BEFORE THE DEPARTMENT OF COMMERCE
OF THE STATE OF MONTANA
In the matter of the amendment of ARM 8.94.3728 pertaining to the administration of the 2021 Biennium Federal Community Development Block Grant (CDBG) Program – Planning Grants
NOTICE OF AMENDMENT
TO: All Concerned Persons
1. On August 7, 2020, the Department of Commerce published MAR Notice No. 8-94-184 pertaining to the public hearing on the proposed amendment of the above-stated rule at page 1378 of the 2020 Montana Administrative Register, Issue Number 15.
2. The department has amended the above-stated rule as proposed.
3. The department has thoroughly considered the comments and testimony received. A summary of the comments received and the department's responses are as follows:
COMMENT NO. 1: We encourage the Montana Department of Commerce Community Development Division CDBG program to increase physical accessibility, visit ability, and universal design in rental and homebuyer housing stock in the state and to partner with cities, towns, and prospective CDBG applicants to highlight accessible community planning.
RESPONSE NO. 1: Commerce concurs that all Montanans should be able to live in the least restrictive environment possible. The 2015-2020 Montana Consolidated Plan (ConPlan) objectives support the provision of housing for those who are homeless, chronically homeless, at risk of homelessness, seniors, and the disabled, all populations that experience difficulty in finding affordable and accessible housing. The HOME, CDBG, HTF, and ESG programs specifically support efforts by local governments and partner organizations to assist the disabled. Each construction project proposal for any of these HUD-funded programs is considered in terms of its likelihood to meet appropriate ConPlan objectives. The CDBG program includes requirements and recommendations for both accessibility and visit ability, as well as increased connectivity through transportation and opportunity.
COMMENT NO. 2: We encourage the Montana Department of Commerce Community Development Division CDBG Planning Program to allow local governments to apply for and receive more than one planning grant during a funding cycle in special situations.
RESPONSE NO. 2: In the interest of serving as many communities as possible across the state with limited planning funding, Commerce limits each eligible county, city, and town to receiving, and having one open CDBG planning grant per funding cycle. Commerce encourages communities to work with their local governments to prioritize planning needs in deciding which projects to propose for CDBG planning funding each cycle and to work with the Community Development Division staff to ensure that CDBG planning grant applications are complete and as competitive as possible when they are submitted.
COMMENT NO. 3: We encourage the Montana Department of Commerce Community Development Division CDBG program to note the impact of civil legal aid on the root causes of homelessness and include financial support for civil legal aid as part of the department's planned future actions to increase housing sustainability and reduce homelessness in Montana communities.
RESPONSE NO. 3: The CDBG planning grant program currently allows for the planning of public services.
/s/ Amy Barnes /s/ Tara Rice
Amy Barnes Tara Rice
Rule Reviewer Director
Department of Commerce
Certified to the Secretary of State September 15, 2020.