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TIMING of CDBG FUNDING and NEPARESTRICTIONS <br />Costs incuned prior to the CDBG award ietter cannot be rcimbursed by CDBG. Eligible costs <br />will be reimbursed by Commerce after a grant contract has been formally executed and the <br />CDBG-specific procedures under NEPA and SEPA are completed. Executing the grant <br />contract and completing the environmental review can occur concurrently. <br />Unless tlie activity is exempt or categorically excluded and not subject to 24 CFR 58.5 under <br />NEPA, the local government grantee, subrecipients, contractors and all other participants may <br />not cornmit CDBG or non-CDBG fi,uids if the activity would have an adverse environmental <br />impacl or limit the choice of reasonable alternatives. This restrictiorr applies to activities as of <br />the date the CDBG program rcceiycsllle grant applicatior]. Portions of preliminaty design <br />work needed for cornpletion of the environrnental review are allowable. <br />Title 1 of the Housing and Community Development Act of 1974 as amended and the <br />environmental review procedures found in 24 CFR 58.22 apply to any activities as part of a <br />CDBG project. The environmental review activities completed for other federal or state <br />funding can ccntribute towards but not entirely meet the CDBG-specific procedure for NEPA <br />and SEPA. Section 6 of the CDIIG ManAgement Ilanclbook provides further detail and the <br />necessal'y CDBG forms. <br />Proiect Phase Restrictions on Elieiblc Activities <br />Before CDBG <br />contract is <br />executed and <br />envlronmcntal <br />review is <br />complete <br />With the award letter, the grantee can begin to incur costs up to 10% of <br />award for the following activities which don't require an envirorunental <br />review IF the grant application requested CDBG funding ofthese costs: <br />Administration: Executing the CDBG contract. Establishing <br />administrative, financial, reporting, and record keeping systems, including <br />staffrng, travel and training. <br />Environmental Review: <br />Review of environmental laws and authorities, including 24 CFR 58.5 and <br />Section 106 of the National Historic Preservation Act of 1996, such as: <br />o Consultation letters to atfected tribesr Cultural resource suryeyr Floodplain/wetlanddetermination <br />Preliminary engineering feasibility studies for the environmental assessment, <br />such as surveying and geotechnical or geophysical analysis (excluding <br />ground-disturbing activity of over one cubic sq. ft.), <br />Subcontracting: Subrecipient agreements or professional service contracts <br />for any of the above activities. <br />Contract Page 035