Interim Guidance for ICC Members on
Community Development Block Grant Funding

Since the passage of the National Flood Insurance Reform Act (HR 4348), that included language re-affirming and amending the use of “Community Development Block Grant” or “CDBG” grant funds for the purposes of building code administration, ICC has been working with the U.S. Department of Housing and Urban Development to create a guidance document, for both code officials interested in applying for grant funding, and for HUD program administrators and state coordinators, to make sure there is a uniform understanding that CDBG funding may be used for building code administration. ICC will also hold a webcast with HUD early this year to provide ICC Members with key information on how they can compete for this CDBG funding.

The best way for code compliance departments to successfully apply for, and receive grant funds, is to make sure both code officials and HUD officials, are seeing the same guidance with respect to the code funding, according to ICC.

As ICC continues to work out details with HUD officials, the following guidance is for Code Officials to use right now to position themselves to obtain CDBG grant funding.

First, a few key facts:

• CDBG funding for code administration is already authorized under existing law, and many code departments have received funding for code programs.  
• HUD classifies cities and counties as either “Entitlement Communities” that get a direct allocation of CDBG funding every year, or as “Non-Entitlement Communities,” which are smaller in size, who must apply for CDBG funding from their State (or sometimes from their county).
• To apply for CDBG grant funds, code departments in Entitlement Communities will need to work within their city or county, to include their request in the overall city/county CDBG grant proposal. Code Departments cannot apply directly to HUD for CDBG funding, even under the new amendments to the program.
• For Non-Entitlement Communities, code departments should likewise work within their own city or county to discuss applying to the state for CDBG funding for code programs.
• The most important and most critical step to take NOW is to determine who in your city/county administration is responsible for coordinating CDBG programs and funds, and find out what the timeline is for development of the next funding proposal.
• Once you determine the schedule, it will be useful to schedule a short meeting with your city/county CDBG coordinator, and determine what the expected total funding proposal for the city/county will be, and what they might believe to be a reasonable request from the code administration department.
• Once you have these key facts at hand, you will be ready to participate in the upcoming ICC/HUD webinar, and utilize the guidance document that we will be publishing.

More information to assist with a successful proposal — WITHIN your city or county.

• As is obvious from the facts above, unless you convince your city/county coordinator to include funds for code administration in the city/county CDBG proposal, you won’t be able to access CDBG funds. So, you must explain why code administration benefits the city/county. Here are a few ideas, for you to consider, and build upon:
  • The best strategy for preventing or reducing community blight and deterioration is a strong code program.
  • Strong code administration is attractive to prospective businesses and to those considering relocation to your community. The Economic Development office may be your ally in seeking to be included in the CDBG proposal.
  • Federal Government requirements for new office space, as well as those of most leading companies, demand energy efficiency, water efficiency, and other green attributes in new buildings, and in leased space. Strong administration of the building codes, including the IECC and IgCC, if applicable, assures them of green buildings.
  • While there are requirements that CDBG funds be used to eliminate blight and help in improving depressed and low-income communities, CDBG funds that pay for the costs of inspecting and enforcing codes in these areas can free up code department funding to enforce green codes, and help with economic development efforts, such as reduced permitting and inspection incentives for new and relocating business entities. Your economic development department can be an ally in this effort.

These are a few ideas for laying the groundwork for a successful CDBG grant effort, both within your city or county, and at the level of HUD, whether your city is an “entitlement” jurisdiction, or whether it applies for funding through its state HUD office. The upcoming ICC/HUD document will fully explain the difference between the two types of jurisdictions, and how the process of CDBG grants varies for the two types of cities/counties. For now, follow the suggestions above, to be ready for the upcoming webinar and guidance publication.