1. N eighborhood R evitalization S trategy A reas in Boston A Presentation for the National Community Development Association’s 2016 Annual Meeting Milwaukee, Wisconsin June 22, 2016

2. Regulations 24 CFR §91.215 Strategic plan. (g) Neighborhood Revitalization. Jurisdictions are encouraged to identify locally designated areas where geographically targeted revitalization efforts are carried out through multiple activities in a concentrated and coordinated manner. In addition, a jurisdiction may elect to carry out a HUD-approved neighborhood revitalization strategy that includes the economic empowerment of low-income residents with respect to one or more of its areas. If HUD approves such a strategy, the jurisdiction can obtain greater flexibility in the use of the CDBG funds in the revitalization area(s) as described in 24 CFR part 570, subpart C. This strategy must identify long-term and short-term objectives (e.g., physical improvements, social initiatives and economic empowerment), expressing them in terms of measures of outputs and outcomes the jurisdiction expects to achieve in the neighborhood through the use of HUD programs

3. What is an NRSA? A Neighborhood Revitalization Strategy Area (NRSA) is a very low-income geographic target area that qualifies for additional flexibility in the use of CDBG funds to support longer term revitalize efforts. The neighborhood or other area must have a contiguous boundary, be primarily residential and have a low/mod percentage at least equal to the jurisdiction’s “upper quartile percentage” or 70%, whichever is lower. It cannot be less than 51% low/mod.

4. What is NRSA Flexibility? Job creation/retention can qualify as low/mod area benefit Aggregate housing units to meet low/mod housing national objective rather than project by project Exempt economic development projects from the aggregate public benefit standards Public service cap exemption

5. 1) Job Creation/Retention as LMA Benefit Job Creation/retention activities may be qualified as meeting low/mod area benefit requirements, eliminating the need to document that 51% of the jobs are taken by or are available to low mod persons. You do not need to document the household incomes of the persons hired.

6. 2) Aggregation of Housing Units All of the housing units assisted as part of the NRSA can be considered part of a single structure for purposes of meeting the 51% low/mod housing requirement. In other words, individual housing projects could have less than 51% low/mod units as long as in aggregate the total units assisted meets the 51% low/mod standard

7. 3) Aggregate Public Benefit Standard Exemption Grantees may choose to exempt economic development activities from the aggregate public benefit standards (1 FTE job per $35,000, or service area must have 1 low mod person for every $350) This means you can use the public benefit standards for individual activities (1 FTE job per $50,000, or 1 low mod person for every $1000) without having to worry about also meeting the aggregate standard.

8. 4) Public Service Cap Exemption Public service activities carried out by a Community-Based Development Organization (CBDO) as part of a NRSA are exempt from the CDBG 15% public service cap. Note that organizations certified as Community Housing Development Organizations (CHDOs) under the HOME program qualify as CBDOs.

9. NRSA Contents Boundary Demographic Criteria Consultation with area’s stakeholders Assessment of economic conditions Economic Empowerment – jobs strategy, substantial revitalization Performance Measurement - benchmarks

10. Level of Detail Empowerment Zone or Enterprise Community located within an entitlement community will be presumed to meet the NRSA requirements – no further review needed HUD expects to extend similar approval policy to Choice Neighborhood transformation plans shortly. May refer to specific portions of other existing plans or documents and supplement as needed. Can include as part of Con Plan – doesn’t have to be a separate document.

11. Boston Example #1: Empowerment Zone Job Creation as LMA benefit - New Boston Seafood $1.7 million Section 108 loan and Economic Development Initiative grant. Presumed LMA Aggregate Public Benefit Standard Exemptions New Boston Seafood: 34 FTE jobs @ $50K/job vs 49 jobs @ $35K/job aggregate South End Community Health Center - $6.4 million Section 108 loan and EDI/CDBG grants. Must have 18,286 low mod persons in service area @ $350 aggregate standard vs 6,400 low mod persons @ $1000 per low/mod person individual activity standard

12. Empowerment Zone - continued Public Service Cap Exemption – was of limited use due to requirement that services be delivered by a CBDO/CHDO. Was most useful when CDBG funds were cut or program income did not meet targets. Boston is one of the communities grandfathered at the higher 1983 public service level. Aggregation of Housing Units – not used

13. Boston Example #2: Choice Neighborhoods Quincy Corridor target area LMA% = 78% Job Creation as LMA benefit – Bornstein & Pearl $14 million shared use commercial kitchen project$3.2 million in Section 108. Proposed 150 FTE jobs over 5 years. Presumed LMJ Aggregate Public Benefit Standard Exemption Aggregate standard required 92 jobs, individual activity standard only required 64 jobs.

14. Choice Neighborhoods - continued Quincy Commons mixed use project – first floor commercial space (condo) in 40-unit Section 202 elderly housing development. $920,000 in Section 108, Economic Development Initiative and CDBG funds. Presumed LMA. Aggregate Public Benefit Standard Exemption Aggregate standard required low/mod population of 2,628, individual activity standard only required low/mod pop of 920. Public Service Cap Exemption & Aggregation of Housing Units – not used for Choice Neighborhoods NRSA

15. NRSA in IDIS Con Plan SP10: Geographic Priorities – identify /describe local target areas, including strategy areas. Action Plan AP50: Geographic Distribution - % distribution of funds, rationale narrative, etc. IDIS CDBG Activity Setup Detail – Page 1 Section on Target Area – Target area type and target area name Reporting/CAPER: CAPER CR15: Geographic distribution and location of investments IDIS PR14 - CDFI & NRSA (all projects flagged in strategy areas IDIS PR84 - CDBG Strategy Area, CDFI and Local Target Area Report (manually enter performance parameters on COPR84 on Reports Selection Page first, then run PR84 report.)

16. NRSA References CDBG National Objectives Guide: Appendix E. https://www.onecpd.info/onecpd/assets/File/CDBG-National- Objectives-Eligible-Activities-Appendices.pdf CPD Notice 96-01 http://www.hud.gov/offices/adm/hudclips/notices/cpd/96- 1CPDN.doc CPD monitoring guide http://portal.hud.gov/hudportal/documents/huddoc?id=65092e 315.doc

17. My Contact Info Bob Gehret, Deputy Director Department Of Neighborhood Development 26 Court Street, 11 th Floor Boston, MA 02108 (617) 635-0242 Robert.Gehret@Boston.gov

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