Resolution with agreement CDBG-CV1

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TIMING of CDBG FUNDING and NEPA RESTRICTIONS Costs incurred prior to the CDBG award letter cannot be reimbursed by CDBG. Eligible costs will be reimbursed by Commerce after a grant contract has been formally executed and the CDBG-specific procedures under NEPA and SEPA are completed. Executing the grant contract and completing the environmental review can occur concurrently. Unless the activity is exempt or categorically excluded and not subject to 24 CFR 58.5 under NEPA, the local government grantee, subrecipients, contractors and all other participants may not commit CDBG or non-CDBG funds if the activity would have an adverse environmental impact or limit the choice of reasonable alternatives. This restriction applies to activities as of the date the CDBG program receives the grant application. Portions of preliminary design work needed for completion of the environmental review are allowable. Title 1 of the Housing and Community Development Act of 1974 as amended and the environmental review procedures found in 24 CFR 58.22 apply to any activities as part of a CDBG project. The environmental review activities completed for other federal or state funding can contribute towards but not entirely meet the CDBG-specific procedure for NEPA and SEPA. Section 6 of the CDBG Management Handbook provides further detail and the necessary CDBG forms. Project Phase Restrictions on Eligible Activities Before CDBG With the award letter, the grantee can begin to incur costs up to 10% of contract is award for the following activities which don't require an environmental executed and review IF the grant application requested CDBG funding of these costs: environmental review is Administration: Executing the CDBG contract. Establishing complete administrative, financial, reporting, and record keeping systems, including staffmg, travel and training. Environmental Review: Review of environmental laws and authorities, including 24 CFR 58.5 and Section 106 of the National Historic Preservation Act of 1996, such as: • Consultation letters to affected tribes • Cultural resource survey • Floodplain/wetland determination Preliminary engineering feasibility studies for the environmental assessment, such as surveying and geotechnical or geophysical analysis (excluding ground -disturbing activity of over one cubic sq. ft.). Subcontracting: Subrecipient agreements or professional service contracts for any of the above activities.