CDBG Entitlement FAQ

What is the low/moderate income preponderance test, and how is it calculated within the CDBG urban county context?

Date Published: April 2019

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A new potentially eligible county may use this method of qualifying if it cannot get every unit of general local government (UGLG) to join the urban county, and, as result, the population of the participating UGLGs and the unincorporated areas does not add up to 200,000. (Note, however, that the county must first meet the 200,000 population threshold to be eligible.)

An existing urban county may use this method of requalifying as an urban county if it has not been an urban county since 1999, or if its population is just over 200,000, and several of its participating UGLGs decide to leave the urban county, thus dropping the population below 200,000. (For example, the largest city in the county crosses the 50,000 population threshold and elects to leave the urban county to become an Entitlement city on its own when the county's current three-year qualification period ends.)

In either of these cases, the county can still qualify, so long as (1) the population of the participating UGLGs and the unincorporated areas has at least 100,000 population; and (2) the areas that are participating include a majority of the low and moderate persons living in the county (see Section 102(a)(6)(A)(ii) of the Housing and Community Development Act -HCDA).

The low/moderate income preponderance test is calculated by taking the total number of low- and moderate-income persons in the county minus the low- and moderate-income population in entitlement cities, if any. Take the sum and divide it by two, then add one. This is the minimum number of persons that reside in the county that must be low- and moderate-income to meet the preponderance test. For example, county X has a population of 200,475, not counting the populations of Entitlement cities Y and Z. County X has a total low- and moderate-income population of 58,000. Subtract the low- and moderate-income population that is in Entitlements Y and Z (58,000 – (12,000 + 2,000)). That leaves 44,000. Divide it by two which equals 22,000 and then add one which equals 22,001. If the unincorporated areas of the county plus all the participating UGLGs combined have at least 22,001 low- and moderate-income residents, county X can qualify as an urban county.

Tags: CDBG Entitlement Program Urban County