BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                      



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          |SENATE RULES COMMITTEE            |                   AB 232|
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                                 THIRD READING


          Bill No:  AB 232
          Author:   V. Manuel Pérez (D), et al.
          Amended:  6/14/12 in Senate
          Vote:     21

           
           SENATE TRANSPORTATION & HOUSING COMM.  :  9-0, 6/12/12
          AYES:  DeSaulnier, Gaines, Harman, Kehoe, Lowenthal, 
            Pavley, Rubio, Simitian, Wyland

           SENATE APPROPRIATIONS COMMITTEE  :  Senate Rule 28.8

           ASSEMBLY FLOOR  :  75-0, 1/26/12 (Consent) - See last page 
            for vote


           SUBJECT  :    Community Development Block Grant Program

           SOURCE  :     Author


           DIGEST  :    This bill, for the economic development portion 
          of the Community Development Block Grant (CDBG) Program, 
          eliminates the dollar-per-job test and the requirement that 
          benefit to low- and moderate-income persons be a scoring 
          factor in ranking applications.  

           ANALYSIS  :    Existing federal law establishes the CDBG 
          Program to provide communities with resources to address a 
          wide range of unique community development needs, including 
          affordable housing, services to the most vulnerable, and 
          job creation through the expansion and retention of 
          businesses.  A grantee must use 70% of CDBG funds for 
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          activities that benefit low- and moderate-income persons.  
          In addition, each activity must meet one of three national 
          objectives for the program:  (1) benefit low- and 
          moderate-income persons; (2) prevent or eliminate slums or 
          blight; and (3) address urgent community development needs 
          posing a serious and immediate threat to the health or 
          welfare of the community.

          The federal Department of Housing and Urban Development 
          allocates CDBG funds via formula to "entitlement 
          jurisdictions" (cities over 50,000 population and counties 
          over 200,000 population) and to states for non-entitlement 
          areas.  In California, the Department of Housing and 
          Community Development (HCD) administers the CDBG Program 
          for non-entitlement areas.  

          HCD makes CDBG funds available in two general categories: 

             Community development, which includes housing, public 
             facilities, public improvements, public services, and 
             planning. 

             Economic development, which includes business 
             assistance, microenterprise activities, and larger scale 
             economic development projects.  

          Existing state law requires that HCD make 30% of CDBG funds 
          available for economic development programs.  Cities and 
          counties use these grants in turn to create or retain jobs 
          for low- and moderate-income persons by making long-term, 
          fixed-rate loans available to businesses at reasonable 
          interest rates and with flexible terms.  For each business 
          assisted, at least 51% of the jobs created or retained must 
          be for persons of low- or moderate-income.  

          With respect to these economic development activities, 
          federal regulations require HCD to meet a two pronged 
          dollar-per-job test:  (1) a maximum of $50,000 per actual 
          individual job, known as the individual test; and (2) a 
          maximum average of $35,000 per job statewide over a funding 
          cycle, known as the aggregate test.  Under existing state 
          law, however, businesses receiving a loan through the CDBG 
          Program must create or retain at least one job for every 
          $35,000.  In other words, state law sets the maximum for 

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          the individual test at the same level as the maximum for 
          the aggregate test.  
          State law also requires HCD, when developing scoring 
          factors for CDBG economic development awards, specifically 
          to use the three national CDBG objectives described above.  


          This bill:

          1. Eliminates, for the economic development portion of the 
             CDBG Program, the dollar-per-job test in state law, in 
             effect relying only on the two-pronged federal 
             dollar-per-job test.  

          2. Deletes the state law requirement that HCD use benefit 
             to low- and moderate-income persons as a scoring factor 
             in ranking economic development applications.

          3. Eliminates the requirement that HCD utilize the federal 
             standards for "blight" and "urgent need" as a scoring 
             factor, and instead clarifies that HCD develop criteria 
             which meet the minimum requirements of federal law for 
             eligible projects and that meet National Objectives.
            
           Comments

          Purpose of this bill  .  According to the author's office, 
          removing the more restrictive $35,000 dollar-per-job test 
          from state law conforms with federal law and grants HCD the 
          flexibility to choose between the two federal tests for 
          determining the appropriate dollar-per-job standard.  The 
          author's office believes this will allow HCD to more 
          quickly certify and award funding for economic development 
          projects across the state.

           What allowing larger per job awards will mean in practice  .  
          HCD divides CDBG economic development funds between two 
          subprograms:  the Enterprise Fund and the Over-the-Counter 
          Program.  The former is a competitive program with 
          applications and awards once a year.  As the name implies, 
          the latter has an open application period, and HCD makes 
          awards one at a time for major economic development 
          projects until funds are exhausted.  


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          While federal regulations allow HCD to award as much as 
          $50,000 per individual job, they also require HCD to award 
          no more than $35,000 per job in aggregate over the two 
          economic development subprograms.  Given that there are two 
          separate subprograms with differing application and award 
          timeframes, as a practical matter HCD under this bill will 
          probably have to limit all Enterprise Fund awards and early 
          Over-the-Counter awards to the $35,000 standard and only 
          allow more generous awards to later applicants, to the 
          extent that room under the aggregate cap still exists.  

          In recent years at least, applicants have not always 
          exhausted funds available in the Over-the-Counter Program 
          within a given funding year, and these funds have then 
          rolled over to the following funding cycle.  If that trend 
          continues, then giving HCD the flexibility to make awards 
          of up to $50,000 per job late in a funding cycle will not 
          necessarily prejudice other potential applicants.  If the 
          trend changes, HCD would still have the flexibility to 
          maintain the $35,000 per job standard for all applicants.  
          It should be pointed out, however, that allowing awards of 
          up to $50,000 per job ultimately is likely to mean that 
          Over-the-Counter funds will support fewer jobs overall.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  Yes   
          Local:  No

           SUPPORT  :   (Verified  6/25/12)

          AFSCME
          California Association for Local and Economic Development


           ASSEMBLY FLOOR  :  75-0, 1/26/12
          AYES:  Achadjian, Alejo, Allen, Ammiano, Atkins, Beall, 
            Bill Berryhill, Block, Blumenfield, Bonilla, Bradford, 
            Brownley, Buchanan, Butler, Charles Calderon, Campos, 
            Carter, Cedillo, Chesbro, Conway, Cook, Dickinson, 
            Donnelly, Eng, Feuer, Fletcher, Fong, Fuentes, Furutani, 
            Beth Gaines, Galgiani, Garrick, Gatto, Gordon, Grove, 
            Hagman, Hall, Hayashi, Roger Hernández, Hill, Huber, 
            Hueso, Huffman, Jeffries, Jones, Knight, Lara, Logue, 
            Bonnie Lowenthal, Ma, Mansoor, Mendoza, Miller, Mitchell, 
            Monning, Morrell, Nestande, Nielsen, Norby, Olsen, Pan, 

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            Perea, V. Manuel Pérez, Portantino, Silva, Skinner, 
            Solorio, Swanson, Torres, Valadao, Wagner, Wieckowski, 
            Williams, Yamada, John A. Pérez
          NO VOTE RECORDED:  Davis, Gorell, Halderman, Harkey, Smyth


          JJA:k  6/26/12   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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