Res-2021-030 - Laserfiche WebLink

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TIMING of CDBG FUNDING and NEPARESTRICTIONS Costs incuned prior to the CDBG award ietter cannot be rcimbursed 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 tlie 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 cornmit CDBG or non-CDBG fi,uids if the activity would have an adverse environmental impacl or limit the choice of reasonable alternatives. This restrictiorr applies to activities as of the date the CDBG program rcceiycsllle grant applicatior]. Portions of preliminaty design work needed for cornpletion of the environrnental 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 ccntribute towards but not entirely meet the CDBG-specific procedure for NEPA and SEPA. Section 6 of the CDIIG ManAgement Ilanclbook provides further detail and the necessal'y CDBG forms. Proiect Phase Restrictions on Elieiblc Activities Before CDBG contract is executed and envlronmcntal review is complete With the award letter, the grantee can begin to incur costs up to 10% of award for the following activities which don't require an envirorunental review IF the grant application requested CDBG funding ofthese costs: Administration: Executing the CDBG contract. Establishing administrative, financial, reporting, and record keeping systems, including staffrng, 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: o Consultation letters to atfected tribesr Cultural resource suryeyr Floodplain/wetlanddetermination 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.