Town of Rockland 3 5; 242 Union Street lees-w" Rockland, MA 02370 ?I?arnn 11"? June 12, 2020 Mark Southard Community Development Manager Department of Housing and Community Development 100 Cambridge Street Suite 300 Boston, MA 02114 RE: Letter of Interest - Rockland Regional CDBG-CV Grant Application Dear Mr. Southard: On behalf of the Town of Rockland, I am pleased to submit this letter of Interest for the Rockland Regional CDBG-CV grant application. Participating Communities and Proposed Activities Rockland will serve as the lead community for this regional application and is partnering with the Towns of Avon, Abington, Holbrook, Hull, and Wareham. These six communities have a combined population of 82,755 residents. Proposed activities to be conducted include: 1) Microenterprise Assistance; and 2) Public Social Services - Nutritional Support Programs (Food Pantries) and Homelessness Prevention. Contact Person Douglas Lapp, Town Administrator Rockland Town Hall 242 Union Street, Rockland, MA 02370 781-871-1874, ext. 1105 Grant Funds Requested: $662,400.00 Of this amount, $480,000.00 will be allocated to assist eligible microenterprises and $96,000.00 will be allocated for public social services, specifically nutrition support and homelessness prevention in the participating communities. A total of $86,400.00 will be allocated for General Administration. Public Hearing A virtual public hearing was conducted by the Rockland Board of Selectmen on June 2, 2020 at 7:00 pm. via Zoom. Notice of the public hearing was posted by the Town Clerk in Rockland on May 28, 2020 and was published in The Patriot Ledger on May 29, 2020. The public hearing notice was also published on each of the participating towns? websites to allow residents and business owners in all six communities to participate. Written comments were accepted until 5 pm. on Friday, June 5, 2020, via email to Rockland Assistant Town Administrator Jennifer Constable. No written comments were received. Copies of the publications, postings, website notices, and meeting agenda and minutes are on file at the Rockland Office of Community Development. Consultants and Partner Agencies Upon notice of a grant award, the Town will procure the services of an experienced community development consultant to administer the grant and manage the proposed activities. Partner agencies in each community will assist in outreach and delivery of services, including each Town?s Planning Department, Council on Aging, Food Pantry and/or Economic Development or Business Interest Group. These partner agencies assisted with the development of this grant application by providing data on the impact of Covid-19 in each community, identifying potentially eligible microenterprises and surveying those businesses regarding the impact of the pandemic on their businesses, as well as identifying the level of need for additional nutritional supports related to the virus. Experience of the Applicant The Town of Rockland has a long history of successfully managing CDBG grants. Since 2010, the Town has received four CDBG grant awards (2010, 2011, 2014, and the current 2018 grant). it was also a regional partner in a 2016 grant in which the Town of Holbrook was the lead. The administrative infrastructure already exists to successfully manage a CDBG-CV grant. Thank you for your consideration of this application. Please let us know if you require additional information. Sincerely, Board of Selectmen Mich el O?Loughlin Chairman cc: Douglas Lapp, Town Administrator TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application CDBG-CV Microenterprise Assistance 1. Program Need: The Town of Rockland requests $480,000.00 to establish a regional microenterprise assistance grant program for Rockland and its partnering towns of Abington, Avon, Holbrook, Hull, and Wareham. According to the Bureau of Labor Statistics, unemployment in Massachusetts increased from 2.8% in March of this year to 15.1% in April. Job losses to that degree can be devastating to communities such as Rockland and its partnering applicants. From April to May, these communities suffered job-loss totaling approximately 7,800, which represents 25% of total jobs, compared to 23% lost in Massachusetts overall for the same time period.1 While 25% is only slightly higher than the state job-loss percentage, the majority of these communities had an already demonstrated high level of need before the Covid-19 pandemic, which suggests LMI business-owners may be disproportionately impacted, as illustrated by HUD LMI percentages and DHCD’s assigned LMI Points. See summary chart below. Community Rockland Abington Avon Holbrook Hull Wareham HUD LMI Percentage* 43% 25.5% 31.9% 44% 37.1% 52.1% LMI Score 9 4 6 9 8 Mini-Entitlement * Source: LMISD by Local Governments, Based on 2011-2015 ACS Collectively, the six communities are home to more than 1,300 microenterprise businesses in a wide range of industries, including construction, wholesale trade, professional/scientific, administrative/support/waste management, health care and social assistance, and arts and entertainment/recreation. Most of these microenterprises are in health care and social assistance and uncategorized “other services.”2 To further assess need in these communities, Community Opportunities Group, Inc., conducted an informal survey in the weeks leading up to this application, receiving dozens of responses directly from microenterprise business owners who were remarkably candid in sharing both their current needs and uncertainty about the future of their businesses and income. A short summary of salient information received follows.  In Rockland, 55% of respondents reported reduced revenue during the pandemic of more than 50%. Three-quarters of respondents said they had reduced staffing, laid off employees, or both.  In Abington, 22% of respondents had reduced revenue by more than 50%, while a quarter of responding business-owners said revenue was reduced by 25% to 50%, and 44% said they had reduced staffing, laid off employees, or both.  Half of survey respondents in Avon reported revenue loss of more than 50%. Half had also reduced staff hours and/or laid off employees.  In Hull, half of survey respondents reported revenue loss of more than 50%, and a quarter indicated that they had reduced staff, reduced staff hours, or laid off employees.    TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application In Wareham, 47% of respondents reported reduced revenue of more than 10%, 23% reported revenue loss of more than 25%, and 11% reported a loss of more than 75%. The majority of all survey respondents reported that they were either already behind on bill payments or would be behind within one to three months. Nearly all survey respondents reported that funding of $5,000 to $10,000 or less would help their business remain sustainable. Without funding, nearly all reported that they would face closure within one to three months. Nearly all reported needed funding to pay rent and/or utilities. While not all survey respondents reported household income amounts that are considered low or moderate, based on the overall regional LMI data and the survey responses received, there is a clear need for microenterprise assistance in all of the participating communities. Using the contact information provided through the survey responses, staff will be able to contact interested businessowners and begin the income-qualification process almost immediately upon grant award. How Activity Will Address Need: The proposed Rockland Regional Microenterprise Assistance Program will address the financial needs of the microenterprises located in the six communities that have been negatively impacted by the Covid-19 pandemic. The Program will provide grants for three months of operating expenses (e.g., costs of rent, staffing, and utilities) up to $10,000 per eligible microenterprise. As illustrated by the survey data, this influx of funding would address the financial impacts the businesses have suffered due to being declared “non-essential” or from having to make debilitating changes in operations due to the pandemic. The assistance will be in the form of grants to the businesses because many microenterprises would not qualify for loans in the current financial climate. A grant would also provide working capital without adding additional debt to already strapped business owners. Eligibility will be determined in accordance with the requirements described in DHCD’s NOFA for the CDBG-CV program. Guidelines will be developed to reflect the requirements regarding duplication of benefits, limits on use of the funding, income-eligibility of the business owner(s), and prohibition of assistance to certain types of businesses/industries. Assistance will be limited to demonstrable expenses and cannot be used for equipment purchases or expansion of the business. Population Impacted: There are more than 1,300 businesses with five or fewer employees among the six communities. Estimated microenterprises by town are: Rockland, 404; Abington, 241; Avon, 88; Holbrook, 157; Hull, 88; Wareham, 343.3 While many of these businesses would not qualify for assistance because they are over-income and/or due to the nature of the business (insurance agents, doctors, lawyers, etc.), a close review of the databases coupled with the survey responses received indicate that there are hundreds of potentially eligible microenterprises in the region. Initial goals are to assist five microenterprises in each town, with a pool of additional funding established for towns with a higher response, indication of need, or both. Please see the Budget Detail below for additional information. TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application Timeline: Milestone Assistance) (Microenterprise Grant Award Grant Agreement Executed CDBG Grant Management RFQP Issued CDBG Management Consultant Selected Program Guidelines Approved Application Period (three weeks) Program Outreach Program in full operation Grant Closeout Target Date Comments July 2020 July 2020 July 2020 September 2020 Subject to change per DHCD Different date may affect schedule October 2020 October 2020 November 2020 Nov. 2020 – May 2021 June 2021 Contract approval will require DHCD First-come, first-served Program Management: This activity meets the National Objective of Benefit to Low- and Moderate-Income (LMI) persons. The Town of Rockland was chosen as the lead municipality for this application due to its long history of successfully managing CDBG grants and meeting National Objectives. Since 2010, the Town has received four CDBG grant awards (FYs 2010, 2011, 2014, and the current 2018 grant). Rockland has traditionally contracted with an experienced grant management consultant to implement its CDBG programs. The Town will take the same approach to successfully manage this CDBG-CV grant. Partners in each community will assist in outreach and delivery of services. Upon notice of a grant award, Rockland will procure (per MGL c.30B and 2 CFR Part 200) the services of an experienced grant management consultant to fulfill the duties of Program Director and Program Manager. The Program Director will be responsible for overseeing the income verification process, program compliance, overall grant implementation performance, development of program guidelines, program policy matters and will initially respond to grievances. The Program Manager will manage the day-to-day operation of the Rockland Regional Microenterprise Assistance Program, including: marketing and outreach; application intake and income verification; contracts; and quarterly and other reports required by DHCD and the City. Program Staff will ensure compliance with the LMI National Objective (Limited Clientele) by determining the owner(s) of the microenterprise is (are) LMI persons (≤80% of the AMI, based on family size) using direct source documentation (2018 or 2019 IRS Form 1040, or eight weeks of income documentation at the time the application is activated to calculate an estimate of current income). Records demonstrating this compliance with the National Objective shall be maintained for each business receiving assistance. As part of the application process, applicants will have to certify that they did not receive assistance for eligible microenterprise costs from another public source of financial assistance (e.g., Payroll Protection Program, MA Attorney General’s program), or that any prior such assistance has been exhausted. This screening will ensure that publicly-sourced benefits are not duplicated and other public funds will not be displaced by any funds distributed through this application. TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application Activity Monitoring: The selected CDBG management consultant shall be responsible for establishing appropriate file management and documentation systems that demonstrate national objective compliance, program guideline compliance and adhere to state and federal provisions for purposes of monitoring. Regular progress reports (on at least a quarterly basis) will be prepared that include demographic information and documentation of program expenses. Microenterprise Assistance Budget Detail: The total budget for this activity is $480,000. Each qualifying microenterprise will be eligible for up to three months of assistance and/or a maximum benefit of $10,000. Based on commercial rental rates in the region, an assumed average business size of three employees and an assumed average salary of $1,000/month per employee, it is projected that each eligible business will qualify to receive close to the maximum benefit. It is estimated the proposed CDBG-CV funds will allow the Program to assist a minimum of 48 microenterprises. A total of $50,000 for each of the six towns will be initially earmarked for the microenterprise program. A common pool for an additional $180,000 will be allocated to the microenterprise program for towns that demonstrate an increased need for the funds. The $50,000 set-aside for each town will be held for six months following program launch. If uncommitted funds remain after six months, the balance will go into the common pool. Rockland Regional Microenterprise Assistance Program Budget Rockland Microenterprise Assistance Abington Microenterprise Assistance Avon Microenterprise Assistance Holbrook Microenterprise Assistance Hull Microenterprise Assistance Wareham Microenterprise Assistance Microenterprise Program, Common Total Units to be Assisted 5 5 5 5 5 5 18 48 CDBG-CV Funds $50,000.00 $50,000.00 $50,000.00 $50,000.00 $50,000.00 $50,000.00 $180,000.00 $480,000.00 This budget was developed by Wayne Darragh of Community Opportunities Group, Inc., a CDBG consultant with more than 25 years of experience managing CDBG grants. 2. Microenterprise Assistance Environmental Review: The Environmental Review Record for this activity is complete and has been submitted with this application. 1 Source: Community Opportunities Group, Inc.; MA EOWLD, Weekly Initial Unemployment Claimant Data; MA EOWLD, ES-202 2019 2 Source: A to Z Databases (http://www.atozdatabases.com); Community Opportunities Group, Inc.; MA EOWLD, Weekly Initial Unemployment Claimant Data; MA EOWLD, ES-202 2019 3 Source: A to Z Databases (http://www.atozdatabases.com); TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application Rockland CDBG-CV Public Social Services Program Need: The proposed Public Social Services will address food insecurity in Rockland, Holbrook, Hull, and Wareham, and the prevention of homelessness in Wareham. Details and justification follow in the next section. The total budget is $96,000.00. How Activity Will Address Need: Need will be addressed in specific ways appropriate to each community and each participating organization’s capacity and circumstances. The Town of Rockland requests a total of $20,000 to fund an increased demand for its Council on Aging meal program and to support a new initiative to supply meals to Rockland veterans. The Rockland COA served 1,338 lunches total during March, April, and May 2020. Last year, the COA served approximately 1,000 lunches. During the same three month period this year, the new Meals for Veterans program served 343 meals for veterans. To date, the COA is funding the additional meals with donations. This funding will ensure the COA has the ability to meet the increased demand for its meals programs. The Avon Baptist Church Food Pantry began seeing increased traffic due to Covid-19 beginning in May. The pantry typically serves an average of 15 people per month, most of whom are seniors, but is now serving more adults of all ages, not quite doubling its client load. The need will be compounded in July, as seniors are currently receiving hot meals through the Avon Public Schools, but that program is slated to end when school ends in June. To meet the needs of increased clients and provide more balanced nutrition, the Avon Baptist Church is requesting assistance totaling $4,500 to purchase an upright refrigerator and freezer so that it can offer fresh produce, milk, and meats to clients. The remaining funds will be used for the purchase of food. Before the pandemic, the Holbrook Ecumenical Food Pantry typically served an average of 100 to 110 families per month at one visit per month. (The average household size in Holbrook is 2.67i). To meet increased need, the pantry is now serving nearly 170 families, twice per month. This requires two to three trips to the Greater Boston Food Bank per month, as opposed to one or two in the past, at a cost of $200 per trip, as the pantry needs to rent a truck. The pantry has also instituted the “Emergency Covid-19 Families” program in which volunteers deliver food to those in quarantine. At the outset, emergencies totaled seven to eight per week and have decreased to an average of one per week. Need is expected to increase again as Unemployment Insurance Relief ends in July, though already the pantry is feeling the strain. At an upcoming distribution, the pantry expects 130 families and has just 72 half-gallons of milk to distribute. The pantry requests $10,500 to cover rental truck costs and fund the purchases of additional goods to meet the increased demand. The Wellspring Multi-Service Center in Hull immediately changed its food pantry to a 100% delivery model, with twice per week deliveries, in response to the pandemic. Previously, it provided the bulk of its services to clients in person. When schools closed, the organization teamed with Hull Public Schools to deliver enough breakfasts and lunches each week for every child who receives free/reduced school lunches. A Title I district, nearly 31% of Hull’s students were considered economically disadvantaged this school yearii. These changes have resulted in increased payroll costs, additional costs in gas and van maintenance, and a strain on the food supply. Staff anticipates continuing the meals for children through August, and is also concerned about increased need once the additional $600 in weekly unemployment benefits runs out in July. The center requests funds totaling $14,500 to cover the additional salary cost of its van driver and to purchase food to meet need. TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application The Family Pantry - Damien’s Place in Wareham has had to reallocate budget items in response to both increased need and an anticipated uptick in clients when supplemental unemployment funds end. The pantry closed for a short period in the beginning of the pandemic due to concerns about employee, volunteer, and client safety, but it did not stop serving the community at large. Staff supported the Council on Aging in Marion and a church pantry in New Bedford (formed due to the pandemic) with thousands of pounds of food. Upon reopening Damien’s, staff realized a need to waive the visitfrequency restrictions it previously imposed. Clients were previously allowed only one visit to Damien’s Place per month. Clients may currently visit whenever they are in need of food and the pantry is open (two days per week). Lifting the one visit per month restriction means Damien’s food supplies aren’t lasting as long and to be replenished more frequently. Damien’s Place requests $21,500 to cover the payroll of its single paid employee, a warehouse worker, to pay rental costs for five months, and to purchase food. Due to Covid-19, funds that would have offset the costs of payroll and rent for the organization had to be reallocated to address other urgent needs, including purchasing cleaning supplies and personal protective equipment, and assisting pantries in neighboring towns with food purchases. Though the pantry receives funding through Wareham’s Mini-Entitlement Program, those funds only cover a short period. CDBG-CV funds would not displace those or other public funds. The Wareham Area Committee for the Homeless (WACH) is bracing itself for an increased need for homelessness prevention services and support through its Turning Point program. With rent and utility protections in place, Turning Point has been treading water during the pandemic in preparation for a surge. Staff has fielded phone calls from dozens of clients and past clients, known to staff to be “responsible renters,” who are anticipating the end of federal and state protections and wondering how they are going to remain in their home after a reduction in work hours and/or job loss. WACH requests $25,000 to help it meet the known and anticipated needs of clients. A years-long recipient of CDBG funding, WACH spends funds expeditiously and with care. This funding will only be used to meet increased need for services. It will not displace CDBG or other public funds. Scale and Impact: Approximately 11,250 total beneficiaries, potentially duplicated  Rockland: Approximately 5,500 total meals ($3.63/mealiii)  Avon: Approximately 689 meals at an average cost of $3.63/meal  Holbrook: Approximately 1,235 meals at an average cost of $3.63/meal  Hull: Approximately 800 meals or 100 meals per monthiv  Wareham (Damien’s Place): 1,830 meals at $3.82/mealv; 122 unduplicated people  Wareham (WACH/Turning Point): Approximately 1,200 beneficiariesvi Timeline: Milestone (Public Social Services) Target Date Comments Grant Award Grant Agreement Executed Program Manager Hired Special Conditions Met NOI/RROF Published; Funds Released PSS Grantees Begin Spending Funds PSS Funds Depleted Grant Closeout July 2020 July 2020 July/August 2020 August 2020 August 2020 Subject to change per DHCD Different date may affect schedule Use prior RFP/Qs as templates to expedite process. August/Sept. 2020 May/June 2021 June 2021 Special Conditions may not be applicable ERR complete TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application Program Management: This activity meets the National Objective: Benefit to low- and moderateincome (LMI) persons. The Town of Rockland was chosen as the lead municipality for this application due to its long history of successfully managing CDBG grants and meeting National Objectives. Since 2010, the Town has received four CDBG grant awards (2010, 2011, 2014, and the current 2018 grant). Rockland has traditionally contracted with an experienced grant management consultant to implement its CDBG programs. The Town will take the same approach to successfully manage a CDBG-CV grant. Further, three of the Public Social Services partners have current or previous experience in implementing CDBG funding: The Wellspring Multi-Service Center, The Family Pantry – Damien’s Place, and the Wareham Area Committee for the Homeless. Upon notice of a grant award, the Town will procure the services of an experienced grant management consultant to administer the grant and manage the proposed activities. Partners in each community will assist in outreach and delivery of services. Public Social Service partners were screened to ensure that federal benefits are not duplicated and other public funds will not be displaced by any funds received through this application. The partners will officially certify the same in writing if funding is awarded. Activity Monitoring: Grant management staff will assist all organizations in setting up file management systems and reports that adhere to state and federal provisions. Monthly progress reports including demographic information and documentation of expenses will be required of all PSS organizations prior to receiving reimbursement of costs. Grant management staff will monitor each organization throughout the life of the grant. Public Services Budget Detail: Each organization included in this application has requested only the funds necessary to help meet the needs presented by the Covid-19 pandemic. The $96,000.00 total budget and estimated 11,250 beneficiaries (potentially duplicated) represent an estimated $8.53 cost per beneficiary. The estimates are conservative. The cost may be lower. The budget was analyzed by Wayne Darragh of Community Opportunities Group, Inc., a CDBG consultant with more than 25 years of experience implementing CDBG grants. A detailed budget for each public service follows. Rockland COA – 5,500 meals/beneficiaries (possibly duplicated) LINE ITEM BUDGET Uses: Food: Approx. $2,470/month x 8 months (~5,500 meals ⅳ) Total Sources: CDBG $19,760.00 $20,000.00* * Rounded from $19,760.00 Avon Baptist Church Food Pantry – 689 meals/beneficiaries (possibly duplicated) LINE ITEM BUDGET Uses: Sources: CDBG Purchase of Upright Freezer (19 cu. ft. or similar) $860.00* Purchase of Upright Refrigerator (17 cu. ft. or similar) $860.00* Purchase of Food $2,500.00* TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application Total $4,500.00** * Source: Lowe’s, June 2020 / ** Rounded from $4,220.00 Holbrook Ecumenical Food Pantry – 1,235 meals/beneficiaries (possibly duplicated) LINE ITEM BUDGET Sources: Uses: CDBG Truck Rental: $200/trip x 2 trips per month x 8 months $3,200.00 Toiletries: Approx. $300/month x 8 months $2,400.00* Food: $115/week x 39 weeks (~1,235 meals) $4,485.00 Total $10,500.00** * Source: Pantry’s estimated average expenses / ** Rounded from $10,085.00 Wellspring Multi-Service Center – 800 meals/beneficiaries (possibly duplicated) LINE ITEM BUDGET Sources: Uses: CDBG Van Driver Additional Salary Cost: 15 hours/week x $17/hour x 39 weeks $9,945.00 Food: Approx. $115/week x 39 weeks (~800 meals ⅳ) $4,485.00 Total $14,500.00* * Rounded from $14,485.00 The Family Pantry – Damien’s Place – 1,830 meals/beneficiaries (possibly duplicated) LINE ITEM BUDGET Sources: Uses: CDBG Warehouse Worker Salary:. $700/week x 12 weeks $8,400.00 Warehouse Rent: $1,200/month x 5 months $6,000.00 Food: 1,830 meals x $3.82/meal v Total $6,990.60 $21,500.00* * Rounded from $21,400.00 Wareham Area Committee for the Homeless (WACH) / Turning Point (1,200 beneficiaries) LINE ITEM BUDGET Uses: Sources: CDBG Homelessness Prevention Services (1,200 beneficiaries) $25,000.00 Total $25,000.00 Public Services Environmental Review: The ERR is completed and included with this application. TOWN OF ROCKLAND Community Development Block Grant COVID-19 (CDBG-CV) Application i U.S. Census, 2018: ACS 5-Year Estimates, Subject Tables, Households and Families (S1101) Massachusetts Department of Elementary and Secondary Education, School and District Profiles, Selected Populations, 2019-2020; http://profiles.doe.mass.edu/profiles/student.aspx?orgcode=01420000&orgtypecode=5&leftNavId=305& iii Current average meal cost in Massachusetts according to Feeding America; https://www.feedingamerica.org/hunger-inamerica/massachusetts iv Conversation with Mr. Vinny Harte, President and CEO of Wellspring Multi-Service Center v Conversation with Mrs. Carol Cordeiro, Damien’s Place Director vi Conservative estimate based on prior spending and anticipated need ii U.S. Department of Housing and Urban Development 451 Seventh Street, SW Washington, DC 20410 www.hud.gov espanol.hud.gov Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5 Pursuant to 24 CFR Part 58.34(a) and 58.35(b) Project Information Project Name: Rockland Regional Microenterprise Assistance Program Responsible Entity: Town of Rockland, Massachusetts Grant Recipient (if different than Responsible Entity): Same State/Local Identifier: MA Preparer: Wayne Darragh, Community Opportunities Group, Inc. Certifying Officer Name and Title: Douglas Lapp, Town Administrator Consultant (if applicable): Community Opportunities Group, Inc. Project Location: Eligible microenterprise businesses located in the participating towns of Rockland, Avon, Abington, Holbrook, Hull and Wareham. Description of the Proposed Project [24 CFR 58.32; 40 CFR 1508.25]: The program will provide grants to income-eligible microenterprise businesses in the participating communities of Rockland, Abington, Hull, Wareham [Plymouth County, Massachusetts], Holbrook and Avon [Norfolk County, Massachusetts] , negatively affected by the Covid-19 Pandemic. Grants are designed to stabilize affected businesses by assisting with operating costs such as rent, utilities, and payroll. Maximum grant for an eligible microenterprise business is $10,000. Level of Environmental Review Determination: Activity/Project is Exempt per 24 CFR 58.34(a): Activity/Project is Categorically Excluded Not Subject To §58.5 per 24 CFR 58.35(b)(4): “Economic development activities, including but not limited to, equipment purchase, inventory financing, interest subsidy, operating expenses and similar costs not associated with construction or expansion of existing operations” Page 1 of 4 Microenterprise Grant Program Rockland Regional Application HEROS Number TBD Estimated Total CDBG Funded Amount: $480,000.00 This project anticipates the use of funds or assistance from another Federal agency in addition to CDBG in the form of (if applicable): Not applicable Estimated Total Project Cost (CDBG and non-CDBG funds) [24 CFR 58.32(d)]: $480,000.00 Compliance with 24 CFR §50.4 and §58.6 Laws and Authorities Record below the compliance or conformance determinations for each statute, executive order, or regulation. Provide credible, traceable, and supportive source documentation for each authority. Where applicable, complete the necessary reviews or consultations and obtain or note applicable permits of approvals. Clearly note citations, dates/names/titles of contacts, and page references. Attach additional documentation as appropriate. Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR 50.4 and 58.6 Compliance determinations Are formal compliance steps or mitigation required? STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR §58.6 Airport Runway Clear Zones and Accident Potential Zones Yes No Yes No 24 CFR Part 51 Subpart D Coastal Barrier Resources Coastal Barrier Resources Act, as amended by the Coastal Barrier Improvement Act of 1990 [16 USC 3501] Project involves grants for operating costs related to losses of eligible microenterprises resulting from Covid-19 pandemic. HUD assistance is not being used for new construction, substantial rehabilitation, acquisition of undeveloped land or activities that would significantly prolong the physical or economic life of existing facilities in an airport runway clear zone (24 CFR Part 51.302). No participating community is located within 15,000 feet of a military airport nor 2,500 feet of a civilian airport. (Maps and worksheets on file) This project involves grant assistance to eligible microenterprises located in the Towns of Rockland, Avon, Abington, Holbrook, Hull and Wareham. Services to applicants located within a CBRS unit are considered ineligible and financial assistance will not be provided. Rockland, Avon, Abington and Holbrook: There are no CBRS units located within the four participating towns therefore the Act does not apply to services provided within Page 2 of 4 Microenterprise Grant Program Rockland Regional Application HEROS Number TBD those towns. Hull: There is a CBRS unit located within the town. However, there are no town parcels located within the CBRS unit Consequently, no assistance will be provided within a CBRS unit in Hull, MA. Wareham: There are CBRS units within the Town of Wareham. A review of locations will be done at the project level and no assistance will be provided to applicants within a CBRS unit. (Maps and worksheet on file) Flood Insurance Flood Disaster Protection Act of 1973 and National Flood Insurance Reform Act of 1994 [42 USC 4001-4128 and 42 USC 5154a] Yes No This project does not involve the acquisition, construction or rehabilitation of a building, mobile home or insurable personal property and is exempt from flood insurance requirements. (Flood insurance worksheet on file). Mitigation Measures and Conditions [40 CFR 1505.2(c)] Summarize below all mitigation measures adopted by the Responsible Entity to reduce, avoid, or eliminate adverse environmental impacts and to avoid non-compliance or non-conformance with the above-listed authorities and factors. These measures/conditions must be incorporated into project contracts, development agreements, and other relevant documents. The staff responsible for implementing and monitoring mitigation measures should be clearly identified in the mitigation plan. Law, Authority, or Factor Mitigation Measure Please see next page. Preparer Signature: __________________________________________Date: 6-1-2020 Page 3 of 4 Microenterprise Grant Program Rockland Regional Application HEROS Number TBD Name/ ?le/Organization: Wayne Darragh, Grant Consultant, Community Opportunities Group, Ln; Responsible Entity Agency Of?cial Signature: (Qt/1? Date: MOE Name/Title: Douglas Lapp. Town Administrator, as Environmental Certifying Of?cer This original, signed document and related supporting material must be retained on ?le by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (ref: 24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program(s). Page 4 of 4 U.S. Department of Housing and Urban Development 451 Seventh Street, SW Washington, DC 20410 www.hud.gov espanol.hud.gov Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5 Pursuant to 24 CFR Part 58.34(a) and 58.35(b) Project Information Project Name: Rockland Regional Public Social Services Responding to Covid-19; Responsible Entity: Town of Rockland, Massachusetts Grant Recipient (if different than Responsible Entity): Same State/Local Identifier: MA Preparer: Wayne Darragh, Community Opportunities Group, Inc. Certifying Officer Name and Title: Douglas Lapp, Town Administrator Consultant (if applicable): Community Opportunities Group, Inc. Project Location: Eligible public social services located in the participating towns of Rockland, Avon, Abington, Holbrook, Hull and Wareham. Description of the Proposed Project [24 CFR 58.32; 40 CFR 1508.25]: The program will provide grants to public social services providing services to low- and moderate-income residents of the participating communities of Rockland, Abington, Hull, Wareham [Plymouth County, Massachusetts], Holbrook and Avon [Norfolk County, Massachusetts] in response to the negative impacts of the Covid-19 Pandemic. Level of Environmental Review Determination: Activity/Project is Exempt per 24 CFR 58.34(a) (4): “Public services that will not have a physical impact or result in any physical changes, including but not limited to services concerned with employment, crime prevention, child care, health, drug abuse, education, counseling, energy conservation and welfare or recreational needs” Activity/Project is Categorically Excluded Not Subject To §58.5 per 24 CFR 58.35(b): Page 1 of 4 Public Social Service Activities Rockland Regional Application HEROS Number TBD Estimated Total CDBG Funded Amount: $96,000.00 This project anticipates the use of funds or assistance from another Federal agency in addition to CDBG in the form of (if applicable): Not applicable Estimated Total Project Cost (CDBG and non-CDBG funds) [24 CFR 58.32(d)]: $96,000.00 Compliance with 24 CFR §50.4 and §58.6 Laws and Authorities Record below the compliance or conformance determinations for each statute, executive order, or regulation. Provide credible, traceable, and supportive source documentation for each authority. Where applicable, complete the necessary reviews or consultations and obtain or note applicable permits of approvals. Clearly note citations, dates/names/titles of contacts, and page references. Attach additional documentation as appropriate. Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR 50.4 and 58.6 Compliance determinations Are formal compliance steps or mitigation required? STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR §58.6 Airport Runway Clear Zones and Accident Potential Zones Yes No Yes No 24 CFR Part 51 Subpart D Coastal Barrier Resources Coastal Barrier Resources Act, as amended by the Coastal Barrier Improvement Act of 1990 [16 USC 3501] Project involves grants to public social service agencies including but not limited to food pantries providing services to low- and moderate-income families in the six participating communities to address the negative effects of the Covid-19 pandemic. HUD assistance is not being used for new construction, substantial rehabilitation or acquisition of undeveloped land in an airport runway clear zone (24 CFR Part 51.302). No participating community is located within 15,000 feet of a military airport nor 2,500 feet of a civilian airport. (Maps and worksheet file) This project involves grant assistance for Public Social Services located in the towns of Rockland, Avon, Abington, Holbrook, Hull and Wareham. Services to applicants located within a CBRS unit are considered ineligible and financial assistance will not be provided. Rockland, Avon, Abington and Holbrook: There are no CBRS units located within the four participating towns therefore the Act Page 2 of 4 Public Social Service Activities Rockland Regional Application HEROS Number TBD does not apply to services provided within those towns. Hull: There is a CBRS unit located within the town. However, there are no town parcels located within the CBRS unit Consequently, no assistance will be provided within a CBRS unit in Hull, MA. Wareham: There are CBRS units within the Town of Wareham. A review of locations will be done at the project level and no assistance will be provided to applicants within a CBRS unit. (Maps and worksheet on file) Flood Insurance Flood Disaster Protection Act of 1973 and National Flood Insurance Reform Act of 1994 [42 USC 4001-4128 and 42 USC 5154a] Yes No This project does not involve the acquisition, construction or rehabilitation of a building, mobile home or insurable personal property and is exempt from flood insurance requirements. (Flood insurance worksheet on file) Mitigation Measures and Conditions [40 CFR 1505.2(c)] Summarize below all mitigation measures adopted by the Responsible Entity to reduce, avoid, or eliminate adverse environmental impacts and to avoid non-compliance or non-conformance with the above-listed authorities and factors. These measures/conditions must be incorporated into project contracts, development agreements, and other relevant documents. The staff responsible for implementing and monitoring mitigation measures should be clearly identified in the mitigation plan. Law, Authority, or Factor Mitigation Measure Page 3 of 4 Public Social Service Activities Rockland Regional Application HEROS Number TBD Preparer Signature. 75%, Date: 6-1 __2_-020 Name/Title/Organization: Wayne Darragh, Grant Consultant, Community Opportunities Group, Responsible Entity Agency Official Signature: Date: 6-1-2020 Name/Title: Douglas Lapp, Town Administrator, as Environmental Certifying Of?cer This original, signed document and related supporting material must be retained on ?le by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (ref: 24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program(s). Page 4 of 4