7124-96A Amend Citizen Participation Plan

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Exhibit A — Attachment I SUBSTANTIAL CHANGE POLICY Federal Regulations require the City of Lakewood, as a recipient of CDBG funds, to prepare and make public a "final statement" as a part of the city's annual CDBG application. The "final statement" contains the city's community development objectives and proposed uses .of CDBG funds. The "final statement" is prepared by the Department of Planning & Development following the approval by City Council of the annual CDBG budget. Federal Regulations also require the city to formally amend the final statement when adding or deleting activities during the grant year. The city is also required to amend the "final statement" when the city wishes to "substantially change" the purpose, scope, location or beneficiaries of an activity contained in the "final statement." These regulations require the city to develop and make public its criteria for what constitutes a "substantial change". For the. purposes of this policy, the Department of Planning & Development has adopted the following as its criteria for determining when a "substantial change" has occurred. Change in Purpose The proposed uses section of the final statement describes the reasons CDBG funds were awarded by the city. It is expected that virtually all the allocated CDBG funds will be spent in conformance with the final statement. A "substantial change" will have occurred when more than 10% of the grant funds for an individual activity are used for a purpose not contained in the final statement. A "substantial change" will not have occurred when the recipient is able. to accomplish the goals. set out in the final statement and their CDBG application for less money than originally budgeted, if these grant funds are used to accomplish another activity contained within the final statement. Change in Scope The final statement often contains the extent of the activity to be undertaken with CDBG funds. However, often the subrecipient is unable to accomplish the project to the extent it originally thought due to external conditions. Therefore, a. "substantial change" will .have occurred only when the project fails to meet 1 /2 of the measurable objectives contained in the final statement. An increase in the number of beneficiaries will not constitute a substantial change solely due to the percentage or numerical increase in the number of beneficiaries assisted by a CDBG subrecipient. Change in Location Locations are rarely contained in the final statement, as most CDBG funds are spent on a city-wide basis. A "substantial change" in location will have occurred when the location contained in the final statement is an integral part of the reason CDBG funds were awarded. Locations contained in the final statement which are incidental to the purpose for which CDBG funds were awarded will not be considered a "substantial change". Change in Beneficiaries The final statement generally classifies types of beneficiaries. For example, homeowners, elderly, or abused children. A "substantial change" will have occurred when 10% or more of the beneficiaries assisted in a specific activity are outside the general classification contained within the final statement.