FY2019 Data Update for Low- and Moderate-Income (LMI) Area Benefit Designation for HUD’s Indian Community Development Block Grant (ICDBG)

To allow ICDBG applicants maximum flexibility under 24 CFR 1003.208(a)(3), in FY 2019, HUD is adopting a policy that for the purposes of determining low- and moderate-income (LMI) benefit areas, applicants may choose from multiple sources of LMI data:

1. ICDBG applicants may use aggregations of the American Community Survey (ACS) that show three different options for estimating the LMI benefit area at the TRIBAL AREA geography.
   • Estimate of the percent of people that are LMI (this is the type of information that HUD provided to ICDBG applicants in the past)
   • Estimate of the percent of households that are headed by an “AIAN alone” person (or spouse of the head of household) that are LMI
   • Estimate of the percent of households that are headed by an “AIAN alone or in combination with another race” person (or spouse of the head of household) that are LMI
   All tribal area estimates can be downloaded here.
2. ICDBG applicants may also use special tabulations of the ACS that designate LMI qualifying Census tracts with households that are AIAN alone or AIAN in-combination with other races. Eligible tracts can be downloaded here
3. In lieu of using the special AIAN LMI data provided above, ICDBG applicants may use the same criteria, data, and methods from HUD’s Community Development Block Grant (CDBG) program to determine LMI benefit areas at the neighborhood level. For ICDBG applicants choosing this option, HUD’s newest CDBG LMI data, which is also aggregated from the ACS, can be downloaded here.

Either one of these LMI datasets may be used by ICDBG applicants to determine if proposed projects meet the primary objective of the program. These datasets will also be used by Area ONAP staff when measuring LMI need in rating factor 2 of the ICDBG Notice of Funding Availability (NOFA) for public facility and improvement projects as well as economic development projects.

ICDBG applicants who feel that the CDBG LMI tables or the special AIAN tabulations do not accurately measure the LMI needs in their area or that census boundaries do not coincide sufficiently well with their service area, may propose alternative survey data to HUD as further outlined in 24 CFR 1003.208(a)(3) and the NOFA. HUD will accept such data if it determines that the survey was conducted in such a manner that the results meet standards of statistical reliability. ICDBG applicants may submit data that are unpublished, not generally available, and not older than the latest data available from the U.S. Census Bureau. As explained in the NOFA, if applicants choose to submit demographic data other than that available from the U.S. Census Bureau the application must contain a statement that all of the following criteria have been met:

• Generally available published data are substantially inaccurate or incomplete;
• Data that you submit have been collected systematically and are statistically reliable;
• Data are, to the greatest extent feasible, independently verifiable; and
• Data differentiate between reservation and BIA service area populations, when applicable.

The data accompanying the statement must identify the total number of persons benefiting from the project and the total number of low- and moderate-income persons benefiting from the project. To be considered, supporting documentation must include all of the following: a sample copy of a survey form, an explanation of the methods used to collect the data and a listing of incomes by household including household size.