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of CDtsG FUNDING end NEPA oNs <br />Costs incuned prior to the CDBG awal'd lettff cannot be reimbursed by CDBG. Eligible costs <br />will be reimbursed by Commerce after a gmnt contract has been formnlly execnted and the <br />cDBG-specific plocedures under NEPA and sEI'A are completed. Executing the grant <br />contract and completing the environmental review can occur concunently, <br />Unless the activily is exempt or categorically exchrded and not subject to 24 CFR 58.5 under <br />NEPA, the local government grantee, subreoipients, contractors and all other participants may <br />not contmit CDBG oL non-CDBQ fi,uids if the activity would have an adverse environmental <br />impact ol limit the choice of reasonable alternatives, This restriction applies to activities as of <br />the date the CDBG program rCgCivjliJ!tg3l11|.3g0lfS4!ra1 Portions of pr.eliminaty design <br />work needed for cornpletion of the environmental review zue allowable, <br />f itle 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 environmenlal review activities cornpleted for other federal or state <br />funding can contribute towards but not entirely meet the CDBG-specific procedure for NEPA <br />and SBPA, Siection 6 ol'thq Cl)fl(i Mlnagcntent llanellnok plovides further detail and the <br />necessary CDBG forms, <br />Restrictions on Elieiblc Activitics <br />With the award letter, the grantee can begin to incur costs up to l0% 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 />Environnrentnl Revierv: <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 />r Consultation lettels to atfected tribes. Cultural resource suffey <br />r FloodplairVwetlanddetermination <br />Preliminary engineering feasibility studies for the envfuonmental 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 />Before CDBG <br />coutract is <br />executed and <br />environmental <br />review is <br />complete <br />P Phase <br />Contract Page 035