the borrower and an annual review of the
           borrower's profit/loss statement.

           C. Municipal Projects

           A municipality participating in the County CDBG Program may decide
           to utilize its guaranteed funding during any three year cycle for a
           “special economic development” activity. In those cases when a
           participating jurisdiction intends to utilize its guaranteed
           funding for a municipal sponsored project, the County will evaluate
           the project to ensure that all eligibility and fundability
           requirements are satisfied. In this situation, the funds will be
           allocated by the County to the municipality with no repayment to
           the County required, unless the project is later determined to be
           unfundable by the CDBG Program.

           In those instances when the municipality agrees to allow a public
           or private nonprofit entity or a private for-profit business to
           utilize its guaranteed funding during any three year cycle, then
           the policies as enumerated under 2) above will apply as
           appropriate.

           D. Projects implemented by specially created Authorities

           There may be occasions when a specially created authority (i.e.
           Redevelopment Authority, Airport Authority, etc.) will seek funding
           directly from the County to carry out a special economic
           development activity on its own.

           Such projects will be considered for funding by the County only
           after all other financial obligations for community participants
           and other activities as outlined in this policy are satisfied. The
           project will be evaluated by the County to insure compliance with
           all program requirement including the eligibility and fundability
           of the project.

           If the justification for the special economic development activity
           is the creation of jobs for low-moderate income persons, then the
           conditions outlined under 2) above will apply.

           E. Private for Profit Business (Reserved)



      V. CDBG PROGRAM ELIGIBLE ACTIVITIES

      CDBG Program funds may be used for the following activities:

      A. The acquisition of real property (including air rights, water rights,
      and other interests therein) which is:

           1. blighted, deteriorated, deteriorating, undeveloped, or
           inappropriately developed from the standpoint of sound community
           development and growth;

           2. appropriate for rehabilitation or conservation activities;

           3. appropriate for the preservation or restoration of historic
           sites, the beautification of urban land, the conservation of open
           spaces, natural resources, and scenic areas, the provision of
           recreational opportunities, or the guidance of urban development;

           4. to be used for the provision of public works, facilities and
           improvements eligible for assistance under this title; or

           5. to be used or other public purposes..

      B. The acquisition, construction, reconstruction, or installation
      (including design features and improvements with respect to such
      construction, reconstruction, or installation that promote energy
      efficiency) of public works, facilities (except for buildings for the
      general conduct of government), and site or other improvements;

      C. Code enforcement in deteriorated or deteriorating areas in which such
      enforcement, together with public improvements and services to be
      provided, may be expected to arrest the decline of the area;

      D. Clearance, demolition, removal and rehabilitation including
      rehabilitation which promotes energy efficiency of buildings and
      improvements including interim assistance, and financing public or
      private acquisition for rehabilitation, rehabilitation of privately
      owned properties, and including the renovation of closed school
      buildings;

      E. Special projects directed to the removal of material and
      architectural barriers which restrict the mobility and accessibility of
      elderly and handicapped persons;

      F. Payments to housing owners for losses of rental income incurred in
      holding for temporary periods housing units to be utilized for the
      relocation of individuals and families displaced by activities under
      this title;

      G. Disposition (through sale, lease, donation, or otherwise) of any real
      property acquired pursuant to this title or its retention for public
      purposes;

      H. Provision of public services, including but not limited to those
      concerned with employment, crime prevention, child care, health, drug
      abuse, education, energy conservation, welfare or recreation needs, if
      such services have not been provided by the unit of general local
      government (through funds raised by such nit, or received by such unit
      from the State in which it is located) during any part of the
      twelve-month period immediately preceding the date of submission of the
      statement with respect to which funds are to be made available under
      this title, and which are to be used for such services, unless the
      Secretary finds that the discontinuation of such services was the result
      of events not within the control of the unit of general local
      government, except that not more than 15 percent of the amount of any
      assistance to a unit of general local government under this title may be
      used for activities under this paragraph unless such unit of general
      local government used more than 15 percent of the assistance received
      under this title for fiscal year 1982 or fiscal year 1983 for such
      activities (excluding any assistance received pursuant to Public Law
      98-8), in which case such unit of general local government may use not
      more than the percentages or amount of such assistance use for such
      activities for such fiscal year, whichever method of calculation yields
      the higher amount;

      I. Payment of the non-Federal share required in connection with a
      Federal grant-in-aid program undertaken as part of the activities
      assisted under this title;

      J. Payment of the cost of completing a project funded under Title 1 of
      the Housing Act of 1949;

      K. Relocation payments and assistance for displaced individuals,
      families, businesses, organizations, and farm operations, when
      determined by the grantee to be appropriate;

      L. Activities necessary to:

           1. to develop a comprehensive community development plan; and

           2. to develop a policy-planning-management capacity so that the
           recipient of assistance under this title may more rationally and
           effectively: (i) determine its needs, (ii) set long term goals and
           short term objectives, (iii) devise programs and activities to meet
           these goals and objectives, (iv) evaluate the progress of such
           programs in accomplishing these goals and objectives, (v) carry out
           management, coordination, and monitoring of activities necessary
           for effective planning implementation.

           3. Payment of reasonable administrative costs and carrying charges
           related to the planning and execution of community development and
           housing activities, including the provision of information and
           resources to residents of areas in which community development and
           housing activities are to be concentrated with respect to the
           planning and execution of such activities and including the
           carrying out of activities as described in Section 701(e) of the
           Housing Act of 1954 on the date prior to the date of enactment of
           the Housing and Community Development Amendments of 1981;

      M. Activities which are carried out by public or private nonprofit
      entities, including:

           1. acquisition of real property;

           2. acquisition, construction, reconstruction, rehabilitation, or
           installation of (i) public facilities (except for buildings for the
           general conduct of government), site improvements and utilities,
           and (ii) commercial or industrial buildings or structures and other
           commercial or industrial buildings or structures and other
           commercial or industrial real property improvements;

           3. planning.

      N. Assistance to neighborhood based nonprofit organizations, local
      development corporations or entities organized under Section 301(d) of
      the Small Business Investment Act of 1958 to carry out a neighborhood
      revitalization or community economic development project in furtherance
      of the objectives of section 101(c), and assistance to
      neighborhood-based nonprofit organizations, or other private or public
      nonprofit organizations, for the purpose of assisting, as part of
      neighborhood revitalization or other community development, the
      development of shared housing opportunities (other than by construction
      of new facilities) in which elderly families (as defined in Section
      3(b)(3) of the United States Housing Act of 1937) benefit as a result of
      living in a dwelling in which the facilities are shared with others in a
      manner that effectively and efficiently meets the housing needs of the
      residents and thereby reduces their cost of housing;

      O. Activities necessary to the development of energy use strategies
      related to a recipient's development goals, to assure that those goals
      are achieved with maximum energy efficiency, including items such as:

           1. an analysis of the manner in, and the extent to, which energy
           conservation objectives will be integrated into local government
           operations, purchasing and service delivery, capital improvements
           budgeting, waste management, district heating and cooling, land use
           planning and zoning, and traffic control, parking, and public
           transportation functions; and

           2. a statement of the actions the recipient will take to foster
           energy conservation and the use of renewable energy resources in
           the private sector, including the enactment and enforcement of
           local codes and ordinances to encourage or mandate energy
           resources, financial and other assistance to be provided
           (principally for the benefit of low-and moderate-income persons) to
           make energy conserving improvements to residential structures, and
           any other proposed energy conservation activities;

      P. Provision of assistance to private, for profit entities, when the
      assistance is necessary or appropriate to carry out an economic
      development project;

      Q. The rehabilitation or development of housing assisted under Section
      17 of the United States Housing Act of 1937; and

      R. Provision of assistance to facilitate substantial reconstruction of
      housing owned and occupied by low income persons: A. where the need for
      the reconstruction was not determinable until after rehabilitation under
      this section had already commenced, or B. where the reconstruction is
      part of a neighborhood rehabilitation effort and the County determines
      the housing is not suitable for rehabilitation and demonstrates to the
      satisfaction of the Secretary that the cost of substantial
      reconstruction is significantly less than the cost of new construction
      and less than the fair market value of the property after substantial
      reconstruction.

      S. Provision of direct assistance to facilitate and expand home
      ownership among persons of low income (except that such assistance shall
      not be considered a public service for purposes of paragraph H. by using
      such assistance to:

           Subsidize interest rates and mortgage principal amounts for low
           income homebuyers;

           2. Finance the acquisition by low income homebuyers of housing that
           is occupied by the homeowners;

           3. Acquire guarantees for mortgage financing obtained by low- and
           moderate- income homebuyers from private lenders (except that
           amounts received under this title may not be used under this
           subparagraph to directly guarantee such mortgage financing and
           grantees under this title may not directly provide such
           guarantees);

           4. Provide up to 50 percent of any downpayment required from low
           income homebuyer; or

           5. Pay reasonable closing costs (normally associated with the
           purchase of a home) Incurred by a low income homebuyers.

      In any case in which an assisted activity described in paragraph M. or
      P. is identified as principally benefitting persons of low income, such
      activity shall: 1. be carried out in a neighborhood consisting
      predominantly of persons of low income and provide services for such
      persons; or 2. involve facilities designed for use predominantly by
      persons of low income; or 3. involve employment of persons, a majority
      of whom are persons of low income.

      In any case in which an assisted activity is designed to serve an area
      generally and is clearly designed to meet identified needs of persons of
      low income in such area, such activity shall be considered to
      principally benefit persons of low income if:

           A. not less than 51 percent of the residents of such area are
           persons of low income; or

           B. in any metropolitan city or urban county, the area served by
           such activity is within the highest quartile of all areas within
           the jurisdiction of such city or county in terms of the degree of
           concentration of persons of low income.

      The requirements of the preceding paragraph do not prevent the use of
      assistance for the development, establishment, and operation for not to
      exceed 2 years after its establishment of a uniform emergency telephone
      number system if the Secretary determines that:

           A. such system will contribute substantially to the safety of the
           residents of the area served by such system;

           B. not less than 51 percent of the use of the system will be by
           persons of low income; and

           C. other Federal funds received by the grantee are not available
           for the development, establishment, and operation of such system
           due to the insufficiency of the amount of such funds, the
           restrictions on the use of such funds, or the prior commitment of
           such funds for other purposes by the grantee.

      The percentage of the cost of the development, establishment, and
      operation of such a system that may be paid from assistance under this
      title and that is considered to benefit low income persons is the
      percentage of the population to be served that is made up of persons of
      low income.

      Any assisted activity under this title that involves the acquisition or
      rehabilitation of property to provide housing shall be considered to
      benefit persons of low and moderate income only to the extent such
      housing will, upon completion, be occupied by such persons.


      VI. CDBG PROGRAM INELIGIBLE ACTIVITIES

      The general rule is that any activity that is not authorized under the
      provisions of 570.206 is ineligible to be assisted with CDBG Program
      funds. This section identifies specific activities that are ineligible
      and provides guidance in determining the eligibility of other activities
      frequently associated with housing and community development. The
      following activities may not be assisted with CDBG Program funds:

           A. Buildings or portions thereof, used for the general conduct of
           government as defined at §570.3(d) cannot be assisted with CDBG
           funds. This does not exclude, however, the removal of architectural
           barriers under §570.201(k) involving any such building. Also, where
           acquisition of real property includes an existing improvement which
           is to be used in the provision of a building for the general
           conduct of government, the portion of the acquisition cost
           attributable to the land is eligible, provided such acquisition
           meets a national objective described in §570.208.

           B. General government expenses. Except as otherwise specifically
           authorized in this subpart or under OMB Circular A-87, expenses
           required to carry out the regular responsibilities of the unit of
           general local government are not eligible for assistance under this
           part.

           C. Political activities. CDBG Program funds shall not be used to
           finance the use of facilities or equipment for political purposes
           or to engage in other partisan political activities, such as
           candidate forums, voter transportation, or voter registration.
           However, a facility originally assisted with CDBG Program funds may
           be used on an incidental basis to hold political meetings,
           candidate forums, or voter registration campaigns, provided that
           all parties and organizations have access to the facility on an
           equal basis, and are assessed equal rent or use charges, if any.

      The following activities may not be assisted with CDBG Program funds
      unless authorized under provisions of §570.203 or as otherwise
      specifically noted herein, or when carried out by a subrecipient under
      the provisions of §570.204.

           A. Purchase of equipment. The purchase of equipment with CDBG
           Program funds is generally ineligible.

           B. Construction equipment. The purchase of construction equipment
           is ineligible, but compensation for the use of such equipment
           through leasing, depreciation, or use allowances pursuant to OMB
           Circulars A-21, A-87 or A-122 as applicable for an otherwise
           eligible activity is an eligible use of CDBG Program funds.
           However, the purchase of construction equipment for use as part of
           a solid waste disposal facility is eligible under §570.201(c).

           C. Fire protection equipment. Fire protection equipment is
           considered for this purpose to be an integral part of a public
           facility and thus, purchase of such equipment would be eligible
           under §570.201(c).

           D. Furnishings and personal property. The purchase of equipment,
           fixtures, motor vehicles, furnishings, or other personal property
           not an integral structural fixture is generally ineligible. CDBG
           Program funds may be used, however, to purchase or to pay
           depreciation or use allowances (in accordance with OMB Circulars
           A-21, A-87 or A-122, as applicable) for such items when necessary
           for use by a recipient or its subrecipients in the administration
           of activities assisted with CDBG Program funds, or when eligible as
           fire fighting equipment, or when such items constitute all or part
           of a public service pursuant to §570.201(e).

           E. Operating and maintenance expenses. The general rule is that any
           expense associated with repairing, operating or maintaining public
           facilities, improvements and services is ineligible. Specific
           exceptions to this general rule are operating and maintenance
           expenses associated with public service activities, interim
           assistance, and office space for program staff employed in carrying
           out the CDBG Program. For example, the use of CDBG Program funds to
           pay the allocable costs of operating and maintaining a facility
           used in providing a public service would be eligible under
           §570.201(e), even if no other costs of providing such a service are
           assisted with such funds. Examples of ineligible operating and
           maintenance expenses are:

           1. Maintenance and repair of streets, parks, playgrounds, water and
           sewer facilities, neighborhood facilities, senior centers, centers
           for the handicapped, parking and similar public facilities.
           Examples of maintenance and repair activities for which CDBG
           Program funds may not be used include the filling of pot holes in
           streets, repairing of cracks in sidewalks, the mowing of
           recreational areas, and the replacement of expended street light
           bulbs; and

           2. Payment of salaries for staff, utility costs and similar
           expenses necessary for the operation of public works and
           facilities.

           F. New housing construction. For the purpose of this paragraph,
           activities in support of the development of low income housing
           including clearance, site assemblage, provision of site
           improvements and provision of public improvements and certain
           housing preconstruction costs set forth in §570.206(g), are not
           considered as activities to subsidize or assist new residential
           construction. CDBG Program funds may not be used for the
           construction of new permanent residential structures or for any
           program to subsidize or assist such new construction, except: 1. as
           provided under the last resort housing provisions set forth in 24
           CFR Part 42; 2. as authorized under §570.201(m); or 3. When carried
           out by a subrecipient pursuant to §570.204(a);

           G. Income payments. The general rule is that CDBG Program funds
           shall not be used for income payments for housing or any other
           purpose. Examples of ineligible income payments include: payments
           for income maintenance, housing allowances, down payments, and
           mortgage subsidies.


     VII. CDBG PROGRAM NATIONAL OBJECTIVES

      In order to be eligible for funding, every CDBG Program-funded activity
      must qualify as meeting one of the three national objectives of the
      Program. This requires that each activity, except program administration
      and planning, meet specific tests for either:

           • Benefitting low and moderate (L/M) income persons;

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

           • Meeting other community development needs having a particular
           urgency because existing conditions pose a serious and immediate
           threat to the health or welfare of the community and other
           financial resources are not available to meet such needs.

      Activities considered to benefit low and moderate income persons are
      divided into four categories: (1) area benefit activities; (2) limited
      clientele activities; (3) housing activities; and (4) job creation or
      retention activities.

      Activities considered under the national objective of slums/blight are
      divided into three categories: (1) an area basis; (2) a spot basis; or
      (3) urban renewal completion. Various records and documentation must be
      maintained for either category.

      To comply with the national objective of meeting community development
      needs having a particular urgency, an activity must be designed to
      alleviate existing conditions which the County certifies: (1) pose a
      serious and immediate threat to the health or welfare of the community;
      (2) are of recent origin or recently became urgent; (3) the County is
      unable to finance on its own; and (4) other resources of funds are not
      available. A condition will generally be considered to be of recent
      origin if it developed or became critical within 18 months preceding the
      County's certification.

      Application Procedures
      An original and one copy of the request form must be submitted to the
      Berks County Community Development Office, County Services Center - 14th
      Floor, 633 Court Street, Reading, PA 19601 by July 31, 2000. All
      required additional information must be included with the application.


      VIII. THE HOME PROGRAM
      General Information

      The HOME Program affirms the Federal government's commitment to provide
      decent, sate and affordable housing to all Americans, and to alleviate
      the problems of excessive rent burdens, homelessness and deteriorating
      housing stock in the nation. Since 1992, the County of Berks has
      received HOME Program funds as a participating jurisdiction. For the
      FFY2000 Program Year, the grant was $526,000.00. The County anticipates
      receiving approximately the same amount each year for FFY2000-2002.

      Purpose of HOME Program
      The HOME Program affirms the Federal government's commitment to provide
      decent, sate and affordable housing to all Americans, and to alleviate
      the problems of excessive rent burdens, homelessness and deteriorating
      housing stock in the nation. As recommended by the National Housing Task
      Force in 1988, the HOME Program provides funding and general guidelines
      to State and local governments and empowers them to design and tailor
      affordable housing strategies to address local needs and housing
      conditions. The HOME Program strives to meet both the short-term goal of
      increasing the supply and availability of affordable housing, and the
      long-term goal of building partnerships between State and local
      governments and private and nonprofit organizations and strengthening
      their capacity to meet the housing needs of low and very low income
      residents.

      Eligible Activities

      HOME Program funds may be used for a variety of activities to develop
      and support affordable housing. Eligible activities include:
      tenant-based rental assistance, assistance to first-time homebuyers and
      existing homeowners, property acquisition, new construction,
      reconstruction, moderate or substantial rehabilitation, site
      improvements, demolition, relocation expenses and other reasonable and
      necessary expenses related to development of non-luxury housing.

           A. Administrative Costs. Participating jurisdictions may use up to
           ten percent of its HOME allocation for planning and administrative
           costs of the HOME Program. Up to 5 percent of the annual allocation
           may be used for community housing development organization (CHDO)
           operating expenses.

           B. Tenant-Based Assistance. HOME Program funds may be used for
           tenant-based assistance in any participating jurisdiction. The
           following conditions apply for such use of funds: (i) The
           participating jurisdiction certifies that such assistance is an
           essential element of its annual housing strategy and specifies the
           local market conditions leading to this determination; and (ii) The
           tenant-based rental assistance is provided in accordance with
           written tenant selection policies and criteria that are consistent
           with the purposes of providing housing to very low- and low-income
           families and are reasonably related to the Federal preference
           rules.

           The tenant-based assistance program may be operated by the
           participating jurisdiction or it may be contracted out to another
           capable entity (such as a public housing authority). The following
           requirements govern tenant-based rental assistance: (i) Rental
           assistance contracts may not exceed 24 months, although they may be
           renewed; (ii) Rents must be reasonable, as compared with comparable
           unassisted units; (iii) Lease requirements must be equitable to the
           tenant; (iv) A participating jurisdiction may not pay more than the
           difference between a rent standard for the unit size (established
           by the participating jurisdiction) and 30 percent of the family's
           monthly adjusted income. This rent standard may not be less than 80
           percent of the Section 8 Existing Housing fair market rent for the
           unit size, nor more than HUD approved community-wide exception
           rent; (v) The participating jurisdiction must require a minimum
           contribution toward rent for each tenant; and (vi) Units must meet
           Section 8 Housing Quality Standards.

           C. Rehabilitation. The HOME Program permits the use of funds for
           rehabilitation, since rehabilitation can be a cost effective
           development strategy. HOME funds may be used for the rehabilitation
           of both rental and homeowner-occupied housing. A participating
           jurisdiction shall give preference to rehabilitation of substandard
           housing unless it determines that: (i) Rehabilitation is not the
           most cost-effective way to meet housing needs to expand the supply
           of affordable housing in that neighborhoods; and (ii) The
           participating jurisdiction's housing needs, within the
           neighborhoods, cannot be met through rehabilitation of available
           stock.

           D. New Construction. The HOME Program permits the use of funds for
           new construction of housing units.

      Ineligible Activities
      HOME Program funds may not be used to pay for public housing
      modernization, tenant subsidies for certain special mandated purposes
      under Section 8, matching funds for other Federal programs, Annual
      Contributions Contracts (ACCs), activities under the Low-Income Housing
      Preservation Acts of 1987 and 1990, and operating subsidies for rental
      housing. Additionally, the funds cannot be used to create a reserve
      account for replacements, a project reserve account for unanticipated
      increases in operating costs, or operating subsidies.

      Various Activity Requirements
      HOME Program funds invested in rental housing must meet the following
      income targeting requirements for the program as a whole:

           A. least 90 percent of such funds must be invested in units that
           are occupied by families whose incomes do not exceed 60 percent of
           the median family income for the area; and

           B. the remaining funds (up to 10 percent) must be invested in units
           occupied by families below 80 percent of median income.

      Each rental project must meet the following affordability tests:

           A. have rents at or below the lesser of either the existing Section
           8 Fair Market Rent, or 30 percent of the adjusted income of a
           family whose income equals 65 percent of the median income for the
           area;

           B. remain affordable for the following terms based on the average
           HOME Program subsidy per unit:

            rehabilitation of up to $15,000:         5 years
            rehabilitation from $15,000 - $40,000    10 years
            rehabilitation from $40,000 +            15 years
            new construction (any amount)            20 years

           C. for projects of 3 or more units, have at least 20 percent of its
           units occupied by very low income families paying not more than 30
           percent of monthly adjusted gross income for rent, or bearing rents
           not greater than 30 percent of the gross income of a family whose
           income equals 50 percent of the median income for the area.

      All of the HOME Program funds used for home ownership assistance must
      benefit first-time homebuyers (including displaced homemakers and single
      parents who may have once owned a home with a spouse), or existing low
      income homeowners whose family incomes are at or below 80% of the area
      median income. In addition:

           A. the assisted housing must be the owner's principal residence;

           B. the purchase price of the property, or the appraised value of a
           property already owned, after rehabilitation must not exceed 95
           percent of median area purchase price; and

           C. resale of the property by a first-time homebuyer is subject to
           restrictions that are established 
 

 

by the participating jurisdiction
           or recapture of the HOME subsidy; either option must be determined
           by the Secretary to be appropriate.

      To ensure that units developed with HOME Program funds are non-luxury,
      affordable units, HUD has established a maximum per unit HOME Program
      subsidy on a market-by-market basis, adjusted for unit size, which will
      be updated and adjusted for inflation annually.

      All HOME-assisted units must meet local codes and standards, and, at a
      minimum, Section 8 Housing Quality Standards.

      Obligations of HOME Program
      All jurisdictions shall make contributions to housing that qualifies as
      affordable housing under the Act. The required contribution, or “match”
      is $0.25 for every $1.00 of HOME Program funds. The HOME Program funds
      are utilized:

      Matching funds must be used for HOME-assisted projects, and requirements
      will be calculated on a project-by-project basis and applied on a
      program-wide basis. A participating jurisdiction is required to match,
      by the end of each fiscal year, all HOME funds expended during that
      year, but is not required to match funds used to cover administrative
      expenses or fill the gap to meet the threshold unless the State
      transfers its funds to a local jurisdiction. A participating
      jurisdiction incurs a “match liability” each time it draws funds from
      its HOME Investment Trust Fund. The match payment must be expended by
      the end of each fiscal year, September 30.

      As a general rule of thumb, investments which are contributions from the
      State/local government or private sources will be eligible to qualify as
      a matching contribution. Eligible sources of match include cash; the
      value of foregone interest, taxes, fees or charges; appraised value of
      land or real property; investments in on- or off-site improvements, bond
      financing donated construction materials and voluntary labor. Ineligible
      match sources include other Federal funds and CDBG Program funds.

      Building Partnerships with Nonprofit Organizations
      Each participating jurisdiction receiving HOME Program funds is required
      to reserve at least 15 percent of the funds for housing to be developed,
      sponsored or owned by CHDOs. A CHDO is a private, nonprofit organization
      which:

           A. has among its purposes, the provision of decent housing that is
           affordable to low- income and moderate-income persons;

           B. has demonstrated its capacity for carrying out activities
           assisted with HOME funds;

           C. has a history of serving the community within which the housing
           to be assisted with HOME funds is to be located;

           D. is organized under State or local laws;

           E. has standards of financial accountability; and

           F. has a tax exemption under section 501(c) of the Internal Revenue
           Code.

      To maintain accountability to low income community residents, at least
      one-third of a CHDO's governing board must be low income residents or
      elected representatives of such residents. CHDOs must maintain a formal
      process for low income residents and program beneficiaries to advise the
      organization on relevant decisions. A CHDO cannot be a public body, nor
      be controlled by, or under the direction of, individuals or entities
      seeking to derive profit or gain from the organization. A CHDO may be
      sponsored or created by a for-profit entity if:

           A. the primary purpose of the for-profit entity is not the
           development or management of housing; and

           B. the CHDO is free to contract for goods and services from vendors
           of its own choosing.

      If a CHDO is sponsored by a public agency or for-profit entity the
      sponsoring entity may not appoint more than one-third of the membership
      of the organization's governing body. For publicly sponsored CHDO's,
      board members appointed by the unit of government may not appoint
      remaining board members

      Up to 15 percent of a participating jurisdiction's CHDO set-aside may be
      used for project-specific technical assistance, site control and seed
      money loans. Any portion of the 15 percent of a participating
      jurisdiction's allocation which is not reserved for CHDOs within the
      24-month period after they have been made available, will be deducted
      from that jurisdiction's HOME Program allocation and reallocated to
      other jurisdictions for use by CHDOs.

      To date, the County has recognized Berks Community Action Program, Inc.
      and Berks Housing Opportunities, Inc. as its designated CHDOs.

      Allocation of Funds

      The County will allocate sufficient funds to insure the proper planning
      and administration of its HOME Program.

      Based on these guidelines, the County of Berks will utilize funding of
      the FFY2000-2002 cycle generally as follows:
       Non-profit Rental Housing Projects                20%
       Property Rehabilitation Program                   40%
       The Next Step Program                             15%
       CHDO Activities                                   15%
       Planning and Administration                       10%

      Prior to the approval of any County HOME Program funds for the
      development of new subsidized housing with 20 or more units, the County
      shall require the following:

        1. A detailed market study or other documentation demonstrating the
           demand for the number of units proposed for the targeted area. At a
           minimum, the study must be completed by a competent market
           professional with demonstrable experience in Pennsylvania
           affordable housing markets, provide a description of the proposed
           site, provide demographic analysis of the number of households in
           the market area which are income eligible and can afford to pay the
           proposed rent, provide geographic definition and analysis of the
           market area, provide a description of rent levels and vacancy and
           turnover rates of comparable properties, provide an analysis of
           expected market absorption on the proposed project including a
           description of the effect on the market area, identify other
           subsidized properties potentially affected by the proposed project,
           and provide a needs assessment addressing the specific features of
           the proposed project which enhance its marketability or the
           specific projected rental housing needs within the community which
           will be addressed by the proposed project.
        2. A detailed supportive services plan demonstrating the availability
           and accessibility of those services needed by the intended
           residents.
        3. Availability of a rent subsidy, to insure that tenants will pay no
           more than 30% of income for shelter costs will be needed for some
           of these proposed projects. This rent subsidy may be from Section 8
           Project Based Certificate Program, or a fund established through
           reinvestment of all or part of the developer’s fees.
        4. A clear rationale for the selection of the proposed site and a
           demonstration of local support for the proposed project.
        5. Indication of other funding sources to be committed to the project.

      Application Procedures
      An original and one copy of the funding request from local non-profit
      organizations must be submitted to the Berks County Community
      Development Office, County Services Center - 14th Floor, 633 Court
      Street, Reading, PA 19601 by July 31, 2000. Demonstration of the ability
      to supply matching funds must be included in the application. Any
      activity funded by the County's HOME Program shall be consistent with
      the goals and objectives of the County's Comprehensive Plan and
      Consolidated Plan.


      IX. THE ESG PROGRAM

      General Information
      The ESG Program awards grants for the rehabilitation or conversion of
      buildings into homeless shelters. It also funds certain related social
      services, operating expenses, homeless prevention activities, and
      administrative costs. The Program supplements State, local, and private
      efforts to improve the quality and number of emergency homeless
      shelters. By funding emergency shelter and related social services, the
      ESG Program provides a foundation for homeless people to begin moving to
      independent living.

      The County of Berks has administered a program to support the repair and
      operations of emergency shelters for the homeless since 1986. Priority
      will be given to applications which support the repairs and operations
      of shelters for parents with children - shelters which work towards the
      goal of reestablishing the family in suitable permanent housing.
      Shelters which provide comprehensive, thoroughly administered services
      which can document success in transitioning clients to permanent housing
      will be given priority.

      Eligible Activities

      Emergency Solutions Grants Program funds may be used for one or more of
      the following activities:

           A. Renovation, major rehabilitation, or conversion of buildings for
           use as emergency shelters for the homeless.

           B. Provision of essential services, including (but not limited to)
           services concerned with employment, health, substance abuse,
           education, or food. Grants may be used to provide an essential
           service primarily if: the service is a new service or a
           quantifiable increase in the level of a service above that which
           the unit of general local government provided during the 12
           calendar months immediately before it received the grant. Services
           must not exceed 30% of the total funds requested.

           C. Operations are defined as payment of maintenance, other costs
           including rentC. Operations are defined as payment of maintenance,
           other costs including rentC. Operations are defined as payment of
           maintenance, other costs including rent (but excluding staff),
           insurance, utilities, and furnishings.

           D. The development and implementation of homeless prevention
           activities.

           E. The County may use up to 5% of its grant for general
           administration purposes.

      Ineligible Activities
      ESG Program funds may NOT be used: (1) to acquire an emergency shelter
      for the homeless; (2) to pay rent for commercial, transient
      accommodations, such as hotels or motels; (3) to pay for rehabilitation
      services, such as preparation of work specifications, loan processing,
      or inspections; (4) to repair religious facilities.

      Federal Program Requirements
      A number of Federal requirements exist. These include requirements that
      each organization (1) supplement the assistance provided under the
      Program with an equal amount of funds from other sources; (2) ensure
      that any building for which assistance is provided will continue to be
      used as a homeless shelter for specified periods from 3 to 10 years; (3)
      ensure that assisted rehabilitation is sufficient to make the structure
      safe and sanitary; (4) assist homeless individuals in obtaining
      appropriate supportive services and other available assistance; (5) meet
      other generally applicable requirements, such as nondiscrimination and
      equal opportunity; and (7) provide a certification that the shelter will
      be operated free of drugs.

           A. Matching Funds: In calculating the amount of the match, there
           may be included the value of any donated material or buildings; the
           value of any lease on a building, any salary paid to staff of the
           grantee or subcontractor nonprofit recipient in carrying out the
           emergency shelter program; and time and services contributed by
           volunteers to carry out the emergency shelter program, determined
           at the rate of $5 per hour. The organization will determine the
           value of any donated material or building, or any lease, using any
           method reasonably calculated to establish a fair market value.

           B. Nondiscrimination, Other Matters of Assurance and Compliance:
           Two of the nondiscrimination requirements with which emergency
           shelter grantees must comply are: 1) Title VIII of the Civil Rights
           Act of 1968, and 2) Executive Order 11063 which prohibit
           discrimination in housing on the basis of race, color, religion,
           sex, or national origin.

           Prohibitions against discrimination on the basis of age under the
           Age Discrimination Act of 1975 and the prohibitions against
           discrimination involving handicapped individuals must be assured,
           under Section 504 of the Rehabilitation Act of 1973 and the
           American's with Disabilities Act.

           The organization must make efforts to encourage the use of minority
           and women's business enterprises in connection with activities
           funded under the ESG Program. The County's guide on procurement
           should be consulted and followed with this program, as with other
           federal/state pass through grant programs.

           Organizations must make known that use of the facilities and
           services is available to all on a nondiscriminatory basis. Where
           the procedures that an organization intends to use to make known
           the availability of such facilities and services are unlikely to
           reach persons with handicaps or persons of any particular race,
           color, religion, sex, age or national origin within their service
           area who may qualify for them, the organization must establish
           additional procedures that will ensure that these persons are made
           aware of the facilities and services. Organizations must also adopt
           and implement procedures designed to make available to interested
           persons information concerning the existence and location of
           services and facilities that are accessible to persons with a
           handicap.

           C. Constitutional Limitations on the Use of Program Funds by
           Primarily Religious Organizations : A private non-profit
           organization deemed pervasively sectarian is not prohibited from
           carrying out eligible activities so long as such activities are
           carried out in a manner free from religious influences pursuant to
           conditions prescribed in the assistance agreement.

           D. Displacement: Organizations must avoid involuntarily displacing
           lower income persons. If such displacement is unavoidable, action
           will be taken to mitigate any adverse effects on these persons.
           Projects causing displacement will not be funded.

           E. Applicability of OMB Circulars: Financial requirements of OMB
           CIRCULAR NOS. A-87 and 24 CFR part 85, as they relate to the
           acceptance and use of emergency shelter grant amounts by States and
           units of general local government, and Nos. A-110 and A-122 as they
           relate to the acceptance and use of emergency shelter grant amounts
           by private non-profit organizations are in effect.

           F. Accessibility Standards: For major rehabilitation or conversion,
           24 CFR Part 576.3 standards apply. Buildings proposed for major
           rehabilitation or conversion must be made accessible to the
           disabled. Applicants are advised to discuss questions about designs
           for handicapped persons with the Berks County Center for
           Independent Living and Labor and Industry Department staff who work
           with these matters.

           G. Lead-Based Paint: Compliance with the requirements of the
           Lead-Based Paint Poisoning Prevention Act must be assured.

           H. Conflicts of Interest: In addition to conflict of interest
           requirements in 24 CFR part 85 and OMB Circular A-110, no person
           who is an employee, agent, consultant, officer, or elected or
           appointed official of the grantee, State recipient, or nonprofit
           recipient (or of any designated public agency) that receives
           emergency shelter grant amounts and who exercises or has exercised
           any functions or responsibilities with respect to assisted
           activities or who is in a position to participate in a decision
           making process or gain inside information with regard to such
           activities, may obtain a personal or financial interest or benefit
           from the activity, or have an interest in any contract, subcontract
           or agreement with respect thereto, or the proceeds thereunder,
           either for him or herself or those with whom he or she has family
           or business ties, during his or her tenure or for one year
           thereafter.

           I. Use of Debarred, Suspended or Ineligible Contractors: Engagement
           of services, awarding of contracts, or funding of any contractors
           or subcontractors during any period of debarment, suspension, or
           placement in ineligibility status is not allowed.

           J. Flood Insurance: No site proposed for grant assistance may be
           located in an area that has been identified by the Federal
           Emergency Management Agency (FEMA) as having special flood hazards,
           unless the community in which the area is situated is participating
           in the National Flood Insurance Program. 

 

           K. Audit: The financial management system used by a private
           nonprofit organization is subject to the audit requirements of OMB
           Circular A-133.

      Reporting Requirements
      Reports will be required on at least a semi-annual basis which describe
      progress on eligible ESG Program activities and describe clients served.

      Fiscal Responsibilities
      All funds must be spent within 24 months of the contract start date.
      Organizations must have an accounting system to maintain records and
      receipts supporting expenditures. Expenditures reports shall be
      submitted in accordance with the schedule negotiated for payouts of the
      grant amount.

      Organizations shall ensure that books, records, documents, and other
      evidence pertaining to cost and expenses of the grant are maintained in
      such detail as will reflect all costs of materials, equipment, supplies,
      services, acquisition, building costs and all other costs and expenses
      for which reimbursement is claimed or payment is made under the grant.
      All expenditures shall be reported on an accrual basis.

      All records pertaining to this grant including financial audit, budget,
      plans/drafts, supporting documents, statistical records, etc, shall be
      retained for a period of at least four (4) years following submission of
      the final expenditure report.

      In the event that any claim, audit, litigation or State/Federal
      investigation is started before the expiration of the aforementioned
      record retention period, the records shall be retained by organizations
      until all claims or findings regarding the records are resolved.

      The Federal government and the County shall have access to any records
      relevant to the project, including books, documents, photographs,
      correspondence, and records to make audit, examinations, transcripts,
      excerpts. If the County determines that such records possess long term
      or historic value, they shall be transferred, as requested, to the
      County.

      Allocation of Funds
      The County's ESG Program guidelines follow the federal program
      requirements which are published in the Federal Register/Volume 54, No.
      214 Tuesday, November 7, 1989 on pages 46799 through 46810. For FFY2000,
      the U. S. Department of Housing and Urban Development provided Berks
      County with $111,000.00 for repair and conversion of buildings used as
      shelters for those homeless and to support shelter operations and new
      essential staff services. The County also received $177,728.00 in ESG
      Program funds from the State's ESG Program. The total amount of the
      grants for the past three year cycle was $319,000.00. Based on this past
      level of funding and considering current funding proposals in Congress
      for the ESG Program, the County anticipates that its annual grant for
      the Program for the next three years will average $100,000.00.

      The County will allocate ESG Program funds based upon its overall
      housing strategy. Based on the principles of the County's overall
      housing strategy, the proposed elements of the homeless strategy are :

        1. Priority should be given to the operation and maintenance of
           existing homeless shelters and transitional housing facilities. In
           turn, these agencies should be cooperating with each other to
           assure that services are not being duplicated. These agencies
           should also be taking a lead in the measurement of the success of
           these programs by providing uniform and reliable data on the
           clients they serve.
        2. The need for additional transitional housing facilities should be
           ascertained. If justified, sites for the facilities should be
           identified. Resources to either reuse existing buildings or
           construct a new facility should be committed. There may be
           potential for City/County joint cooperation in this effort, using
           Beacon House as a model.

      The County will allocate sufficient funds to insure the proper planning
      and administration of its ESG Program.

      Based on these guidelines, the County of Berks will utilize funding of
      the FFY2000-2002 cycle generally as follows:

       Operations and Maintenance              65%
       Essential Services                              30%
       Planning and Administration                 5%

      Application Procedures
      An original and one copy of funding requests from local non-profit
      organizations must be submitted to the Berks County Community
      Development Office, County Services Center - 14th Floor, 633 Court
      Street, Reading, PA 19601 by July 31, 2000. Demonstration of the
      coordination of essential services through local organizations is
      encouraged. Any activity funded by the County's ESG Program shall be
      consistent with the goals and objectives of the County's Comprehensive
      Plan and Consolidated Plan. Applications must included:

           A. Purpose: Prospective organizations should explain the purpose of
           the ESG Program funds including information and any data which is
           applicable.

           B. Goals and Objectives: Organizations should include an outline of
           the intended goals of the ESG Program project, with an assessment
           of the impact of the project on local homeless needs. The number of
           units or beds, an estimate of total development cost, source of
           ongoing operation funds, a management plan, and overview of the
           intended participation of the existing social services support
           network must be provided in this section of the application.

           C. Project Description: Proposals should provide a detailed
           description of the proposed project including the following
           information:

                1. Complete narrative description of the chosen facility
                (size, physical condition, number of existing units, former
                use, photographs showing exterior and interior conditions).

                2. Complete description of repairs, renovations and/or
                conversions to be undertaken, if applicable.

                3. Specifications, drawings and/or write-up of work or
                improvements proposed to be undertaken, if applicable.

                4. Construction Cost Estimates, if applicable.

                5. Construction schedule, if applicable.

                6. Management plan for the project including procedures for
                intake, schedules and fee arrangements (if any), letters of
                support from existing social service agencies such as local
                mental health/mental retardation and drug and alcohol
                programs, and proposed rules and regulations for project
                residents (House Rules).

                7. Evidence of cooperation with social service providers,
                particularly those offering services for the homeless.

           D. Fiscal Information: Total Project budget proposed through the
           contract period must be submitted indicate amount and source of 50%
           local matching funds. Indicate other sources of funding to be
           utilized by the Project. The total agency budget for this time must
           be provided.


      X. AFFORDABLE HOUSING PROGRAM

      Background
      The 1992, the General Assembly passed the Optional County Affordable
      Housing Funds Act (Act 1992-137). The intend of the General Assembly is
      to provide an alternative method for county governments to raise
      revenues at the local level to enable county residents to purchase or
      rent quality residential housing.

      The Act allows county governments to increase the fees charged by the
      recorder of deeds for recording deeds and mortgages under the act of
      June 12, 1919 (P.L. 476, No. 240) referred to as the Second Class County
      Recorder of Deeds Fee Law, and the act of April 8, 1982 (P.L. 310,
      No.87), referred to as the Recorder of Deeds Fee Law. The additional
      fees levied by the county shall not exceed 100% of the amounts charged
      on the effective date of Act 137.

      Berks County enacted Ordinance 1-94 on March 24, 1994 and the ordinance
      became effective as of May 9, 1994. The Ordinance increases the fee
      charged for recording documents as follows:

           A. Deeds from eleven dollars and fifty cents ($11.50) each to
           twenty-three dollars ($23.00) each.

           B. Mortgages from eleven dollars and fifty cents ($11.50) each to
           twenty-three dollars ($23.00) each.

           C. Each page or part over four contained in deeds and mortgages
           from two dollars ($2.00) to four dollars ($4.00).

           D. Each additional name over four contained in deeds and mortgages
           from fifty cents ($.50) to one dollar ($1.00).

      Disposition of Proceeds
      Additional revenue, about $430,000.00 per year, raised by the increase
      in fees is deposited in the County General Fund and allocated as
      follows:

           A. 85% of the additional revenue is set aside in a separate account
           to be used to fund affordable housing efforts in the County.

           B. 15% of the additional revenue is used by the County for
           administrative costs associated with the affordable housing
           efforts.

      Affordable Housing Efforts
      Affordable housing efforts may include, but are not limited to:

           A. Providing local matching funds to secure National Affordable
           Housing Act of 1990 HOME Program funds for the County of Berks and
           the City of Reading.

           B. Assisting or supporting housing efforts by the Pennsylvania
           Housing Finance Agency and by commercial banks and thrift
           institutions.

           C. Supporting soft second mortgage programs.


XI. CITIZEN PARTICIPATION PLAN

      Berks County, through the Community Development Office, utilizes the
      programs of various Federal and State agencies including the U.S.
      Department of Housing and Urban Development, the Pennsylvania Department
      of Community Affairs, etc. to implement housing and community
      development related activities.

      The C.D. Office recognizes the obligation to provide adequate
      information to citizens regarding those programs through which it may
      seek funding. Therefore, the C. D. Office will insure that adequate
      information is provided to local citizens to evaluate various proposals.
      The County will also provide the proper forum to obtain citizen views on
      housing and community development related issues.

      The County receives annual grants from the U.S. Department of Housing
      and Urban Development resulting from its classification as an
      “entitlement” community. The County is also eligible to apply for
      supplemental funds under the Section 108 Loan Guarantee Program. The
      County may exercise its option to apply for Section 108 Loan Guarantee
      funding and in so doing will follow the procedures outlined in this
      Citizen Participation Plan.

      The C.D. Office recognizes that persons affected by public action should
      have a voice in policy formulation. Although the various housing and
      community development related activities are designed to have a long
      term beneficial effect on the community, these activities may also have
      an adverse impact on some individuals. Therefore, it is important that
      citizens know what is being planned and be given an opportunity to
      present their views.

      The County recognizes the need to consult and coordinate with
      appropriate public and private agencies, such as the State and other
      local jurisdictions, local public housing agencies participating in an
      approved Comprehensive Grant Program, and among its own departments, to
      assure that its programs and plans are comprehensive and address any
      statutory purposes. It will also confer with social service agencies
      regarding the housing needs of children, elderly persons, persons with
      disabilities, homeless persons, and other categories of residents. The
      County will consult with State and local health and child welfare
      agencies, and examine existing data on hazards and poisonings, including
      health department data on the addresses of housing units in which
      children have been identified as lead poisoned.

      In order to comply with the spirit of program requirements relative to
      citizen participation, the C.D. Office has developed this Citizen
      Participation Plan. Generally, the plan is designed to insure the
      involvement of affected persons and other concerned citizens, the
      openness and freedom of access to information, the adequate and timely
      presentation of pertinent data, the submission of views and proposals,
      and the continuity of citizen participation through each stage of
      resulting activities.

      Access to Records
      The C.D. Office shall provide for full public access to citizens, public
      agencies, and other interested parties, including those most affected,
      to information pertaining to any program under which funding is sought
      or concerning the use of funds from any program used for housing and
      community development activities and administered by the C.D. Office.
      Affirmative efforts will be made to make adequate information available
      to citizens, especially to those of low, very low, and poverty income
      and to those residing slum and blighted areas and in areas where funds
      from federal or state programs are proposed to be used. At the time the
      C.D. Office initiates the process to seek specific funding, the
      following program information shall be provided:

           A. The total amount of funds expected to be available to the County
           for housing and community development activities under the
           program(s) being assessed.

           B. The range of activities that may be undertaken with these funds;

           C. The estimated amount of funds proposed to be used for activities
           that will benefit low, very low, and poverty income persons;

           D. The possibility of residential and/or commercial displacement
           resulting from program implementation and the plans for minimizing
           such displacement, and;

           E. The types and levels of assistance to be made available to
           persons displaced by contemplated activities.

      Upon completion of an application for funding by the C. D. Office and
      submission of the application to the appropriate agency, the County
      shall publish a notice in a newspaper of general circulation if program
      regulations so require. The notice shall appear in a paper such as the
      Reading Eagle/Times and indicate that necessary documentation has been
      submitted and is available to interested parties upon request. The C.D.
      Office shall make copies of the appropriate documentation available in
      the Community Development Office, County Services Center, 14th Floor,
      633 Court Street, Reading, PA.

      Consolidated Plan
      The Consolidated Plan provides the framework for a planning process used
      by States and localities to identify housing, homeless, community and
      economic development needs and resources and to tailor a strategic plan
      for meeting those needs. For citizens, the Consolidated Plan provides a
      way to help define their government’s priorities for addressing housing,
      homeless, community and economic development needs. For grantees, it
      simplifies the steps needed to receive funds under four HUD block grant
      programs: the Community Development Block Grant (CDBG), the Emergency
      Shelter Grant (ESG), HOME Investment Partnerships Program (HOME) , and
      Housing Opportunities for Persons with AIDS (HOPWA). It also provides a
      way to measure if the activities they funded with these program actually
      meet the needs and objectives identified by the community.

      The Consolidated Plan serves the following functions: (1) A planning
      document for communities, which builds on a participatory process at the
      lowest levels; (2) An application for federal funds under HUD's formula
      grant programs; and (3) A strategy to be followed in administering HUD
      programs.

      Upon completion of the proposed Plan, the County shall publish the
      proposed Plan or summary of the Plan in sufficient time to permit
      citizens to comment on the Plan prior to its approval and adoption by
      the Board of County Commissioners. The notice will appear in a non-legal
      section of a paper of general circulation such as the Reading
      Eagle/Times at least fifteen (15) calendar days prior to the adoption of
      the Plan and will indicate the locations at which the Plan will be made
      available for public review.

      Upon approval of the Plan, the County shall publish a notice in a
      newspaper of general circulation if program regulations so require. The
      notice shall appear in a paper such as the Reading Eagle/Times and
      indicate that necessary documentation has been submitted and is
      available to interested parties upon request.

      Technical Assistance
      Technical assistance in the form of C. D. Office staff, staff of other
      County agencies or third party contractors to the County or its agencies
      will provide technical assistance to citizen participants, low, very
      low, and poverty income groups or persons to enable them to understand
      the requirements associated with various programs such as Davis-Bacon
      Fair Labor Standards, environmental policies, equal opportunity
      requirements, relocation provisions, etc. Technical assistance will also
      be provided to groups representative of persons of low, very low, and
      poverty income that request assistance in developing proposals. Such
      assistance will be made available upon request by interested citizens or
      organizations to the County's C. D. Director. In addition, the C.D.
      Office, through the public hearings will review such program
      requirements and will have available for interested parties handout
      material dealing with technical program requirements so as to assure
      understanding. Furthermore, the C.D. Office will provide interpretation
      services to any non-speaking person who may require such assistance in
      understanding a particular program being planned or administered by the
      C.D. Office.

      Public Hearings
      The C.D. Office will conduct a public hearing or hearings on specific
      application proposals in accordance with Federal or State requirements
      for the subject program under consideration.

      An initial hearing will be held to obtain the views of interested
      citizens and organizations regarding overall community development and
      housing needs, development of proposed activities, and a review of
      program performance. The second hearing will be held to obtain the views
      of interested citizens and organizations on the particular funding
      application.

      Generally, hearings shall be held in the Commissioners Board Room in the
      County Services Center, which is centrally located within the County.
      Such hearings will be duly advertised. All public hearings will be held
      in facilities that afford accessibility for persons with disabilities.
      At least ten (10) calendar days prior to any hearing, a notice shall be
      published in the non-legal section of a paper of general circulation
      such as the Reading Eagle/Times. The notice will give the date, time,
      place and topics to be considered at the hearing.

      In addition, the times, dates and purposes of public hearings will be
      forwarded to local radio and TV stations serving the County of Berks or,
      as appropriate, units of general local government including any adjacent
      units of local government concerning community development needs.
      Notices will also be sent to social service agencies and other public
      and semi-public groups which may have particular interest or be affected
      by the proposed program. The C.D. Office will work through these
      agencies and groups to encourage participation in the hearing process on
      the part of low, very low, and poverty income persons who reside areas
      where funds will be spent. The C.D. Office will also work with these
      agencies and groups to involve persons who reside in low, very low, or
      poverty income neighborhoods. All notices of the second hearing will
      also contain a detailed description of the area or areas affected by the
      project activities in an effort to alert the residents of such areas of
      such proposals and to encourage their participation in the hearing
      process.

 

 

      If any organization or group representing affected residents requests to
      be involved in the citizen participation process, the C.D. Office shall
      place such group on the C.D. Office's list of representative groups and
      organizations. The C. D. Director shall be responsible for maintaining a
      list of representative groups and organizations. This list shall be
      updated at the beginning of each program year. Additions to the list may
      be made by written request to the C. D. Office stating the nature of the
      organization omitted and why it should be included.

      The Chairman of the Board of County Commissioners shall have the
      responsibility for calling meetings and hearings with citizens likely to
      be affected by activities undertaken by the C. D. Office. The Chairman
      may delegate assignments to the C. D. Director. The Chairman shall also
      develop procedures for meetings and hearings and for moderating such
      meetings either directly or through the C. D. Director.

      Written Response
      The C.D. Office will consider and respond in writing to all comments,
      views or proposals submitted either verbally or in writing at public
      hearings or meetings. The response to a request for activities or
      projects shall be made in a timely fashion, but in any case prior to the
      meeting of the County Commissioners at which approval of the application
      will be considered.

      The C.D. Office will respond in writing to citizen complaints and/or
      grievances related to community development and housing programs as soon
      as possible. Citizen complaints and/or grievances will be responded to
      in writing within fifteen (15) working days from receipt of such
      complaint in the C.D. Office.

      Criteria for Amendment to Programs
      The County may decide to amend its approved programs based upon one of
      the following decisions:

           A. To make a substantial change in its allocation priorities;

           B. To undertake an activity, using funds from any program covered
           by a program (including program income) which was not previously
           described in an action plan or funding application;

           C. To decide not to carry out an activity for which funding is
           approved; or

           D. To substantially change the purpose, scope, location, or
           beneficiaries of an activity.

      Substantial change is defined as the increase or decrease in the cost of
      an approved activity by more than 25% or the change (increase or
      decrease) in the service area and/or class of beneficiaries of an
      activity. Such a course of action would constitute an amendment to an
      approved program.

      In such an instance, the C.D. Office shall provide citizens with
      reasonable notice of, and opportunity to comment on, such proposed
      changes in its use of funds. The C.D. Office will publish a notice in
      the non-legal section of a paper of general circulation such as the
      Reading Eagle/Times of the proposed program change and give interested
      or affected citizens at least thirty (30) calendar days to submit
      comments on the amendment. The C.D. Office shall consider any such
      comments and, if the County deems appropriate, modify the amendment. The
      C.D. Office will notify the appropriate funding agency of the proposal
      and provide a description of any changes. A letter transmitting such
      description to the agency shall be signed by the Chairman of the Board
      of County Commissioners.

      Non-English Speaking Residents
      The County will take such measures as are appropriate to accommodate the
      needs of non-English speaking residents in the case of public hearings
      where a majority of the participants at the hearing are expected to be
      non-English speaking residents. At a minimum, all handout material
      prepared for such hearings will be bi-lingual to accommodate the needs
      of attendees. Secondly, the C. D. Office may engage the services of a
      bilingual person to assist in presenting relevant information at the
      hearing.

      Notice of Annual Performance Report
      The County may be required to file a performance report to a grantor
      agency. The C.D. Office will publish a notice of completion of the
      report in sufficient time to permit citizens to comment on the report
      prior to its submission to the appropriate agency. The notice will
      appear in a paper of general circulation such as the Reading Eagle/Times
      at least fifteen (15) calendar days prior to the submission of the
      report and will indicate the locations at which the report will be made
      available for public review.

      Adoption of Plan
      Prior to the initial adoption of the Citizen Participation Plan, the
      C.D. Office will publish a notice of completion of the plan in
      sufficient time to permit citizens to comment on the report prior to its
      submission to the appropriate agency. The notice will appear in a
      newspaper of general circulation such as the Reading Eagle/Times at
      least ten (10) calendar days prior to the adoption of the plan by the
      Board of County Commissioners and will indicate the locations at which
      the report will be made available for public review.

      Use of Plan
      The County shall follow the Citizen Participation Plan for all funding
      applications and amendments to the approved applications.

      Modification of Plan
      This Citizen Participation Plan may be modified from time to time by the
      C. D. Office provided such revisions are consistent with Federal and
      State law, regulations and administrative requirements covering citizen
      participation. Prior to any modification of the Citizen Participation
      Plan, the C.D. Office will publish a notice of modification of the plan
      in sufficient time to permit citizens to comment prior to approval by
      the Board of County Commissioners. The notice shall be published in
      local newspapers of general circulation such as the Reading Eagle/Times
      at least ten (10) calendar days prior to the adoption of the
      modification by the Board of County Commissioners.

      Any questions or comments on this plan or request for information should
      be directed to: Berks County Community Development Office, County
      Services Center - 14th Floor, 633 Court Street, Reading, PA 19601,
      Telephone Number (610) 478-6325.

      Definitions Click here to go to the glossary


      XII. ANTI-DISPLACEMENT AND RELOCATION ASSISTANCE PLAN

      The County of Berks will replace all occupied and vacant occupiable
      lower income dwelling units demolished or converted to a use other than
      as lower income housing in connection with an activity assisted with
      funds provided under the Housing and Community Development Act of 1974,
      as amended, as described in 24 CFR 570.606(c)(1).

      All replacement housing will be provided within three (3) years after
      the commencement of the demolition or conversion. Before entering into a
      contract committing the County of Berks to provide funds for an activity
      that will directly result in demolition or conversion, the County of
      Berks will make public by publication in a newspaper of general
      circulation and submit to the U.S. Department of Housing and Urban
      Development (HUD) the following information in writing:

           A. A description of the proposed assisted activity;

           B. The address, number of bedrooms, and location on a map of lower
           income housing that will be demolished or converted to a use other
           than as lower income housing as a direct result of the assisted
           activities;

           C. A time schedule for the commencement and completion of the
           demolition of conversion;

           D. To the extent known, the address, number of bedrooms and
           location on a map of the replacement housing that has been or will
           be provided;

           E. The source of funding and a time schedule for the provision of
           the replacement housing;

           F. The basis for concluding that each replacement housing will
           remain a lower income housing for at least ten (10) years from the
           date of initial occupancy;

           G. Information demonstrating that any proposed replacement of
           housing units with smaller dwelling units ( e.g. a 2-bedroom unit
           with two 1-bedroom units) or any proposed replacement of efficiency
           or single-room occupancy (SRO) units with units of a difference
           size, is appropriate and consistent with the housing needs and
           priorities identified in the approved Berks County Comprehensive
           Housing Affordability Strategy (CHAS).

      To the extent that the specific location of the replacement housing and
      other date in items 4 through 7 are not available at the time of the
      general submission, the County of Berks will identify the general
      location of such housing on a map and complete the disclosure and
      submission requirements as soon as the specific data is available.

      The Berks County Community Development Office (Phone Number
      610-478-6325) is responsible for tracking the replacement of lower
      income housing and ensuring that it is provided within the required
      period.

      The C. D. Office is also responsible for providing relocation payments
      and other relocation assistance to any lower income persons displaced by
      the demolition of any housing or the conversion of lower income housing
      to another use.

      Consistent with the goals and objectives of activities assisted under
      the Act, the County of Berks will take the following steps to minimize
      the displacement of persons from their homes:

           A. Program funds will be used to assist activities that will result
           in the displacement of persons only as a last resort and only after
           it has been demonstrated that economic factors, sound planning, and
           environmental considerations indicate that not to proceed with the
           activity will have a negative impact on the County's overall
           Program. The relocation assistance standards requiring the County
           to provide substantial levels of assistance to persons displaced by
           HUD assisted programs constitutes the most effective
           anti-displacement policy. The County will proceed with a project
           involving the displacement of persons only after consultation with
           various County agencies and only after a determination that such
           action is in the best interest of the County and the Program; and

           B. Coordinate code enforcement with rehabilitation and housing
           assistance programs.


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