The Community Development Block Grant (CDBG) program requires that each CDBG funded activity must either principally benefit low- and moderate-income (LMI) persons, aid in the prevention or elimination of slums or blight, or meet a community development need having a particular urgency. Most activities funded by the Community Development Block Grant (CDBG) program are designed to benefit low- and moderate-income (LMI) persons. This benefit may take the form of housing, jobs, and services. Additionally, activities may qualify for CDBG assistance if the activity will benefit all the residents of a primarily residential area where at least 51 percent of the residents are low- and moderate-income persons, i.e. area-benefit (LMA). [Certain exception grantees may qualify activities as area-benefit with fewer LMI persons than 51 percent.]
- National Objectives and Eligibility Guide for CDBG Entitlement Communities Chapter 3, or
- National Objectives and Eligible Activities Guide for State CDBG Programs
Two-Step Documentation Process
There are two steps that a grantee should use to qualify activities as area-benefit.
- Determine Service Area
Based on the type of activity, the grantee will choose a reasonable service area, and then refer to the LMISD for an equivalent geography (see step two). Grantees may choose to take additional steps to delineate service areas, such as market studies. Activity service areas should be reasonably delineated based on the intended beneficiaries of the LMA activity. Once the service area has been reasonably delineated, the most-corresponding LMISD geographies are chosen. The service area shall not be drawn to include LMI persons that would not benefit, nor shall it be drawn to exclude non-LMI persons that would benefit.
- Document the Percentage of Low- and Moderate-Income Persons
Grantees may use either the HUD-provided, low- and moderate-income data OR local income survey data that is methodologically sound.
- Low Moderate Income Summary Data (LMISD)
CPD Notice 19-02 discusses how to use the LMISD geographies to match the service area. The LMI percentages are determined for various geographies, including each block group, each local government (both incorporated and unincorporated cities and towns, i.e. "places"), and each CDBG grantee. Additionally, HUD publishes data based on the 2011-2015 American Community Survey ACS 5-year estimates, the 2006-2010 ACS 5-year estimates, and 2000 Decennial Census. See Low Moderate Income Survey Data Sets below to determine which set should be used.
- Local Income Survey
- Guidance on how to do an Income Survey:
Notice CPD-14-013: Guidelines for Conducting Income Surveys to Determine the Percentage of Low- and Moderate-Income (LMI) Persons in the Service Area of a CDBG-Funded Activity
- CPD Notice 19-02 also provides new policy regarding the minimum standards for confidence interval and margin of error for local income surveys.
- Survey Tools – coming soon!
Low- and Moderate-Income Survey Data LMISD Sets
- Questions about the calculation of the estimates may be directed to Formula Help Desk.
- Questions about the use of the data should be directed to the staff of the CPD Field Office.