CPD FORMULA PROGRAMS SIGNIFICANT AREAS Use of 2010 Census Data for Formula Use of ACS Data for Formula Use of ACS Data for LMISD Use of ACS for Upper Quartile exception

GRANTEE ELIGIBILITY & FORMULA COMPUTATIONS

DATA SOURCES – CDBG FORMULA Previously, only population (& growth lag) were updated annually by Census. This will continue unchanged Poverty, Overcrowding, Pre- ’40 Housing previously came from decennial census, stayed constant for 10 years Starting in 2012: Poverty, Overcrowding, Pre-’40 Housing now come from 5 year ACS rolling averages – will change yearly

CDBG FORMULA Previously: Only minor shifts in formula allocation amounts for 10 years, then major shifts in 3 rd year of decade with addition of new decennial data Henceforth: More year-to-year fluctuations in allocations amounts, but allocation amounts will more closely track demographic changes over time

ISSUES WITH USING NEW DATA Statute requires use of data in effect as of 90 days before the start of that fiscal year (e.g. 7/1/12 for FY13) If HUD doesn’t receive Census or ACS data by 7/1, its use in formula would be delayed one year (but would still be more current than what we used before)

CENSUS DATA AND ENTITLEMENT ELIGIBILITY Statutory Grandfathering even if population drops under 50,000 or no longer an OMB principal city New city & county eligibility depends on when HUD gets Census population data New city & county eligibility depends on frequency of OMB updates to metro areas New city eligibility still depends on Urban County participation/cycle

EFFECTS OF 2010 CENSUS/ACS DATA ON OTHER PROGRAMS HOME: Previously used decennial census for all six formula factors Starting FY 2012, will use 2005 – 2009 American Community Survey data Will result in more fluctuation in HOME grants from year to year Appropriation level affects minimum grant size threshold

EFFECTS OF 2010 CENSUS/ACS DATA ON OTHER PROGRAMS ESG: Previously, statute mandates ESG allocations proportional to prior year’s CDBG allocations Appropriation level affects minimum grant size threshold (.05%) Hearth Act did not change these

EFFECTS OF 2010 CENSUS/ACS DATA ON OTHER PROGRAMS HOPWA: Formula Grant eligibility based on MSA status, definitions & population (500,000+) Allocation amount based on CDC data Some places waver just over/under the population threshold Changes in MSA principal city designation can affect which locality is the grantee

METROPOLITAN AREA STATUS AND FORMULA ELIGIBILITY New city & county eligibility depend on future OMB updates to metro areas OMB MSA standards issued June 2010: updates to counties & principal cities in existing metro areas only in 2013 & 2018; yearly designation of new metro areas New OMB designations often published too late to affect that year’s funding (e.g. November 2013 issuance wouldn’t affect FY14 funding eligibility)

COMPUTING LOW/MODERATE INCOME SUMMARY DATA

How LMISD Is Produced Not Census data per se – HUD computes from a special Census data run + Section 8 income limits Up to now, data came from decennial Census, issued 3 years afterward, stayed constant for 10 years Last updated in 2007 to use current Section 8 Income Limit areas/definitions

Major Changes…. How and when LMISD is produced will change dramatically Census data will now come from ACS 5 year rolling averages – will change yearly Census Bureau would not provide ACS data at the Block Group level ACS Data not available for Insular Areas

…Still In Flux HUD appealed to Census Bureau on getting Block Group level data Partial success: we’ll get ACS data at Block Group level EXCEPT for split block groups (block groups split between 2 or more jurisdictions) Keep using old 2000 Census- based data until we issue ACS-based data What do we use for the territories?

Issues to be resolved New LMISD data every year Areas that qualify could change every year – inhibits long term planning Areas (or entire jurisdictions) that waver just above/below the line Upper Quartile %s would change every year On the other hand, you wouldn’t be stuck using outdated data or doing surveys in lieu of!

….Implementation Issues HUD will get the new data early in Before we can implement it, HUD needs to: Come up with transition policy on when to start using new data – may not be available until the middle of 2013 Come up with policy on how long data can be used (deal with yearly fluctuations) Revise IDIS to accommodate annual/multi-year LMI data for activities Revisit/revise survey methodology guidance