CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need U.S. Department of Housing and Urban Development Ofﬁ ce of Policy Development and Research

CDBG Formula Targeting to Community Development Need

Prepared by:

Todd Richardson Office of Policy Development and Research U.S. Department of Housing and Urban Development Washington, DC

February 2005

Foreword

Last year marked the 30 th Anniversary of the Community Development Block Grant (CDBG) program. The primary objective of the CDBG program is the development of viable urban communities, by providing decent housing, suitable living environments, and expanded economic opportunities, principally for low- and moderate-income persons. To divide the annual appropriation of CDBG funds among jurisdictions, the Congress designed a formula that is intended to provide larger grants to communities with relatively high community development need and smaller grants to communities with relatively low community development need.

The CDBG statute identifies poverty, neighborhood blight, deteriorated housing, physical and economic distress, decline, suitability of one’s living environment, and isolation of income groups, among others, as important components of community development need. The CDBG formula uses variables identified in the 1970s that proxy these dimensions of community development need. The core variables in the formula that allocates the CDBG funds to local jurisdictions have not been changed since 1978.

This report provides the latest assessment of how well the variables being used in the CDBG formula continue to target funds toward community development need. It shows that the formula does generally continue to target to need. Among the entitlement communities, on a per capita basis, the 10 percent of communities with the greatest community development need receive four times as much as the 10 percent of jurisdictions with the lowest level of community development need. However, targeting toward community development need has declined substantially over the past 26 years. Over time, an increasing number of jurisdictions with similar need have come to receive substantially different grants. Furthermore, the amount of funds going to the most needy grantees on a per capita basis has decreased, while the amount of funds going to the least needy grantees on a per capita basis has increased.

This report offers four alternative formulas that would substantially improve targeting to community development need. Each alternative provides trade-offs in terms of the following:

• formula simplicity; • amount of funds reallocated; and • the type of community development need provided highest priority.

It is important to recognize that any change to the existing formula that improves targeting to need will result in a significant redistribution of funds. Nonetheless, the Department hopes that serious attention be given to the alternatives presented in this report. We look forward to working with Congress, CDBG grantees, and other stakeholders to discuss alternatives to the current formula.

Denis C. Shea Assistant Secretary for Policy Development and Research

Acknowledgements

The author thanks Nelson Bregón, Richard Kennedy, Robert Duncan, Sue Miller, and Steve Johnson of the U.S. Department of Housing and Urban Development’s Office of Community Planning and Development (CPD) and Darlene Williams, Jennifer Stoloff, and Mark Shroder of the Office of Policy Development and Research (PD&R) for their comments and suggestions on earlier draft versions of this report. I am most indebted to both Robert Meehan of CPD, who provided invaluable institutional memory, data sets, and the core elements of Chapter 7 of this report, and Kevin Neary of PD&R, who taught me all that I know about formula allocations and provided the core elements of Chapter 8. F. Stevens Redburn and Dustin Brown of the U.S. Office of Management and Budget also provided helpful comments that greatly improved this report. I am extremely grateful to Giles Roblyer, Patricia Dumrose, and Linda Wolfe Keister of HR Communications, Ltd. for their careful editing.

Despite the generous contributions from these individuals, any errors and omissions that remain in the report are, of course, my own.

v Table of Contents

Executive Summary.................................................................................................... vii

Chapter 1. Introduction. .................................................................................................1

Chapter 2. Current Formula Mechanics. .......................................................................5

Chapter 3. Developing a Community Development Needs Index. .............................11

Chapter 4. CDBG Targeting to Need: Entitlement Communities. .............................37

Chapter 5. CDBG Targeting to Need: States (Nonentitlements). ...............................53

Chapter 6. CDBG Alternative Formulas. ....................................................................61

Chapter 7. Impact of New Metropolitan Area Definitions. ........................................85

Chapter 8. The 70/30 Split. .........................................................................................91

Chapter 9. Conclusion. ................................................................................................95

Appendix A. Targeting to Individual Measures of Need

Appendix B. Impact of Alternatives on Individual Grantees

References

vi

CDBG Formula Targeting to Community Development Need vii Executive Summary

Purpose of the Report

This report assesses how well the Community Development Block Grant (CDBG) formula, after introduction of 2000 Census data into the formula, allocates funds toward the community development needs identified in the Housing and Community Development Act of 1974. The U.S. Department of Housing and Urban Development (HUD) indicated in its Fiscal Year (FY) 2004 budget that it would undertake this study.

The National Research Council’s Panel on Statistical Issues in Allocating Funds by Formula (Louis, Jabine, and Gerstein 2003) recommends that policymakers periodically review formula allocation programs to assess whether they perform as intended. The CDBG formula has undergone the following five major assessments since 1974:

1. The first of the reports, prepared at the request of Congress in 1976, pioneered the thinking on how to target funds to community development need (Bunce 1976). The major conclusions of that report led to the current CDBG allocation formula, which first allocated funds in 1978. 2. A follow-up report in 1979 discussed the targeting of the newly created formula (Bunce and Goldberg 1979). 3. & 4. With the introduction of new census data into the formula in 1980 and 1990, HUD performed follow-up studies to determine whether the CDBG formula continued to target well to community development need (Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). Those studies showed that targeting to need has declined as new census data have been introduced into the formula, and significant funding anomalies still exist, but in general, the formula still provides considerably more dollars per capita to needier communities than it does to less needy communities. 5. This report continues in the tradition of those reports, assessing how well the formula allocates toward community development need following the full introduction of 2000 census data into the formula. This report also provides several alternative formulas for improving targeting to community development need.

How the CDBG Formula Works

After setting aside funds for special purposes such as technical assistance, projects specified by Congress, and the Indian CDBG program, the annual appropriation for CDBG formula funding is split so that 70 percent is allocated among eligible metropolitan cities and counties (referred to as entitlement communities), and 30 percent among the states to serve nonentitled communities.

HUD uses two basic formulas, known as Formula A and Formula B, to allocate CDBG funds to entitlement communities. A similar “dual formula” system allocates funds to states. For entitlements, Formula A allocates funds to a community based on its metropolitan shares of: (1) population, weighted at 25 percent; (2) poverty, weighted at 50 percent; and (3) overcrowding, weighted at 25 percent, times appropriations. Formula B allocates funds to a community based

CDBG Formula Targeting to Community Development Need viii on: (1) its share of growth lag 1 , weighted at 20 percent; and its metropolitan shares of (2) poverty, weighted at 30 percent and (3) pre-1940 housing weighted at 50 percent times appropriation.

HUD calculates the amounts for each entitlement jurisdiction under each formula. Jurisdictions are then assigned the larger of the two grants. That is, if a jurisdiction gets more funds under Formula A than Formula B, its grant is based on Formula A. With this dual formula system, the total amount assigned to CDBG grantees has always exceeded the total amount available through appropriation. To bring the total grant amount allocated to entitlement communities within the appropriated amount, HUD uses a pro rata reduction. In FY 2002, for example, the pro rata reduction was 11.43 percent.

Current Formula, 2004 Entitlement Communities States (Nonentitlements) Formula A Formula B Formula A Formula B 25% * population 20% * growth lag 25% * population 20% * population 50% * poverty 30% * poverty 50% * poverty 30% * poverty 25% * overcrowding 50% * pre-1940 housing 25% * overcrowding 50% * pre-1940 housing Metropolitan denominators except for growth lag. Grant is larger of two formulas less a pro rata reduction. State nonentitlement total denominators. Grant is larger of two formulas less a pro rata reduction.

The formula for the nonentitled areas of states generally operates like the entitlement formula. Two key differences exist, however: (1) Formula B uses population instead of growth lag and (2) jurisdiction share is based on the state nonentitlement total rather than the metropolitan or nonmetropolitan total. As with entitlement communities, HUD calculates the amounts for each state under each formula, then assigns the larger of the two grants. To bring the total grant amount to states within the appropriated amount, HUD uses a pro rata reduction. In FY 2002, the pro rata reduction for states was 16.85 percent.

Creating a Needs Index

To assess how well the current formula targets to the community development need of 2000, HUD staff created two needs indexes: one capturing a range of community development needs among entitlement grantees and another capturing the community development needs of nonentitled areas served by states.

In previous CDBG studies, HUD used a methodology to develop standard measures of needs across entitlement cities. This study uses the same basic methods, except it includes urban counties in addition to cities. The report also creates a separate needs index for state nonentitlement areas.

1 Growth lag is the shortfall in population that a city or county has experienced when comparing its current population to the population it would have had if it grew like all metropolitan cities since 1960. For the FY 2002 formula allocation, the growth rate for all entitlement communities between 1960 and 2000 was 37.4 percent. If a city or county grew at a rate greater than 37.4 percent between 1960 and 2000, it receives a growth lag value of zero. Cities receive growth lag funding based on their share of total growth lag for all cities while urban counties receive growth lag funding based on their share of total growth lag for all entitlements (urban counties and cities).

CDBG Formula Targeting to Community Development Need ix Community development need encompasses many different elements—housing quality, infrastructure, economic development, poverty, tax base, and others. To account for these dimensions of need, the needs index serves as our best estimate of the actual level of community development need. For entitlements, the needs index comprises 17 variables identified as indicators of one or more dimensions of community development need. The state needs index comprises 10 variables. Factor analysis condenses these multiple variables into only a few variables. Factor analysis groups variables that appear to relate to one another and creates a factor score for the patterns of variance common among variables. In past studies of the CDBG formula, three distinct patterns of variance have emerged, resulting in three factors: one relating to problems associated with poverty, another relating to problems associated with aging communities, and a third relating to communities in decline (Bunce 1976; Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). These different patterns of need between communities with high poverty and communities with age and decline drove the creation of the dual formula.

The factor analysis for this study likewise creates three factors, but they represent different patterns of variance than the factor analysis in the previous studies. For entitlement communities, a single factor now captures most of the variance associated with the variables of poverty, age of housing, and decline, suggesting that a single formula could now capture those three elements, reducing the justification for the current dual formula. Two new patterns of variance arise in 2000, however, that were not evident in 1970, 1980, or 1990: (1) a factor representing fiscal stress associated with immigrant growth, and (2) a factor reflecting low-density places with high poverty concentrations but declining poverty rates.

To create a single needs score for every jurisdiction, the three factors are weighted and summed. The factor that represents poverty, age of housing, and decline was weighted at 80 percent because it explains most of the variance among the 17 needs variables and represents the dimensions of need most emphasized in the CDBG statute. A 15-percent weight was applied for the factor measuring the fiscal stress associated with immigrant growth, recognizing this new dimension of community development need. Finally, a 5-percent weight was provided for the poverty concentration/declining poverty factor. This factor represents one dimension of need, but it also represents improving communities.

The factor analysis for states also creates three factors: one related to poverty and economic distress, a second related to age of housing, and a third related to a weak proxy for infrastructure. These factors are also weighted and summed to create a single needs score. To create a single needs score for each state, the poverty and economic distress factor is weighted at 70 percent, age of housing is weighted at 25 percent, and infrastructure is weighted at 5 percent. Chapter 3 provides a more thorough justification for the weighting to create the entitlement and nonentitlement composite needs scores.

Current Formula Targeting to Need

When this report discusses targeting to need, it uses per capita grants to compare the relative funding of communities. This approach assumes that population is not a measure of need. This assumption enables us to compare the relative level of grant of New York City (population

CDBG Formula Targeting to Community Development Need x 8,084,316) to East Orange, New Jersey (population 69,750). Though their total grants are dramatically different ($219 million versus $2 million in FY 2004, respectively), their per capita grants are comparable ($27.07 versus $28.66). Targeting operates on the premise that a community with high need should get a larger per capita grant than a community with low need.

Performance of the Entitlement Formula

Prior CDBG studies have shown that the current CDBG formula has, relative to a community development needs index, worsened in its ability to appropriately target funds to entitlement communities (Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). The changing demographic makeup of jurisdictions throughout the 1990s has led the CDBG formula to generally target worse in 2000 than it did in 1990. That said, the current entitlement formula does continue to target to need. On average, the 10 percent of communities with the most need get four times larger per capita grants than the 10 percent of communities with the least need.

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Current Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart ES-1. Current Entitlement Formula. Targeting to the Needs Index

An increasing number of troubling inequities exist, however. Chart ES-1 provides a graphical presentation of this problem, ordering entitlement grantees left to right from least needy to most needy based on the needs index. The solid line represents how many dollars a jurisdiction would get on a per capita basis if the grant funds were allocated using the needs index. The “bouncing” line represents how many dollars jurisdictions get on a per capita basis with the current formula. A number of very low need grantees on the left side of the chart get high per capita grants relative to their need under the current formula. Some very needy grantees on the right side of the chart receive relatively low per capita grants.

CDBG Formula Targeting to Community Development Need xi

On the left side of the chart, relatively low need communities receiving very high per capita grants include Newton, Massachusetts, Royal Oak, Michigan, and Wauwatosa, Wisconsin. These older suburbs benefit from the pre-1940 and growth lag variables of Formula B. These communities are relatively low need, however, enjoying poverty rates of 2 to 3 percent and per capita incomes substantially above the national average. They receive per capita grants of $28 to $33 while communities with similar need scores receive grants in the range of $4 to $7 per capita.

On the right side of the chart, some high need communities get low per capita grants relative to their need score. These communities include Miami, Florida, Paterson, New Jersey, Pharr, Texas, and Compton, California, which suffer poverty rates ranging from 20 to 35 percent and per capita incomes well below the national average. Under the current formula, they receive grants of $23 to $26 per capita while communities with similar need scores receive $40 to $50 per capita.

Problems in the current entitlement formula can be traced to the following three elements:

1. The relative flatness of Formula A. The most needy grantees funded under Formula A do not get substantially more on a per capita basis than the least needy grantees. This flatness is due primarily to the 25 percent weight on population in Formula A.

2. Formula B grantees of similar need often get very different per capita grant allocations. This relative inequity primarily results from the pre-1940 housing variable allocating substantial amounts of funds to some communities that have old housing but otherwise do not have any community development need. The growth lag variable also contributes to the inequity because many slow growing communities, and even some that have lost population, do not suffer economically.

3. On average, Formula A grantees get substantially less than similarly needy Formula B grantees. This inequity results from the share of the need represented by the variables in Formula A being spread across both Formula A and Formula B grantees while the share of the need represented by growth lag and pre-1940 housing in Formula B is largely concentrated among Formula B grantees.

In addition, the poverty variable results in overfunding of “college towns” relative to their per capita need. In some communities a large number of full-time college students live in off-campus housing. When the Census Bureau collects income information from those students, it does not count income support from family, thus counting a large number of students as in poverty. For example, in State College, Pennsylvania, home to Penn State University, 74 percent of college students live in poverty while 12 percent of the remaining population is in poverty. The college student poverty rate inflates State College’s total poverty rate to 47 percent, greater than the very distressed communities of Benton Harbor, Michigan (43 percent poverty rate) and Hidalgo County, Texas (42 percent poverty rate).

CDBG Formula Targeting to Community Development Need xii The growth lag variable also creates some inequities among high-need communities. Chart ES-1 shows a number of relatively high-need communities on the right side of the chart with per capita grants nearly double what their community development needs index score suggests is fair relative to the need of other jurisdictions. The relative overfunding largely results from the growth lag variable, which moves more than 18 percent of the total appropriation for CDBG entitlements to the relatively few communities with growth lag, particularly to the even fewer communities with very high levels of population loss. For example, Saint Louis, Missouri has a per capita grant of $73, $41 from growth lag alone. Detroit, Michigan, a more needy Formula B city as measured by the community development needs index, receives $49 per capita, $29 from growth lag. Both cities are distressed and have community development needs related to decline, but the analysis of community development need suggests that Detroit’s grant at $49 per capita is consistent with its level of community development need and Saint Louis’s grant of $73 per capita is significantly higher than is appropriate for its relative level of need.

Performance of the State Formula

The state formula also tends to target poorly to need. Chart ES-2 shows that with the exception of one grantee (Puerto Rico), the appropriate per capita grants (the solid line) are approximately $5 for the least needy grantees and approximately $15 to $20 for the most needy. The current per capita grants for all of the grantees except Puerto Rico show almost no relationship to the community development needs index line. While little relationship exists between the needs index and the current per capita grants, the magnitude of the anomalous targeting is not as large as it is in the entitlement formula.

$0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Per Capita Grant Current Per Capita Grant Need (Slope 8.0) Low Need High Need

Chart ES-2. Current Nonentitlement Formula. Targeting to the Needs Index

CDBG Formula Targeting to Community Development Need xiii Two primary reasons drive the poor targeting of the nonentitlement formula:

1. The relative flatness of both Formula A and Formula B. The most needy grantees do not get substantially more on a per capita basis than the least needy grantees. This flatness results primarily from the 25 percent weight on population in Formula A and the 20- percent weight on population in Formula B.

2. The unfairness of Formula A, due to overcrowding, and Formula B, due to pre-1940 housing. Our analysis shows overcrowding and poverty to be closely correlated in nonentitlement areas. Overcrowding, however, is concentrated in a few states, thus the formula essentially gives those states added dollars for their poverty population. The pre- 1940 housing variable simply rewards states with old housing without determining if they are needy.

Unlike the entitlement formula, a large inequity in funding between Formula A and Formula B does not appear to exist. With the exception of Puerto Rico, to which Formula A does target well, both formulas are relatively weak in their targeting to need.

Four Alternative Formulas

A number of items must be considered when creating an alternative to the current formula. Clearly any change to the current formula will be motivated by a desire to improve targeting to need. Specifically, we seek to (1) improve equity, so similarly needy grantees get similar grant amounts, and (2) improve the relative targeting of the formula so the most needy grantees get substantially higher per capita grants than the least needy grantees.

We also seek a simple formula that causes the least disruption to the current CDBG funding levels. A simple formula can be easily explained so grantees and policymakers understand the mechanics that determine the grant amounts. Regarding the disruption of funds, any change to the current formula will cause some grantees to gain funding while others lose.

We offer four alternative formulas with different degrees of improving targeting to need, different levels of simplicity, and different patterns of redistributing funds.

Alternative 1

Entitlement Alternative 1 tweaks the existing formula by fixing the problems in Formula A and B that lead to large inequities in funding among grantees within each individual formula by taking the following actions:

• Formula A o Reduce the weight on population from 25 percent to 10 percent and increase the weight on poverty to 60 percent and the weight on overcrowding to 30 percent. This action increases the grants for the more needy Formula A grantees that are currently significantly underfunded relative to the needs index.

CDBG Formula Targeting to Community Development Need xiv o Change the definition of poverty to “persons living in family households or elderly headed households living in poverty” to correct for the relative overfunding of college towns relative to their community development need.

• Formula B o Replace the pre-1940 variable with “housing 50 years or older occupied by a poverty household” to better target to needy communities with older infrastructure and dilapidated housing. o Change the definition of poverty to “persons living in family households or elderly headed households living in poverty” to correct for the relative overfunding of college towns relative to their community development need. o Lower the weight on growth lag to 10% and increase the weight on poverty to 40%. Also adjust growth lag to reduce funding for communities with relatively high per capita incomes and low poverty rates. These changes reduce some of the overfunding relative to community development need caused by growth lag.

Generally, these changes improve the targeting within each formula but do not correct for the funding inequities between Formula A and Formula B. Alternative 1 causes the least redistribution of funds but makes the formula even more complicated. This option is similar to the alternative presented in 1995 by Neary and Richardson.

Alternative 1 Entitlement Communities States (Nonentitlements) Formula A Formula B Formula A Formula B 10% * population 10% * adjusted growth lag 10% * population 10% * population 60% * family & elderly poverty 40% * family & elderly poverty 65% * family & elderly poverty 40% * family & elderly poverty 30% * overcrowding 50% * housing 50 years or older occupied by a poverty household 25% * overcrowding 50% * housing 50 years or older occupied by a poverty household Metropolitan denominators except for growth lag. Grant is larger of two formulas less a pro rata reduction. State nonentitlement total denominators. Grant is larger of two formulas less a pro rata reduction.

Chart ES-3 shows that entitlement alternative 1 does improve targeting relative to the current formula (Chart ES-1), most notably decreasing grants for low need grantees that are currently relatively overfunded. For example, it reduces the grants for Newton, Royal Oak, and Wauwatosa from around $30 per capita to approximately $5 per capita, an allocation more consistent with the grants of communities with similar need. It also reduces the high growth lag grants somewhat, but not enough to bring them in line with the needs index. The Saint Louis per capita grant, for example, is reduced from $73 to $63 per capita. It also provides small increases to some high-need underfunded communities. For example, Miami, Paterson, Pharr, and Compton, with current grants of $23 to $26 per capita, have their grants increase to $30 to $34 per capita, a bit closer to the $40 to $50 per capita of similarly needy grantees.

CDBG Formula Targeting to Community Development Need xv $0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Alternative 1 Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart ES-3. Alternative 1. Targeting to Need

Nonentitlement Alternative 1 likewise tweaks the existing formula by fixing the problems in Formulas A and B that lead to large inequities in funding among grantees within each individual formula. This alternative undertakes the following changes:

• Formula A o Reduce the weight on population from 25 percent to 10 percent and increase the weight on poverty to 65 percent. This change increases the funding for the more needy Formula A grantees while decreasing funding for the less needy as measured by the needs index. o Change the definition of poverty to “persons living in family households or elderly headed households living in poverty” to correct for the relative overfunding of states with significant college student populations in the nonentitlement areas.

• Formula B o Replace the pre-1940 variable with “housing 50 years or older occupied by a poverty household” to better target to states with older infrastructure and dilapidated housing. o Change the definition of poverty to “persons living in family households or elderly headed households living in poverty” to correct for the relative overfunding of states with large college student populations in the nonentitlement areas. o Reduce the weight on population from 20 percent to 10 percent and increase the weight on poverty to 40 percent. As with Formula A, this change increases the funding for the more needy Formula B grantees while decreasing funding for the less needy as measured by the needs index.

CDBG Formula Targeting to Community Development Need xvi Chart ES-4 shows that these changes move the per capita allocations much closer to the needs line than the current formula.

$0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Per Capita Grant Alternative 1 Per Capita Grant Need (Slope 8.0) Low Need High Need

Chart ES-4. Nonentitlement Alternative 1. Targeting to Need

Alternative 2

Entitlement Alternative 2 was designed to be a very simple single formula that closely matches the allocation suggested by the needs index. The formula uses four easy-to-understand variables to allocate the funds: poverty, female-headed households with children under 18, housing older than 50 years occupied by a household in poverty, and overcrowding. These variables bear a high correlation to the individual needs factors and relatively low correlation with one another. A regression model seeking to best target to the needs index forms the basis for the weighting of the variables. Unlike the other alternatives proposed, this formula has no adjustments or pro rata reductions. This option dramatically improves the fairness of the formula (Chart ES-5), in part by eliminating funding inequities between Formula A and B.

Alternative 2 Entitlement Communities—70% States (Nonentitlements)—30% 50% * family & elderly poverty 60% * family & elderly poverty 10% * female-headed household with children under 18 10% * female-headed household with children under 18 20% * overcrowding 30% * housing 50 years or older occupied by a poverty household 20% * housing 50 years or older occupied by a poverty household

Entitlement total denominators. State nonentitlement total denominators.

CDBG Formula Targeting to Community Development Need xvii The formula, however, only modestly increases funding to the more needy jurisdictions. By improving fairness in the funding allocation without increasing the average funding level to the relatively more needy grantees, some very needy Formula B communities experience significant funding decreases. For example, Detroit’s grant is reduced from $49 per capita to $38 per capita to put it in line with similarly needy Miami, whose grant increases from $28 per capita to $41 per capita. High-need grantees that are relatively overfunded by the formula as compared to the needs index suffer even larger decreases. Saint Louis experiences a funding decrease of 50 percent under this alternative, bringing its grant to $37 per capita. Buffalo, New York, has a funding decrease of 39 percent, bringing its grant to $41 per capita, and Cleveland, Ohio has a decrease of 36 percent, bringing its grant to $39 per capita.

By correcting for the inequities of the current formula, funding levels increase for high-need communities currently receiving small per capita grants relative to their need. Paterson has its grant increase from $23 to $32 per capita, Pharr increases from $26 to $36 per capita, and Compton increases from $26 to $38 per capita.

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Alternative 2 Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart ES-5. Entitlement Alternative 2. Targeting to Need

Nonentitlement Alternative 2 was designed to be simple and closely match the recommended funding pattern of the nonentitlement needs index. The formula uses three widely available and easily understandable variables to allocate the funds: poverty, female-headed households with children, and housing older than 50 years occupied by a person in poverty. This formula does not use overcrowding as a factor due to its high correlation with poverty in the nonentitled areas. Unlike in the entitlement formula, overcrowding does not capture a dimension of community development need not already captured by poverty. This alternative dramatically improves the targeting to need as shown by Chart ES-6.

CDBG Formula Targeting to Community Development Need xviii

$0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Per Capita Grant Alternative 2 Per Capita Grant Need (Slope 8.0) Low Need High Need

Chart ES-6. Nonentitlement Alternative 2. Targeting to Need

Alternative 3

Entitlement Alternative 3 builds from entitlement alternative 2 but moderates the sharp drop in funding for the very needy Formula B communities and generally shifts funding from low-need communities to high-need communities. The formula uses the same variables as entitlement alternative 2 but places more weight on older housing occupied by a poverty household and less on overcrowding than alternative 2. Compared to the original needs index justifying the current formula, the needs index in this study does not contain as many variables capturing community decline. To account for this deficiency, the shift in weight for alternative 3 is intended to put more emphasis on places with the problems of age and decline versus places with growing immigrant populations. The nonentitlement formula is the same as in alternative 2.

Alternative 3 Entitlement Communities—70% States (Nonentitlements)—30% 50% * family & elderly poverty 60% * family & elderly poverty 10% * female-headed household with children under 18 10% * female-headed household with children under 18 10% * overcrowding 30% * housing 50 years or older occupied by a poverty household 30% * housing 50 years or older occupied by a poverty household

Entitlement total denominators. Adjusted by the ratio of metropolitan area per capita income divided by local per capita income with an adjustment cap of +/- 25 percent. Pro rata reduction of adjusted grant to match grant allocation to appropriations. State nonentitlement total denominators.

CDBG Formula Targeting to Community Development Need xix

In addition, to account for fiscal disparities within metropolitan areas, this alternative adjusts grants up for jurisdictions with a low per capita income relative to their metropolitan per capita income and adjusts grants down for jurisdictions that have a high per capita income relative to their metropolitan per capita income. This adjustment results in an average increase in grants greater than the number of decreases. The application of a pro rata reduction ensures the total grant amount does not exceed appropriations.

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Alternative 3 Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart ES-7. Entitlement Alternative 3. Targeting to Need

Chart ES-7 shows that alternative 3 targets well to need, but differently than alternative 2. Alternative 3 has a higher slope than alternative 2, allocating more funds per capita to the higher need grantees and less funds per capita to the lower need grantees. Alternative 3, however, has more variation in grant amounts among grantees with similar need than alternative 2.

Associated with its higher slope, alternative 3 increases the funding for the more needy grantees at the expense of the less needy grantees and also benefits some of the older declining cities. Instead of declining, as it does under alternative 2, Detroit’s grant increases under alternative 3 to $51 per capita. Miami’s grant increases a lesser amount to $44 per capita. This separation in per capita grant amounts between the similarly needy Miami and Detroit represents the greater differentiation in grant amounts for similarly needy jurisdictions under alternative 3 versus alternative 2. These fluctuations largely result from the higher weight given to decline in alternative 3. Nonetheless, relatively overfunded high-need jurisdictions with substantial decline, like Saint Louis, Buffalo, and Cleveland, still suffer decreases in funding relative to their current grants (32 percent, 14 percent, and 12 percent, respectively), but not as significant as under alternative 2.

CDBG Formula Targeting to Community Development Need xx

Low-need jurisdictions largely have significant reductions under alternative 3. For example, the relatively low-need jurisdiction of Newport Beach, California, has its per capita grant fall to $3 per capita (its current grant is $6 per capita and its alternative 2 grant is $4 per capita).

Alternative 4

Alternative 4 is a single formula allocating all funds to both entitlements and states without a 70/30 split. Currently, entitlement grantees are allocated 70 percent of the funds and states are allocated 30 percent of the funds. Since FY 1982 when the 70/30 split was first put into effect, the number of entitlement grantees has grown from 732 to 1,105 in FY 2004. While the split between entitlements and nonentitlements has remained static, the relative share of the U.S. population served by the 70 percent share of entitlement funds has grown while the relative share of the population served by the nonentitlement side of the formula has decreased. The nonentitlement share of the population, however, is still greater than 30 percent, having fallen from 45 percent in FY 1982 to 36 percent in FY 2002.

Alternative 4 Entitlement Communities and State (Nonentitlements)—100% 50% * family & elderly poverty 10% * female-headed household with children under 18 10% * overcrowding 30% * housing 50 years or older occupied by a poverty household Adjusted by the ratio of metropolitan area per capita income divided by local per capita income (states not adjusted) with an adjustment cap of +/- 25 percent. Pro rata reduction of adjusted grant to match grant allocation to appropriations.

This 70/30 split could be maintained in its current state, the split could be changed using some different approaches, or the split could be eliminated altogether with a single formula. If a single formula were used, and that formula used the factors and weighting of entitlement alternative 3, 2

the de facto split would be 69 percent to entitlements and 31 percent to nonentitlements in FY 2004. As shown on Chart ES-8, that targeting would be almost exactly the same as shown in Chart ES-7 for alternative 3.

2 By including states in the formula, unlike nonentitlement alternative 3, states do get some funding due to overcrowding (10 percent). Consequently, a moderate shift of funds occurs from high poverty states with no overcrowding to high poverty states with overcrowding.

CDBG Formula Targeting to Community Development Need xxi

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement and Nonentitlement Grantees Per Capita Grant Alternative 4 Per Capita Grant Combined Needs Index Per Capita Grant Low Need High Need

Chart ES-8. Alternative 4. Targeting to Need

Impact

All of the alternatives we discuss in this report result in a significant redistribution of funds. Table ES-1 shows the impact on entitlements and Table ES-2 shows the impact on nonentitlements. Alternative 1, which simply tweaks the formula, results in fewer very large losses and gains than alternatives 2 and 3. For entitlements, alternative 4 causes the largest redistribution of funds. Alternatives 1, 3, and 4 for entitlements largely redistribute funds from the least needy to the most needy. Alternative 2, by fixing the anomaly in funding between Formula A and Formula B grantees, also leads to funding reductions for some very needy grantees, a problem that alternative 3 seeks to fix. Alternative 4 has the same impact as alternative 3, except slightly more losers than winners for entitlements occur because the pot of funds for entitlements is effectively reduced to 69 percent from its current 70 percent. For states, however, slightly more winners occur under alternative 4 than alternatives 2 and 3 because the pot of funds effectively has increased to 31 percent from 30 percent.

CDBG Formula Targeting to Community Development Need xxii

Table ES-1 Percent of Entitlement Grantees Gaining/Losing Funds by Formula Alternative

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Loss greater than 40% 5% 12% 15% 15% Loss 20 to 40% 16% 15% 18% 19% Loss 10 to 20% 15% 9% 11% 10% Loss 0 to 10% 20% 12% 11% 12% Gain 0 to 10% 18% 12% 12% 11% Gain 10 to 20% 13% 11% 10% 11% Gain 20 to 40% 11% 17% 14% 13% Gain greater than 40% 1% 12% 11% 9% Total 100% 100% 100% 100% N=1,105 (As compared to FY 2004 allocation)

Table ES-2 Percent of Nonentitlement Grantees Gaining/Losing Funds by Nonentitlement Formula Alternatives

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Loss greater than 40% 0% 4% 4% 0% Loss 20 to 40% 14% 18% 18% 18% Loss 10 to 20% 20% 22% 22% 20% Loss 0 to 10% 16% 16% 16% 18% Gain 0 to 10% 26% 6% 6% 6% Gain 10 to 20% 20% 12% 12% 16% Gain 20 to 40% 6% 20% 20% 20% Gain greater than 40% 0% 4% 4% 4% Total 100% 100% 100% 100% N=51 (using FY 2004 geography)

Table ES-3 shows the total redistribution of funds by region caused by the different alternatives. As expected, alternative 1 has the smallest redistribution of funds. Even so, the New England region suffers a very large loss of funding of 22 percent, primarily resulting from the replacement of the variable of pre-1940 housing with pre-1950 housing occupied by a household in poverty in Formula B. Alternative 2 causes the largest regional redistribution of funding because of its correction for the A and B formula anomalies without substantially raising the slope of the allocation. Alternatives 3 and 4 have regional redistributions similar to alternative 1, but less than alternative 2 because of the increase in slope and an increased weight on communities in decline.

CDBG Formula Targeting to Community Development Need xxiii

Table ES-3 Total Regional Shifts for Both Entitlements and States for Each Alternative

Region Alternative 1 Alternative 2 Alternative 3 Alternative 4 New England -22% -31% -21% -21% New York/New Jersey -2% -5% 3% 2% Mid-Atlantic -7% -18% -11% -12% Southeast 8% 20% 16% 16% Midwest -11% -19% -11% -11% Southwest 13% 21% 15% 16% Great Plains -9% -12% -8% -8% Rocky Mountain -5% -2% -4% -3% Pacific/Hawaii 9% 14% 0% 1% Northwest/Alaska -6% -3% -7% -5% Puerto Rico 33% 35% 23% 24% N=1,156

Recommendation

Serious consideration should be given to changing the CDBG allocation formula so that it better targets to community development need. Any of the alternatives proposed in this report would accomplish this goal. HUD looks forward to working with Congress, CDBG grantees, and other stakeholders to discuss these alternatives.

CDBG Formula Targeting to Community Development Need xxiv

CDBG Formula Targeting to Community Development Need 1 Chapter 1. Introduction

Purpose of the Report

The purpose of this report is to assess how well the Community Development Block Grant (CDBG) formula, after introduction of Census 2000 data into the formula, allocates funds toward the community development needs identified in the Housing and Community Development Act of 1974. HUD indicated in its Fiscal Year (FY) 2004 budget that it would be undertaking this study.

The National Research Council’s Panel on Statistical Issues in Allocating Funds by Formula (Louis, Jabine, and Gerstein 2003) recommends that policymakers periodically review formula allocation programs to assess whether they are performing as intended. For the CDBG formula, the following four major assessments of the formula have preceded this one:

1. The first report, prepared at the request of Congress in 1976, pioneered the thinking on how to target funds to “community development need” (Bunce 1976). The current CDBG allocation formula, which first allocated funds in 1978, is built around the major conclusions of that report.

2. A follow-up report in 1979 addressed the targeting of the newly created formula (Bunce and Goldberg 1979).

3 & 4. As new census data were introduced into the formula in 1980 and 1990, HUD did follow-up studies to determine whether the CDBG formula continued to target well to community development need (Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). Those studies show that while targeting to need has declined as new census data have been introduced into the formula, and that there are significant funding anomalies, in general, the formula still provides considerably more dollars per capita to needier communities than it does to less needy communities.

In FY 2003, 2000 Census data were fully introduced into the CDBG allocation formula. Continuing HUD’s tradition of reexamining the formula when new decennial census data are available, this report evaluates how the introduction of 2000 Census data affects the formula’s targeting to community development need. An already published report, “Redistribution Effect of Introducing Census 2000 Data Into the CDBG Formula” (Richardson, Meehan, and Kelly 2003), provides basic information about which formula variables are responsible for shifts in funding. This report does not repeat that analysis; rather, it focuses on targeting to community development need. In addition to the needs analysis, this report does the following:

• Describes the impact of introducing the Office of Management and Budget’s (OMB’s) new definitions for metropolitan areas.

• Explains the 70/30 funding split between entitlement and nonentitlement CDBG grantees.

CDBG Formula Targeting to Community Development Need 2 • Provides four alternative formulas 3 that would improve targeting to need.

Report Overview

This report is structured into nine chapters.

Chapter 1. Introduction. This chapter explains the purpose of the report.

Chapter 2. Current Formula Mechanics. This chapter explains how the current dual formula works and provides direct examples.

Chapter 3. Developing a Community Development Needs Index. This chapter describes the selection of variables for inclusion in a community development needs index, the statistical techniques used to isolate different patterns of community development need, and the process used to create a single score for each community to proxy its level of community development need relative to the national average.

Chapter 4. CDBG Targeting to Need—Entitlement Communities. This chapter shows how, after the introduction of 2000 Census data, the CDBG entitlement formula targets to the community development needs index. It also describes which components of the existing formula are responsible for its increasingly poor targeting to need.

Chapter 5. CDBG Targeting to Need—States (Nonentitlements). This chapter shows how the CDBG nonentitlement formula targets to the community development needs index. It also describes the components of the formula that contribute to its generally poor targeting.

Chapter 6. CDBG Alternative Formulas. This chapter shows three possible alternatives for improving the targeting to need of the CDBG entitlement formula and two possible alternatives for improving the targeting to need of the nonentitlement formula.

Chapter 7. Impact of New Metropolitan Area Definitions. OMB’s new metropolitan area definitions could potentially result in the addition of 78 entitlement cities and 12 urban counties. The new definitions also change the metropolitan denominator for the entitlement program for each of the formula variables. This chapter describes the potential implication of adding all of the eligible communities as well as the reality of how many jurisdictions actually decided to participate in FY 2004.

Chapter 8. The 70/30 Split. Since 1981, nonentitled portions of states have received 30 percent of the CDBG formula allocation while entitlement areas have received 70 percent. Since that time, numerous new communities and urban counties have been added to the entitlement share of the formula from the nonentitlement share. This chapter offers some options ranging from

3 The report provides three alternatives for the entitlement formula, two alternatives for the nonentitlement formula, and one single formula alternative. For simplicity in the Executive Summary and concluding chapter, the entitlement and nonentitlement formulas are linked to create individual alternatives resulting in a total of four complete alternatives.

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need 3 continuing the current split, to annually adjusting the split, to creating a single formula that funds both entitlements and nonentitlements.

Chapter 9. Conclusion. This chapter summarizes the report findings and recommends that serious consideration be given to changing the formula.

CDBG Formula Targeting to Community Development Need 4

CDBG Formula Targeting to Community Development Need 5 Chapter 2. Current Formula Mechanics

The Community Development Block Grant (CDBG) program provides annual “entitlement” allocations to eligible cities and counties and nonentitlement allocations to states for areas that do not qualify or choose not to participate as entitlements. As specified in sections 102 and 106 of the Housing and Community Development Act of 1974, the program allocates funds based on demographic data provided by the U.S. Census Bureau.

After setting aside funds for special purposes, such as technical assistance, congressionally specified projects, and 1 percent for the Indian CDBG program, the annual appropriation for CDBG formula funding is split so that 70 percent is allocated among entitlement cities and counties and 30 percent among the states. The communities and states must submit annual plans that show how they expect to use these funds and other Community Planning and Development formula funds and report on their prior year accomplishments. Program regulations govern the eligible use of the funds (24 CFR Part 570).

For the most part, CDBG funding levels allocated by formula have remained constant in recent years at some amount between $4.2 and $4.4 billion. In Fiscal Year (FY) 2002, the total appropriation level for the CDBG formula was $4.341 billion, $3.039 billion allocated to entitlement communities and $1.302 billion for nonentitlement communities. 4

Entitlement Communities and States

To qualify as an entitlement community, cities and counties must meet criteria established in section 102 of the Housing and Community Development Act. The statute makes the following areas eligible for the entitlement program.

Metropolitan Cities

• Central cities of metropolitan areas (MAs). 5

• Other cities with a current population of 50,000 or more that are also in MAs. • Cities that retain metropolitan city status as a result of previously meeting the criteria for metropolitan cities.

4 For comparison to the previously published “Redistribution Effect of Introducing Census 2000 Data Into the CDBG Formula,” the discussion in chapters 2 through 6 uses the FY 2002 appropriation level and universe of grantees. Chapters 7 and 8, Executive Summary tables, and Appendix B reflect the FY 2004 universe of CDBG grantees. 5 The Office of Management and Budget defines metropolitan areas and designates central cities. This office establishes the criteria and updates the MA list when decennial census data are issued and as the Census Bureau updates population estimates throughout the decade. Beginning in FY 2004, due to revisions to the OMB definitions of MAs, “principal city” is used instead of “central city” as a means of determining eligibility for the entitlement program.

CDBG Formula Targeting to Community Development Need 6

Urban Counties

• Counties that are in MAs and have a population of 200,000 or more after excluding metropolitan cities and eligible Indian tribes. • Counties that retain qualification status as a result of previously meeting criteria for urban counties.

The nonentitled portion of a state receives funding based on the balance of need characteristics that remain after subtracting data for metropolitan cities and urban counties that choose to participate in the entitlement program. Data for Native Americans living in federally recognized Indian tribal areas are also subtracted because they are eligible for funding under separate grant programs.

Qualification process. The Department of Housing and Urban Development (HUD) designates metropolitan cities based on population estimates available from the Census Bureau and central cities designated by the Office of Management and Budget (OMB). HUD uses the data that are available for all units of government 90 days before the start of the federal fiscal year.

HUD also identifies urban counties annually when the data show that a county could potentially have a population of more than 200,000 or meet other legislative tests. The county includes unincorporated areas along with local units of government where the county has authority or a legal agreement with local governments to undertake community development activities. Urban counties go through a process of establishing legal agreements for participation with local governments when they are first qualified and every 3 years thereafter.

States are automatically funded under the CDBG program 6 . They are funded based on the nonentitled portion in the state; that is, the balance of the state after excluding metropolitan cities, urban counties with their included units of government and all Native Americans living in eligible tribal areas. Only units of general local government (small cities, small towns, and rural counties) in the nonentitled area may apply to the state for funding. The Housing and Community Development Act defines the District of Columbia as a metropolitan city. It includes Puerto Rico as a state. Other territories, outlying areas, and Native Americans living in tribal areas are excluded from the formula and funded under set-asides from the annual appropriation.

The number of metropolitan cities and urban counties participating as entitlement communities in CDBG has increased steadily since the creation of the program in 1974. Since 1981, when Congress established that entitlements would receive 70 percent of the funds and nonentitlements 30 percent (the 70/30 split), the number of entitlement grantees has ballooned from 666 to 1,105 in FY 2004, a 66 percent increase. Generally, when new metropolitan cities are added to the formula, individually they have a small impact because they have small populations, usually around 50,000. Because the population threshold for urban county participation—200,000—is

6 Since 1981, when Congress gave states the ability to assume responsibility for administering the CDBG program, there has been a gradual transition from HUD administration of the nonentitled funds for individual states to state administration of the CDBG nonentitlement program. Only Hawaii’s nonentitled grant continues to be administered by HUD.

CDBG Formula Targeting to Community Development Need 7 higher than that of cities, however, their entry into the program has a larger impact on the entitlement allocation. Since 1981, roughly a quarter of all new entitlement communities have been urban counties. Chapter 8 explains the implications of the increasing number of entitlement communities and the fixed split of 70 percent to entitlements and 30 percent to states.

CDBG Formulas

The CDBG “formula” consists of two basic formulas, known as Formulas A and B, to allocate CDBG funds. In practice, five formulas are used in this annual process, all variations on Formulas A and B. Three formulas allocate 70 percent of funds to entitlement communities, and two formulas allocate funds to the states (for nonentitlement communities). This system of five formulas has been in place since FY 1981 (Neary and Richardson 1995).

Formula A for entitlement communities is as follows:

(0.25 Pop (a) + 0.5 Pov (a) + 0.25 Ocrowd (a)) x $3.039 billion Pop (MA) Pov (MA) Ocrowd (MA)

Formula B for cities is as follows:

(0.2 GLag (a) + 0.3 Pov (a) + 0.5 Age (a) ) x $3.039 billion GLag (MC) Pov (MA) Age (MA)

Formula B for urban counties is as follows:

(0.2 GLag (a) + 0.3 Pov (a) + 0.5 Age (a) ) x $3.039 billion GLag (ENT) Pov (MA) Age (MA)

where: • (a) is the value for the jurisdiction. • (MA) is the value for all MAs. • (MC) is the value for all entitlement cities. • (ENT) is the value for all entitlement jurisdictions (cities and urban counties).

• $3.039 billion is the amount available for allocation to entitlement jurisdictions in FY 2002.

• Pop is the total resident population. • Pov is the number of persons below the poverty level. • Ocrowd is the number of overcrowded housing units. A housing unit is overcrowded when more than 1.01 persons per room are living in the unit. • Age is the number of housing units built before 1940. • Glag is population growth lag. Growth lag is the shortfall in population that a city or county has experienced when comparing its current population to the population it would have had if it grew like all metropolitan cities since 1960. For the FY 2002 formula allocation, the growth rate for all entitlement communities between 1960 and 2000 was

CDBG Formula Targeting to Community Development Need 8 37.4 percent. If a city or county grew at a rate greater than or equal to 37.4 percent between 1960 and 2000, it receives a growth lag value of zero. 7

HUD calculates the amounts for each entitlement jurisdiction under both Formulas A and B. Jurisdictions are then assigned the larger of the two grant amounts. That is, if a jurisdiction gets more funds under Formula A than Formula B, its grant is based on Formula A. With this dual formula system, it is not surprising that the total amount assigned to CDBG grantees has always exceeded the total amount available through appropriation. To bring the total grant amount allocated to entitlement communities within the appropriated amount, HUD uses a pro rata reduction. In FY 2002, for example, the pro rata reduction was 11.43 percent. That is, the amount assigned to a community under the dual formula is multiplied by 0.8857 (1 – 0.1143) to generate the actual grant amount. 8

The formula for the nonentitled areas of states generally operates like the entitlement formula. Two key differences, however, are present: (1) Formula B uses population instead of growth lag, and (2) the denominator for all of the variables is the sum of the nonentitled total (NEnt) instead of the sum of non-MAs. The formulas for the nonentitlement allocation are as follows:

Formula A is as follows:

(0.25 Pop (a) + 0.5 Pov (a) + 0.25 Ocrowd (a) ) x $1.302 billion Pop (NEnt) Pov (NEnt) Ocrowd (NEnt)

Formula B is as follows:

(0.2 Pop (a) + 0.3 Pov (a) + 0.5 Age (a) ) x $1.302 billion Pop (NEnt) Pov (NEnt) Age (NEnt)

As with entitlement communities, HUD calculates the amounts for each state under each formula. States are then assigned the grant that is the larger of the two. To bring the total grant amount to states within the appropriated amount, HUD uses a pro rata reduction. In FY 2002, for example, the pro rata reduction for states was 16.85 percent.

Sources of Data for the Formulas

To ensure objectivity and consistency, the decennial census is the primary source of the data in the CDBG formula. In years following the release of the decennial data, the Census Bureau provides updated population estimates, identifies new incorporations, and reports major

7 HUD does not have a 1960 population figure for some communities. Those communities are not included when calculating the 1960 to 2000 growth rate. In addition, while the latest population used to compute growth lag reflects recent boundary changes, HUD cannot make changes to the 1960 population for individual communities based on boundary changes that result from annexations because the 1960 data are not available. HUD does make changes to the 1960 population data for communities that result from mergers, since the data are available. 8 There could conceivably be a pro rata increase, since the sum of the values in each numerator (entitlement jurisdictions) is less than the denominator (all MAs, portions of which are not entitled). In the more than 20 years of the CDBG dual formula, there has never been a need for a pro rata increase.

CDBG Formula Targeting to Community Development Need 9 boundary changes (usually due to annexation). As required by statute, HUD uses the latest data consistently available for all areas as of 90 days before the start of the fiscal year. Since HUD allocates funds to Indian tribes separately, HUD excludes data for Native Americans living in tribal areas from the formula data for all states and entitlement communities.

Formula Allocation Example

Below is an example of how the formulas work. The estimated CDBG grant for this city 9 would be based on 350,000 persons; 50,000 persons in poverty; 7,500 overcrowded housing units; 65,000 housing units that were built before 1940; and a growth lag of 40,000 persons between 1960 and 2000. It would receive the larger of the amounts generated by the two formulas.

Formula A:

Population Poverty Overcrowding (0.25 350,000 + 0.5 50,000 + 0.25 7,500 ) x $3.039 billion 229,192,836 27,561,898 5,551,631

= $4,942,675

Formula B:

Growth Lag Poverty Age of Housing (0.2 40,000 + 0.3 50,000 + 0.5 65,000 ) x $3.039 billion 25,564,131 27,561,898 12,974,750

= $10,216,211

This grantee gets substantially more money using Formula B than with Formula A. As a result, its grant would be the total of the larger, Formula B, multiplied by a pro rata reduction of 12.37 percent, making the total grant after pro rata reduction $8,952,466.

It is useful to know that FY 2002 used Census 2000 data for population and growth lag, but still used Census 1990 data for the poverty, overcrowding, and pre-1940 housing. The FY 2003 allocation used Census 2000 data for all the variables, and the FY 2004 allocation uses the Census 2002 population estimates for the population and growth lag variables and the new OMB metropolitan area definitions for determining the denominator on most of the variables. Appropriation amounts allocated by formula have remained fairly similar over the 3 years: $4.341 billion in FY 2002, $4.340 billion in FY 2003, and $4.331 billion in FY 2004. Richardson, Meehan, and Kelly (2003) showed the impact on redistributing funds as a result of Census 2000 data being fully introduced into the formula in FY 2003.

9 This calculation is based on the FY 2002 universe of grantees and appropriation amount. All the data used are from Census 2000.

CDBG Formula Targeting to Community Development Need 10

CDBG Formula Targeting to Community Development Need 11 Chapter 3. Developing a Community Development Needs Index

The report “Redistribution Effect of Introducing Census 2000 Data into the CDBG Formula” (Richardson, Meehan, and Kelly 2003) showed how funds are redistributed among communities when the Census 2000 data are introduced. This chapter describes the establishment of the measurement tool—a needs index—used to assess whether the redistribution of funds resulting from the new Census 2000 data improves or aggravates the formula’s ability to target toward community development need.

In previous Community Development Block Grant (CDBG) studies, the Department of Housing and Urban Development (HUD) used a methodology that created standard measures of “community development need” across entitlement cities (Bunce 1976; Bunce and Goldberg 1979; Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). This study used the same basic methods. Advancing the work of previous studies, however, this study develops a needs index that includes urban counties in addition to cities. It develops a separate needs index for the nonentitlement balance of states.

Community development need encompasses many different things—housing quality, infrastructure, economic development, poverty, tax base, and others. To account for these many dimensions of need, this study assembled data on 17 community-need-related variables for each entitlement jurisdiction. 10 Factor analysis is used to group variables that correlate highly with one another. For variables that correlate highly with each other, factor analysis creates a factor score to represent the common variance among these variables. To the extent there are different patterns of variance, factor analysis creates multiple factor scores. The factor score for each jurisdiction represents the number of standard deviations it is from the mean. For example, if poverty and overcrowding have a high level of correlation, a place with a poverty rate near the national mean and an overcrowding rate near the national mean would have a factor score of zero. A place with a rate of poverty and overcrowding one standard deviation less than the national average would receive a factor score of –1.0; a place with a rate one standard deviation greater than the national average would receive a factor score of 1.0.

CDBG Formula History

The formula originally established for allocating CDBG funds in the 1974 authorizing legislation (Housing and Community Development Act of 1974) was relatively simple and easy to understand. It had only three variables—population weighted at 25 percent, poverty weighted at 50 percent, and overcrowding weighted at 25 percent. The formula gave the largest weight to poverty, which reflects the emphasis on communities with low-income persons that CDBG was intended to serve. HUD conducted an analysis after enactment of the law that used the same approach used in this report. A community development needs index was created, and the new formula’s allocation was compared against the needs index. The report from this analysis, published in 1976, showed that the formula in the original 1974 legislation targeted very well to communities with large poverty populations but did not target well to older and declining

10 Data are available on all 17 variables for only 899 of the 1,024 Fiscal Year 2002 entitlement jurisdictions. Analyses that use the needs index refer to these 899 jurisdictions only.

CDBG Formula Targeting to Community Development Need 12 communities (Bunce 1976). It also showed that poverty and decline were not closely related, suggesting the need for a dual formula system.

As a result of HUD’s 1976 analysis, and the realization that many of the older and declining communities had been large recipients of the categorical grants CDBG was intended to replace, Congress enacted legislation in 1977 (Housing and Community Development Act of 1977) that created a dual formula that would target funds to both places with large poverty populations and older and declining communities. The dual formula has been in use since the Fiscal Year (FY) 1978 appropriation.

Identifying the Variables

Four studies have preceded this one in developing a community development needs indicator: Bunce 1976; Bunce and Goldberg 1979; Bunce, et al. 1983; and Neary and Richardson 1995. As with these four studies, this study started the process of identifying the variables for the community development needs index by looking at the Congressional intent of the CDBG program.

The Housing and Community Development Act of 1974, as amended, established as the primary objective of the CDBG program “the development of viable urban communities, by providing decent housing and suitable living environment and expanding economic opportunities, principally for persons of low and moderate income.” The statute goes on to specify that at least 70 percent of the funds should be used to benefit persons of low and moderate income. The statute directs that the funds be directed at the following specific objectives:

1. The elimination of slums and blight and the prevention of blighting influences and the deterioration of property and neighborhood and community facilities of importance to the welfare of the community, principally persons of low and moderate income.

2. The elimination of conditions which are detrimental to health, safety, and public welfare through code enforcement, demolition, interim rehabilitation assistance, and related activities.

3. The conservation and expansion of the Nation’s housing stock in order to provide a decent home and a suitable living environment for all persons, but principally for those of low and moderate income.

4. The expansion and improvement of the quantity and quality of community services, principally for persons of low and moderate income, which are essential for sound community development and for the development of viable urban communities.

5. A more rational utilization of land and other natural resources and the better arrangement of residential, commercial, industrial, recreational, and other needed activity centers.

6. The reduction of the isolation of income groups within communities and geographical areas and the promotion of an increase in the diversity and vitality of neighborhoods

CDBG Formula Targeting to Community Development Need 13 through the spatial deconcentration of housing opportunities for persons of lower income and the revitalization of deteriorating or deteriorated neighborhoods.

7. The restoration and preservation of properties of special value for historic, architectural, or esthetic reasons.

8. The alleviation of physical and economic distress through the stimulation of private investment and community revitalization in areas with population out-migration or a stagnating or declining tax base.

9. The conservation of the Nation’s scarce energy resources, improvement of energy efficiency, and the provision of alternative and renewable energy sources of supply. (Housing and Community Development Act of 1974)

Community Development need clearly encompasses many different elements, and the CDBG statute is specifically designed to give jurisdictions a great deal of flexibility to address the community development needs specific to their community. Any community development needs indicator must encompass a wide variety of measures reflecting different types of community development need.

Variables Used To Construct the Community Development Needs Indicator

This study identified the variables to be used in the needs index for the entitlement communities based on the CDBG objectives noted above. Table 3-1 shows the variables used in previous studies, as well as those used for this study. Many of the variables selected for this study have been used in one form or another in all of the studies. Data availability and continuing research on the changing dynamics of community need have led to variable modifications and the addition or subtraction of variables over time.

Table 3-1. Community Development Needs Variables, 1976–2003

Variable Description Bunce (1976) Bunce and Goldberg (1979) Bunce, Neal, and Gardner(1983) Neary and Richardson (1995) Richardson (This Report) Income variables Percent of poor persons (census) X X X Percent of persons under the age of 18 in poverty (census) X X Percent of persons living in poor families or poor households headed by a elderly person (census) X X Percent of households that are female- headed with children in poverty X Change in percentage of poor persons over 10 years (census) X X X Real per capita income (census) X X

CDBG Formula Targeting to Community Development Need 14 Variable Description Bunce (1976) Bunce and Goldberg (1979) Bunce, Neal, and Gardner(1983) Neary and Richardson (1995) Richardson (This Report) Ratio of per capita income to metropolitan per capita income (census) X Net change in real per capita income over 20 years (census) X (10 years) X X (10 years) Percent of poverty persons in 40 percent or higher poverty census tracts (census) X Social and demographic variables Percent of families with a female head and children under 18 (census) X X X X Percent of population older than 65 (census) X X Percent of households minority (census) X X X X Percent of population black (census) X Change in percent of population black over 10 years (census) X X Percent of population of Spanish origin (census) X Percent of population age 25–65 without a high school education (census) X X X X Minority dissimilarity index (segregation)multiplied by percent minority X Economic Variables Percent of population age 16–64 that is employed (census) X X X Percent of persons age 16 or older in the labor force that are unemployed (census) X (Bureau of Labor Statistics [BLS]) X X (BLS) X X Percent change in the volume of retail sales over 5 years (economic census) X (9 years) X (10 years) X Percent change in retail sales establishments over 9 years (economic census) X Percent change in retail, wholesale, and service employment over 10 years (economic census) X (5 years) X

Percent change in manufacturing employment over 10 years (economic census) X Net change in unemployment rate over 10 years (census) X New housing permits in past 2 years X Housing variables Percent of occupied housing units that are pre-1940 and occupied by poverty household (census) X X (pre-1950) Percent of occupied housing units that are pre-1960 occupied by a poverty renter (census) X X (pre-1970)

CDBG Formula Targeting to Community Development Need 15 Variable Description Bunce (1976) Bunce and Goldberg (1979) Bunce, Neal, and Gardner(1983) Neary and Richardson (1995) Richardson (This Report) Percent of housing units pre-1940 (census) X X X Percent of rental units pre-1940 (census) X Percent of housing units owner-occupied (census) X X (renter) Percent of owner units pre-1940 (census) X Percent of occupied housing that is rental with one of four housing problems (census) 11 X X Percent of housing units lacking complete plumbing (census) X X Percent of housing units overcrowded X X X X Population trends Percent change in population since 1960 (census) X X X X (loss only) Percent change in population over 10 years (census) X (5 years) X X X (loss only) Percent change in households over 10 years X Other indicators Number of murders, assaults with weapons, incidents of nonnegligent manslaughter, and robberies per 1,000 persons (UCR) X X X X X Change in violent crime over 4 years X Number of persons per square mile (census) X X X X

The variables selected for creating a community development needs index are best explained in the context of the CDBG objectives. For simplicity, in this report, the CDBG objectives are summarized in four categories; each variable is explained in the specific CDBG category. Each variable’s description is supported by an historic rationale and any relevant recent research supporting the variable’s use. Not all the variables identified are available for all 1,024 CDBG entitlement jurisdictions; needs scores are created for 899 jurisdictions only. 12

1. Low and Moderate Income Persons. The overall objective of CDBG is to serve “persons of low and moderate income.” Thus, indicators that target low- and moderate-income persons are essential. The specific objectives provide a special emphasis on targeting communities with high neighborhood concentrations of low- and moderate-income persons. The

11 Overcrowding, without complete kitchen, without complete plumbing, and/or with housing cost burden greater than 30 percent. 12 There is some bias in the jurisdictions that are excluded due to missing data. Specifically, 38 grantees in Illinois are excluded because the crime data for most Illinois communities, except Chicago, are missing; all 21 Puerto Rico jurisdictions are excluded for lack of crime data; and a disproportionate number of urban counties, 32 of the 159 urban counties, are excluded due to incomplete crime data. Crime rate is an excellent measure of community distress not captured by any of the other factors used in this analysis, which justifies its inclusion even though its use reduces the number of grantees used in this analysis from 1,024 to 899.

CDBG Formula Targeting to Community Development Need 16 objectives also indicate that CDBG funds should be used to fund community services for low- and moderate-income persons; this report identifies subgroups of persons that are particularly high consumers of community services.

Income Variables

a. Persons in poverty living in families or elderly households. The first CDBG formula study identified the importance of poverty as a measure of community development need because poor persons have a high reliance on city government for basic necessities. In addition, poverty is associated with “substandard housing, urban blight, neighborhood instability, and housing abandonment” (Bunce 1976). This study uses persons in poverty living in families or elderly households instead of simply persons in poverty because the persons in poverty variable from the census includes off-campus college students, who often receive support from their families that is not recorded by the census. The persons in poverty variable, therefore, tends to distort the level of need in areas where large colleges or universities are located. By focusing on just persons in poverty that live in families (two or more related persons) or elderly households, this anomaly is largely resolved (Neary and Richardson 1995). 13

b. Percentage point change in poverty rate between 1990 and 2000. Jurisdictions with growing numbers of persons in poverty have special community development needs associated with their capacity to address a growing impoverished population. Research has demonstrated, for example, that every 1 percent increase in a city’s poverty rate reflects a 5.5 percent increase in per capita expenditure on police services. Similar effects exist for fire protection costs (Ladd and Yinger 1989). The change in poverty rate among CDBG entitlements between 1990 and 2000 ranges from a drop of 18 percentage points (Toa Alta Municipio, PR) to an increase of 8 percentage points (North Miami, FL).

c. Jurisdiction per capita income relative to metropolitan per capita income. This is a new variable for this study. Rather than use per capita income alone, this measure takes into account the metropolitan context of that per capita income. It extends research conducted by David Rusk (1993) showing that “the city-suburb per capita income ratio is the single most important indicator of an urban area’s social health.” Conceptually, it takes into account the relationship between the cost of providing services, which is driven by metropolitan area incomes (the employment/services market), and the tax base to pay

13 Because this variable excludes single, nonelderly persons in poverty (the proxy for college students in this analysis), there is a sense that it may misrepresent the needs of communities with particularly high portions of their population made up of noncollege students who are single, nonelderly, and in poverty. To test this, HUD requested a special tabulation of census data that specifically excluded full-time college students from the poverty count. Comparing the noncollege student poverty rate to the poverty rate for persons living in families and elderly households in poverty across the CDBG universe finds a correlation of 0.989. A few noncollege town communities have a 10 percent reduction in the share of the national poverty total when the elderly and families in poverty are used instead of special Census tabulation data on noncollege students in poverty. Those communities include Bangor, Maine; Clearfield, Utah; Myrtle Beach, South Carolina; Portland, Maine; Asheville, North Carolina; Lewiston, Maine; Portland, Oregon; Miami Beach, Florida; Glens Falls, New York; Charleston, West Virginia; Wheeling, West Virginia; Superior, Wisconsin; Sarasota, Florida; Clearwater, Florida; Palm Springs, California; and Atlantic City, New Jersey.

CDBG Formula Targeting to Community Development Need 17 for those services, which is driven by local incomes. The lower this ratio, the more difficult it is for a community to provide a level of service that can compete with the level of service provided in other communities in the Metropolitan Statistical Area (MSA). This measure is at the heart of Rusk’s concept of inelastic and elastic cities, where elastic cities can annex their growing suburbs and inelastic cities are landlocked. Inelastic cities experience declining tax bases and increased need for services.

d. Net change in per capita income from 1989 to 1999. This variable measures the economic growth of a community. Rising per capita income reflects a growing economy and a stronger tax base. Declining per capita income growth suggests a struggling economy and a waning tax base relative to rising costs for a jurisdiction.

e. Concentrated poverty. This is a new variable for this study. The exact variable is the percent of persons in poverty living in neighborhoods with more than 40 percent poverty. 14 This measure uses Jargowsky’s (1996) definition of a ghetto neighborhood as 40 percent poverty or more.

The sixth objective of the CDBG statute calls for the “reduction of the isolation of income groups within communities.” A number of recent studies have documented the extent of poverty concentrations in the United States (Jargowsky 1996; Rusk 1999) and the consequences of ghetto poverty (Wilson 1987; Blank 1997; Brooks-Gunn, Duncan, and Aber 1997). Recent research on the impact of moving poor families from high- poverty to lower poverty neighborhoods demonstrates significant effects for women and girls in terms of increased safety, reduced incidence of psychological disorders, and less obesity. However, there appears to be a negative impact on boy’s behavior. (Orr, et al 2003). Generally, the social cost of poor people living in high-poverty neighborhoods appears to be higher than the cost of just having poor people, in terms of public safety and health care costs.

High Consumers of Community Services 15

a. Female-headed households with children. This is a group seen to have day care needs. In addition, communities with large segments of single parent households are often correlated with neighborhood instability and substandard housing (Bunce 1976). This is also a good supplement to the poverty measure because it captures a high number of households that are just above the poverty threshold. According to Census 2000 data, 49 percent of female-headed households with children in the US have incomes less than $20,000 compared to just 8 percent of married families with children. Very few female-

14 To address the issue of college towns, this variable uses persons in poverty living in families and elderly households rather than all persons in poverty. 15 In all previous studies, the percentage of persons over age 65 was used as a factor. This study initially included elderly persons based on the premise that they often have special needs for transportation, housing, recreation, and health care (Bunce 1976). This study determined, however, that elderly persons did not correlate well with any other factors. Further exploration suggests that a large elderly population can mean higher service costs but it also is very indicative of communities with a significant population of well-off retirees. Because the meaning of this variable has changed, it is not included in this analysis.

CDBG Formula Targeting to Community Development Need 18 headed households with children have higher incomes, only 4 percent nationwide have incomes greater than $60,000.

b. Persons with lower education levels. Lack of high school education is correlated with high crime rates, unemployment, and social problems. Individuals without a high school education also often live in declining neighborhoods. Not having a high school education increases the likelihood a person is dependent on public support (Bunce 1976).

2. Decent Housing. This study interprets the statute’s focus on “decent housing principally for persons of low and moderate income” to encourage targeting of CDBG funds to areas with large amounts of substandard housing, as well as places with a lack of decent affordable housing. Variable selection also takes into account the historic preservation and energy conservation objectives.

a. Occupied housing units that are pre-1950 and occupied by a poverty household and occupied housing units that are pre-1970 and occupied by a poverty renter. Earlier studies found that housing built before 1940 was an indicator of substandard housing and a good proxy for “government repair and maintenance costs of older sanitation facilities and sewage lines.” Older housing was also associated with housing abandonment. (Bunce 1976). As needier jurisdictions have demolished their pre-1940 housing stock over time and less needy jurisdictions have renovated their pre-1940 housing stock, pre-1940 housing has steadily lost this targeting ability (Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). Age of housing remains a good proxy for an older infrastructure, the costs of maintaining that infrastructure, and a need for historic preservation. Ladd and Yinger (1991) found that cities with older housing had higher operating costs than cities with newer housing. It is highly desirable to capture the concept of age without overly rewarding communities that have aged gracefully.

Census 2000 does not have a perfect proxy for inadequate housing. Historically, pre-1940 housing has been used; its targeting ability has declined over time, however, as dilapidated older units were demolished in declining communities and renovated in improving communities. Neary and Richardson (1995) modified the older housing variable to include occupancy by a poor person to improve the targeting of the age of housing variable toward inadequate housing. Table 3-2 shows results from analysis of 2001 American Housing Survey data on the relationship between inadequate housing and older housing. Nationally, 6.3 percent of the nation’s housing stock is inadequate. 16 Older housing is indeed more likely to be substandard, with housing built before 1940 nearly twice as likely (11.1 percent) to be substandard than on average nationally. Poor people are also more likely to live in inadequate housing (12.1 percent). Combining poverty with old housing substantially improves targeting toward inadequate housing. Approximately 18 percent of pre-1950 housing units occupied by a person in poverty have housing quality problems. Tenure is also a good measure of housing inadequacy. Renters are more likely to live in inadequate housing, particularly renters in older housing (16.5 percent for renters of pre-1950 housing).

16 Using the definition of “Physical problems - moderate and severe” in the American Housing Survey for the United States: 2001 (U.S. Census Bureau 2002).

CDBG Formula Targeting to Community Development Need 19 Table 3-2. Age of Housing, Income, and Tenure as Indicators of Housing and Neighborhood Distress

National Total Poverty Pre-1940 Housing Pre-1950 Poverty Pre-1950 Renter Pre-1970 Poverty Renter Housing need indicators Percent of units inadequate 6.3 12.1 11.1 17.9 16.5 18.7 Percent of units severely inadequate 2.0 4.0 3.7 5.9 5.4 6.4 Percent rating house quality 6 or less on 10 point scale (1 is low, 10 is high) 14.2 21.3 21.0 26.7 30.4 30.6 Neighborhood need indicators Percent living near abandoned buildings 4.8 8.2 10.2 12.9 12.0 13.8 Percent living near roads in need of repair 35.2 40.4 41.5 44.6 46.5 45.6 Percent rating neighborhood quality 6 or less on 10 point scale (1 is low, 10 is high) 17.2 23.8 23.9 29.9 30.7 33.2 Percent deeming crime to be so bothersome that resident wishes to move 3.7 6.4 5.2 8.9 9.3 11.8 Source: Analysis of 2001 American Housing Survey Data

To capture communities with somewhat newer housing stock (pre-1970) but with housing inadequacy problems, the pre-1970 poverty renter variable has targeting advantages similar to pre-1950 poverty.

b. Percent of housing units with more than 1.01 persons per room. Bunce’s 1976 report identified overcrowding as an important indicator of (1) disposal and sanitation problems, (2) a high demand for recreational facilities, (3) density of the population, and (4) excess demand for housing. In 1995, the CDBG needs indicator included renter units with one of four housing problems as an indicator of need. This factor included overcrowding, renter cost burden of 30 percent or more, and units without complete kitchen and/or plumbing. This study returned to using overcrowding alone. 17 Overcrowding has increased between 1990 and 2000 and is closely associated with growing immigrant population, which puts a unique strain on local government resources. Studies commissioned by the National Academy of Sciences of the states of California and New Jersey found that immigrants, particularly the low-skilled immigrants with larger families that reflect overcrowding, contribute less to local and state revenues than they consume (Smith and Edmonston 1997).

3. Suitable Living Environment. The variables in this category address the CDBG objectives of eliminating slums and blight, neighborhood revitalization, and land use planning.

17 Analysis of the cost burden variable shows that it is generally a good indicator of high housing costs. For CDBG targeting purposes, however, it has the side effect of especially targeting college towns. College towns often have high housing costs because they are desirable places to live, with few community development need, and apparently large numbers of persons with low incomes resulting in cost burden. The low incomes are deceptive, however, because many college students have low earned incomes but are supported by their parents.

CDBG Formula Targeting to Community Development Need 20 a. Number of murders, assaults with weapons, incidents of nonnegligent manslaughter, and robberies per 1,000 persons in 2001. 18 Communities with higher crime rates are confronted not only by the need for greater police enforcement but also the social cost associated with higher crime, including substantial health costs (Orr, et al. 2003). Crime also is a “push” factor that provides a strong incentive for people with a choice, generally the people contributing most to a jurisdiction’s tax base, to leave the community (Skogan 1990).

b. Number of persons per square mile in 2000. Research by Ladd and Yinger (1989) demonstrated that higher general service costs are associated with both high- and low- density communities. According to Ladd and Yinger, “Cities with low densities face high transportation and coordination costs, whereas cities with high densities face severe congestion.”

c. Level of minority segregation in metropolitan area multiplied by the percent of the minority population. For this variable, this study uses a metropolitan level dissimilarity index. This index measures the proportion of the population in the metropolitan area that would need to move for the minority population to be evenly represented in all census tracts. 19 Zero represents complete integration and 1 is complete segregation. The index is then multiplied by the percent minority in a particular jurisdiction. In previous studies, percent minority has been used as a separate indicator because urban blight and abandonment were found to be concentrated in minority neighborhoods. Areas with high minority concentrations were associated with overcrowded housing, a higher infant mortality rate, greater welfare dependency, substandard housing, and high rates of unemployment (Bunce 1976). Minorities are also more likely to have extended stays in poverty (Blank 1997). More recent research indicates that these problems are much more concentrated in metropolitan areas with high degrees of segregation (Rusk 1999).

Furthermore, racial segregation has been found to have a high correlation with fiscal inequality and urban sprawl, defined as decreases in population density in the urbanized area (Orfield 2002). 20 This could be driven partly by the substantial wealth gap between minorities and whites (Oliver and Shapiro 1995). From this evidence, this study concludes that jurisdictions with the highest percent minority population in a racially segregated metropolitan area are likely to have relatively high levels of distress in terms of fiscal revenue capacity and loss of population density in favor of urban sprawl.

18 All data are from Department of Justice Uniform Crime Reports (UCR). If city data are available from 2001 UCR, that is used; otherwise, 1999 UCR data are used. For urban counties, 2000 UCR data is used less the entitlement city UCR counts above. If no data are available for one or more entitlement city in a county but are available for that county, data are not used for either. If the UCR population count for a county is greater than 1.20 or less than 0.5 of the actual population count for an urban county, UCR data are not used for that county. For the 123 urban counties for which data was available, 103 have ratios between 0.90 and 1.10. 19 Minority is defined as all persons except non-Hispanic whites. 20 Orfield found the correlation between tax base inequality in the 25 largest metropolitan areas correlates with the dissimilarity index for racial segregation at 0.57. He also determined the correlation between decline in urbanized land area density and the dissimilarity index for racial segregation to be –0.52.

CDBG Formula Targeting to Community Development Need 21 4. Economic Opportunities. The statute clearly states that CDBG should be targeted at communities with population out-migration or a stagnating or declining tax base.

Population Trends

a. Population loss between 1960 and 2000. The Census of 1960 marked the population height for many older, industrial central cities. The growth of interstate highway systems and housing finance systems that favored suburban development over central city housing, along with the decline in the number of manufacturing jobs located in central cities, contributed a great deal to this population loss (Oliver and Shapiro 1995). Cities with significant population loss are often confronted by the costs associated with managing abandoned housing, an aging infrastructure that is larger than needed or that it can support, and usually an older and larger poverty population than cities that are growing. As a result, these cities have higher than average numbers of municipal employees per 10,000 residents and tend to levy a higher combined state and local tax burden (Moore and Stansel 1993). Even those jurisdictions that stabilized their population between 1990 and 2000 still retain the higher costs noted above 21 .

b. Population loss between 1990 and 2000. Some jurisdictions that continued to grow in population between 1960 and 1990 have begun to experience population loss. These “newer” declining cities and urban counties, many of them inner-ring suburbs, are beginning to experience population decline and some of the stresses noted in the previous section for the older cities with population loss.

Economic Variables

a. Percent of population age 16 to 64 that was employed in 2000. The smaller the segment of working age population that is employed, the greater social distress for a community. This is a measure of the extent that the primary generators of income for a community are idle, unemployed, or dependent on services. High rates of idleness are often related to higher crime and dependence on community services without contributing to the tax base.

b. Percent of persons age 16 years or older in the labor force that was unemployed in 2000. This is a direct measure of economic distress for a community. High numbers of unemployed persons who are looking for work is reflective of a troubled regional economy or a mismatch between the skills of the persons and the jobs available in the region.

In prior years, changes in retail sales over 5 years, in manufacturing employment over 10 years, and service employment over 10 years have been included in the needs index. These data have come from the U.S. Census Bureau’s Economic Census, which is conducted every 5 years. The most recent data available are from 1997. Unfortunately for this study, which

21 One caveat on the population loss estimates relates to falling household size. Some communities with population loss, generally well-off suburbs that were almost fully built out in 1960, lost population in the form of falling household size but actually are relatively well off.

CDBG Formula Targeting to Community Development Need 22 depends on changes between two time periods, the Census Bureau began using North American Industry Classification System (NAICS) codes in 1997 for defining types of industry in place of the Standard Industrial Classification (SIC) codes that were used for previous economic census. For many types of jobs, there is no direct one-to-one link between SIC code jobs and NAICS codes. For time series analysis, it is very important to have data defined the same for both time periods. Because the economic census data are not defined the same for both time periods, they could not be used in this study. The consequence for this analysis is to have relatively few measures of economic growth and decline as part of the needs index.

Factor Analysis

After identifying the variables that indicate community development need, for this study, those data were translated into a single “needs indicator” using a statistical technique called “factor analysis.” Factor analysis identifies underlying factors that capture the variance among multiple variables. In this way, a single variable can be created that represents the common variance of multiple variables. Generally, with a large number of variables, factor analysis will create more than one factor to represent the different patterns of variance among the variables (Kim and Mueller 1978).

Over the past three decades, there has been remarkable consistency in terms of the number and type of factors created using this technique. Those factors have generally been (1) problems associated with poverty, (2) density, and (3) age/decline (Bunce and Goldberg 1979; Bunce, Neal, and Gardner 1983; Neary and Richardson 1995). The first CDBG study that used this technique to create a measure of community development need (Bunce 1976) identified these three factors as well as factors for (4) crime and unemployment and (5) lack of economic opportunity.

This study determined that over the past decade, the factors that previously had different patterns of variance—problems associated with poverty, unemployment, older infrastructure, and decline—have largely converged into a single factor that accounts for 46 percent of the variance among the 17 variables identified above. Two new needs variables, however, have emerged: one that appears to be closely associated with high rates of immigration growth, and another that is closely associated with a trend, documented by Jargowsky (2003), where many places with concentrated poverty had substantial poverty rate declines during the 1990s.

For purposes of the formula alternatives described in Chapter 6, it is useful to note that the factor analysis from the previous studies indicated that a dual formula system—one that targets toward poverty and another toward age and decline—was appropriate. In the 1970s, 1980s, and 1990s, poverty was clearly a dimension of need that did not relate well to age and decline. The analysis from this study, however, indicates that this finding is no longer true. For the entitlement communities, places with high rates of older housing and population loss are now accounted for in the same factor that picks up poverty (factor 1). If policy makers choose, those dimensions of community development need can now be captured through a single formula.

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need 23 Factor 1. Poverty/Age/Economic Distress/Decline

Factor 1 is an excellent factor for showing community development need. It reflects 46 percent of the variance among the variables used in the factor analysis. Furthermore, 11 of the 17 needs variables used in this analysis correlate with factor 1 at 60 percent or higher (shown in bold in Table 3-3) while 5 of the remaining 6 variables have correlations of greater than 40 percent (shown in italics in Table 3-3). Only the change in the poverty rate between 1990 and 2000 has a weak correlation with this factor. That is, communities that score high on this factor, score high regardless of their poverty rate change between 1990 and 2000. Table 3-3 shows the correlation between factor 1 and each of the community need variables used in this study.

Table 3-3. Correlation of Individual Need Variables to Underlying Factor 1

Correlation 22

Percent of persons in poor families or poor elderly households, 2000 0.913 Point change in poverty rate, 1990–2000 0.018 Per capita income/per capita income of MSA, 2000 (negative equates with good targeting to need) –0.668 Net per capita income change, 1989–1999 (negative equates with good targeting to need) –0.676 Percent of poor persons in census tracts with greater than 40 percent poverty, 2000 0.489 Percent of families with female head with children under age 18, 2000 0.740 Percent of population age 25–64 without high school education, 2000 0.781 Percent of occupied housing units built pre-1950, occupied by a poverty household, 2000 0.734 Percent of occupied housing units built pre-1970, occupied by a poverty renter household, 2000 0.855 Percent of housing units overcrowded, 2000 0.479 Number of homicides, assaults, and robberies per 1000 persons, 1999/2000/2001 0.711 Persons per square mile, 2000 0.430 MSA dissimilarity index multiplied by percent minority 0.715 Percent population loss, 1960– 2000 0.516 Percent population loss, 1990–2000 0.429 Percent of population age 16–64 employed, 2000 (negative equates with good targeting to need) –0.835 Percent of persons age 16 or older in labor force and unemployed, 2000 0.864 N=899

Table 3-4 shows a select group of communities that have high need and low need on factor 1. 23

This table shows that factor 1, which is strongly correlated with poverty, the old housing variables, and unemployment, targets strongly to older cities such as Detroit and Baltimore while it targets away from large urban counties such as Fairfax County, Virginia, and Oakland County, Michigan.

22 Correlations at or above 0.600 are in bold while correlations from 0.400 to 0.600 are italicized. 23 The select communities are cities with population greater than 250,000 and urban counties with population greater than 500,000. Tables 3-4, 3-6, 3-8, and 3-9 show the 10 most needy and 10 least needy of these communities on each factor.

CDBG Formula Targeting to Community Development Need 24 Communities that have a high value on factor 1 are generally recognized to have considerable community development need.

Table 3-4. Examples of High- and Low-Need Communities on Factor 1

Higher Need Score Lower Need Score Newark, NJ 3.22 Orange County, CA –0.97 Detroit, MI 2.98 Contra Costa County, CA –1.00 Buffalo, NY 2.59 Montgomery County, MD –1.02 St. Louis, MO 2.54 Cobb County, GA –1.03 Cleveland, OH 2.53 King County, WA –1.05 Baltimore, MD 2.37 Montgomery County, PA –1.22 Miami, FL 2.29 Fairfax County, VA –1.25 Philadelphia, PA 2.09 Oakland County, MI –1.31 New Orleans, LA 2.00 Hennepin County, MN –1.41 Factor 1: Poverty/age of infrastructure/ economic distress/ inadequate tax base/crime New York, NY 1.81 Westchester County, NY –1.42

Factor 2. Low-Skilled Immigrants/Overcrowding

As noted earlier, factor 2 is a new dimension of community distress that has surfaced as a result of the rapid growth in the immigrant population in the 1980s and 1990s, particularly low-skilled immigrants with larger families. The communities reflected in factor 2 are growing, often in very high cost areas of the country. The immigrant population it targets generally is not in

Table 3-5. Correlation of Individual Need Variables to Underlying Factor 2

Correlation Percent of persons in poor families or headed by elderly poor person, 2000 0.049 Point change in poverty rate, 1990–2000 0.315 Per capita income/per capita income of MSA, 2000 –0.142 Net per capita income change, 1989–1999 –0.238 Percent of poor persons in census tracts with greater than 40 percent poverty, 2000 –0.058 Percent of families with female head with children under age 18, 2000 –0.454 Percent of population age 25–64 without high school education, 2000 0.464 Percent of occupied housing units built pre-1950, occupied by a poverty household, 2000 –0.491 Percent of occupied housing units built pre-1970, occupied by a poverty renter household, 2000 –0.305 Percent of housing units overcrowded, 2000 0.780 Number of homicides, assaults, and robberies per 1000 persons, 1999/2000/2001 –0.110 Persons per square mile, 2000 0.326 MSA dissimilarity index multiplied by percent minority 0.401 Percent population loss, 1960–2000 –0.643 Percent population loss, 1990–2000 –0.616 Percent of population age 16–64 employed, 2000 –0.206 Percent of persons 16 or older in labor force and unemployed, 2000 0.022

CDBG Formula Targeting to Community Development Need 25

poverty, but does tend to contain low-wage workers with limited education. As Table 3-5 shows, this factor is most strongly correlated with overcrowding. This factor accounts for 16 percent of the variance among the variables used in this analysis.

Not surprisingly, communities with the least need on this factor are communities that have limited economic opportunity and are losing population, another dimension of community development need that is largely captured in factor 1. Table 3-6 shows, for example, that the very distressed cities on factor 1, such as Buffalo, New York, and St. Louis, Missouri have very low need on factor 2. This leads to an important policy tradeoff question for the CDBG formula: to what extent should CDBG funds be targeted to communities experiencing fiscal stress due to immigration growth? Doing so comes at the expense of communities experiencing fiscal stress due to poverty, age, and decline, as measured by factor 1.

Table 3-6. Examples of High- and Low-Need Communities on Factor 2

Higher Need Score Lower Need Score Santa Ana, CA 4.07 Toledo, OH –1.17 Anaheim, CA 2.25 New Orleans, LA –1.35 Los Angeles, CA 1.70 Baltimore, MD –1.78 Long Beach, CA 1.55 Louisville, KY –1.93 Miami, FL 1.46 Detroit, MI –1.94 Los Angeles County, CA 1.37 Cleveland, OH –2.26 New York, NY 1.25 Cincinnati, OH –2.58 San Jose, CA 1.20 Pittsburgh, PA –2.70 Riverside, CA 1.17 St Louis, MO –2.88 Factor 2: Overcrowding/ population growth Houston, TX 1.10 Buffalo, NY –2.98

Factor 3. Concentrated Poverty, Low Density With Declining Poverty Rates

Factor 3 is difficult to interpret as a measure of community development need. As Table 3-7 shows, it correlates most strongly with places that have concentrated poverty and low-density population, and declining poverty rates. It captures an interesting trend of the 1990s: the overall decline of concentrated poverty (Jargowsky 2003). Clearly, locations with concentrated poverty are distressed, but to what extent should CDBG funds be targeted to these places if they are experiencing a general decline in poverty?

CDBG Formula Targeting to Community Development Need 26

Table 3-7. Correlation of Individual Need Variables to Underlying Factor 3

Correlation Percent of persons in poor families or headed by elderly poor person, 2000 0.284 Point change in poverty rate, 1990–2000 –0.644 Per capita income/per capita income of MSA, 2000 0.223 Net per capita income change, 1989–1999 0.108 Percent of poor persons in census tracts with greater than 40 percent poverty, 2000 0.602 Percent of families with female heads with children under age 18, 2000 0.032 Percent of population age 25–64 without high school education, 2000 0.077 Percent of occupied housing units built pre-1950, occupied by a poverty household, 2000 –0.250 Percent of occupied housing units built pre-1970, occupied by a poverty renter household, 2000 –0.173 Percent of housing units overcrowded, 2000 –0.026 Number of homicides, assaults, and robberies per 1000 persons, 1999/2000/2001 0.170 Persons per square mile, 2000 –0.557 MSA dissimilarity index multiplied by percent minority 0.004 Percent population loss, 1960–2000 –0.242 Percent population loss, 1990–2000 –0.178 Percent of population age 16–64 employed, 2000 –0.172 Percent of persons age 16 and older in labor force and unemployed, 2000 0.130

Table 3-8 shows the conflict associated with this measure of need. Needy communities that have shown some improvement in the 1990s, such as Atlanta, Fresno, and El Paso, rank very high on this measure, but distressed places with increasing poverty rate and high density, like Buffalo and New York, New York, rank very low on this factor.

Table 3-8. Examples of High- and Low-Need Communities on Factor 3

Higher Need Score Lower Need Score Atlanta, GA 2.33 Baltimore, MD –0.78 Fresno, CA 2.16 Newark, NJ –0.81 El Paso, TX 2.05 St. Louis, MO –0.84 New Orleans, LA 1.59 Philadelphia, PA –0.91 Memphis, TN 1.55 Anaheim, CA –0.95 Tampa, FL 1.51 Santa Ana, CA –1.06 San Antonio, TX 1.43 San Francisco, CA –1.19 Baton Rouge, LA 1.40 Boston, MA –1.40 Corpus Christi, TX 1.34 Buffalo, NY –1.73 Factor 3: Declining poverty/ poverty concentration/ low density Miami, FL 1.14 New York, NY –1.94

CDBG Formula Targeting to Community Development Need 27 Creating a Composite Needs Index

Creating a single measure of community development need requires evaluating the CDBG objectives to determine the relative importance of each needs factor identified above. From that assessment, the weight of the individual dimensions of need can be determined.

By definition, factors 1, 2, and 3 are independent of each other as dimensions of the variance explained by the variables used in this analysis. Factor 1 clearly targets to communities with problems identified in the CDBG statute, specifically places with large segments of their population including persons with low and moderate income, communities with substantial neighborhood blight, places with deteriorated housing and physical and economic distress, and decline (41 USC 5301[c]). Factor 1 accounts for 45 percent of the total variance and correlates well with nearly all the variables identified in this analysis as measures of community need.

Factor 2 represents a new dimension of community need, growing immigrant communities. The CDBG statute states as one of its purposes the development of new centers of population growth and economic activity (41 USC 5301[b][1]). For the communities targeted by factor 2, population growth and economic activity come at the cost of increased fiscal stress associated with providing community services for the growing population of low-wage workers. In addition, the CDBG statute calls for the expansion of the nation’s housing stock to provide a decent home and a suitable living environment for all persons (41 USC 5301[c][3]). Because much of the growing immigrant population is moving into expensive housing markets for work, the consequence is a shortage of housing that leads to overcrowding. Factor 2 accounts for 16 percent of the variance between the variables used in this analysis. Factor 2, however, targets away from many of the high-need communities identified in factor 1.

Finally, factor 3 captures a dimension of need—poverty concentration—but also some dimensions of positive economic growth in the form of declining poverty rates. One objective of the CDBG program is to reduce the isolation of income groups (41 USC 5301[c][6]). Factor 3 targets toward the subset of communities with poverty concentration that are also experiencing declining poverty rates. Like factor 2, it targets away from other communities with high need that have increasing poverty rates. Factor 3 represents about 9 percent of the variance of the 17 variables used in this analysis.

Using the CDBG program’s statutory objectives as a guide, the weight assigned to each factor to create a composite needs index score is as follows:

null Factor 1 is assessed a weight of 80 percent. Factor 1 receives the largest share of the weight because (1) it targets toward multiple components of the CDBG objectives, (2) reflects a very high proportion of the variance in need between communities, and (3) communities that rank as less needy on this factor do not rank as particularly needy on either factor 2 or 3, thus decreasing the risk of anomalous targeting.

null Factor 2 is assessed a weight of 15 percent. Factor 2 is modestly weighted to reflect that, although it targets well toward the fiscal stress associated with growing low-wage

CDBG Formula Targeting to Community Development Need 28 immigrant populations, it also targets away from many of the high-need communities of factor 1.

null Factor 3 is assessed a weight of 5 percent. Factor 3 gets a very low weight. While it does account for a select group of communities with high rates of concentrated poverty, factor 3 also targets away from needy communities with increasing poverty rates. The author also suspects that factor 3 may reflect a pattern of variance unique to the 1990s.

Table 3-9 shows the individual scores for some of the larger CDBG jurisdictions with relatively high composite scores, meaning that they have high community development need, and others that have relatively low scores. Not surprisingly, the high-need communities of factor 1 are most frequently represented in the higher need category. Especially needy communities on factor 2, such as Santa Ana, CA, however, move up on this list as well.

Table 3-9. Examples of High- and Low-Need Communities on Composite Needs Index

Higher Need Score Lower Need Score Newark, NJ 2.55 Virginia Beach, VA –0.72 Detroit, MI 2.12 Contra Costa County, CA –0.76 Miami, FL 2.11 Montgomery County, MD –0.78 Santa Ana, CA 1.88 Cobb County, GA –0.80 Cleveland, OH 1.68 King County, WA –0.85 Baltimore, MD 1.60 Fairfax County, VA –0.97 St. Louis, MO 1.56 Montgomery County, PA –1.00 Buffalo, NY 1.54 Oakland County, MI –1.07 New York, NY 1.54 Westchester County, NY –1.15 Composite needs index:

0.80*Factor 1 + 0.15*Factor 2 + 0.05*Factor 3 Philadelphia, PA 1.50 Hennepin County, MN –1.17

The composite needs index for entitlement communities will be used as the “measuring stick” in Chapter 4 to assess how well the current entitlement formula targets toward community development need. This needs index is used in that chapter to answer the following two basic questions:

1. Do communities with similar needs index scores receive similar per capita grant amounts?

2. Do communities with very high needs index scores get much larger grants on a per capita basis than communities with very low needs index scores?

CDBG Formula Targeting to Community Development Need 29 Nonentitlement Targeting to Need

Nonentitlements are statewide aggregates of all the communities not covered by the entitlement side of the formula. They reflect urban and rural areas, small towns, new growing suburbs, and declining agricultural communities. This diversity of communities, often in a single state, makes creating a needs index for nonentitlement areas difficult.

A review of the data available that are comparable across grantees for the geographic areas that make up nonentitlements indicates that decennial census data are the only reliable and comparable source of data. This is due to the odd geography of nonentitlement areas, which are balances of states remaining after subtracting entitlement areas. It cannot be assumed, for example, that rural areas are a good proxy for nonentitlement areas because in some states a high percentage of the nonentitlement areas are urban.

The variables used to create the nonentitlement needs index include nine variables previously used in the analysis of need for entitled areas that make practical sense for nonentitlement areas. We don’t use, for example, the measure of local per capita income relative to metropolitan per capita income in the nonentitlement needs index because the balance of a state consists of multiple MA and non-MA areas.

The nine variables used for the nonentitlement needs index that are the same as for the entitlement needs index are selected for the same reasons as for the entitlement jurisdictions. One additional variable is added: a proxy for infrastructure need due to the high percentage of nonentitlement funds that are spent on infrastructure. The variables as they related to the summary objectives of the CDBG statute are described below. 24

1. Low- and Moderate-Income Persons.

Income Variables

a. Persons in poverty living in families or elderly households. b. Concentrated poverty.

High Consumers of Community Services

a. Female-headed households with children. b. Persons with lower education levels.

24 The CDBG statute calls for subtracting Native Americans who live in Native American areas, such as reservations, trust land, and Oklahoma Tribal Statistical Areas, from the data used in the CDBG formula. This impacts a few urban counties and states with large Native American populations living in Native American areas. For this analysis, Native Americans are subtracted from the overcrowding variable only. This impacts the scores for a few states with large Native American populations, such as Oklahoma, Alaska, and New Mexico. The allocation amounts provided in Appendix B do reflect subtracting Native Americans for all of the selected variables.

CDBG Formula Targeting to Community Development Need 30 2. Decent Housing.

a. Occupied housing units built pre-1970 and occupied by a poverty renter. b. Occupied housing units built pre-1950 and occupied by poverty household. c. Overcrowding.

3. Suitable Living Environment.

null Housing units with wood or bottled gas as the main source of heating fuel. This variable is not used in the entitlement needs index. It was added for the nonentitlement needs analysis to obtain a proxy for infrastructure need. Analysis of 2001 American Housing Survey data show that this is a reasonable proxy for water and sewer infrastructure. Housing units using wood or bottled gas as the main source of heating fuel are also likely not to have public water or sewer connections. 25

4. Economic Opportunities.

a. Population age 16 to 64 that was employed in 2000. b. Persons age 16 years or older in the labor force that were unemployed in 2000.

These 10 variables show similar patterns of variance that create three factors: (1) poverty, economic distress, and overcrowding; (2) older housing; and (3) some elements of water and sewer need.

Factor 1—Poverty/Economic Distress/Overcrowding

Nonentitlement factor 1 captures 55 percent of the variance explained by the 10 variables. As Table 3-10 shows, it most closely represents poverty need, but also very closely captures the need associated with unemployment, low education, and concentrated poverty. It also has a very high correlation with overcrowded housing.

25 According to data analyzed from the 2001 American Housing Survey (AHS), 77 percent of households that use wood or bottled gas as their main source of heat also do not have public sewers; 22 percent of households without sewers also use wood or bottled gas as their main source of heat. The correlation between no sewer and no piped gas is 0.35. The AHS data show that 26 million households have no sewers. Similarly, this survey indicates that 54 percent of households that use wood or bottled gas as their main source of heat also do not have public or private piped water. Of households without piped water, 26 percent also use bottled gas or wood as their main source of heat. The correlation between no piped water and no piped gas is 0.31. This same survey shows that 17 million households have no piped water. In total, 8.8 million households use bottled gas or wood as their main source of heating. The lack of coverage on this variable may make this proxy regionally biased toward rural places where bottled gas is used and away from rural places where other heating fuels, such as oil or electricity, are used.

CDBG Formula Targeting to Community Development Need 31

Table 3-10. Correlation of Individual Need Variables to Nonentitlement Underlying Factor 1 Correlation Percent of persons in poor families or headed by elderly poor person, 2000 0.980 Percent of poor persons in census tracts with greater than 40 percent poverty, 2000 0.864 Percent of families with female head with children under 18, 2000 0.564 Percent of population age 25– 64 without high school education, 2000 0.846 Percent of occupied housing units built pre-1950 occupied by poverty household, 2000 0.098 Percent of occupied housing units built pre-1970 occupied by poverty renter household, 2000 0.595 Percent of housing units overcrowded, 2000 0.804 Percent of population age 16–64 employed, 2000 (negative equates with good targeting to need) –0.959 Percent of persons age 16 or older in labor force and unemployed, 2000 0.933 Percent households heat with wood or bottled gas, 2000 0.067

Table 3-11 shows the states that rank the highest and lowest on factor 1. Table 3-11 shows one nonentitlement grantee, Puerto Rico, whose score on factor 1 is substantially greater than 1. Puerto Rico is unique among nonentitlements because of its very high poverty rate and thus very high score on factor 1. 26

Table 3-11. Examples of High- and Low-Need States on Factor 1

Highest Need Score Lowest Need Score Puerto Rico 5.62 Colorado –0.71 New Mexico 1.24 Indiana –0.71 Mississippi 1.20 New Jersey –0.72 Arizona 1.10 Nebraska –0.73 Louisiana 1.09 Iowa –0.80 California 0.91 Minnesota –0.84 West Virginia 0.60 New Hampshire –0.92 Kentucky 0.45 Wisconsin –0.97 Alabama 0.44 Massachusetts –0.99 Factor 1: Poverty, economic distress, overcrowding South Carolina 0.42 Connecticut –1.20

Factor 2—Old Housing Occupied By Needy Families

Unlike the needs index for entitlement grantees, old housing occupied by needy families remains a distinctly separate element of need from the poverty measure of need in factor 1. Factor 2 is

26 Chapter 5 suggests that the poverty rate for Puerto Rico is not directly comparable to other states because the cost of living is less. This would suggest that the factor score for Puerto Rico should be somewhat less.

CDBG Formula Targeting to Community Development Need 32 most closely targeted toward nonentitlements with old housing stock occupied by households in poverty.

Table 3-12. Correlation of Individual Need Variables to Nonentitlement Underlying Factor 2 Correlation Percent of persons in poor families or headed by elderly poor person, 2000 0.045 Percent of poor persons in census tracts greater than 40 percent poverty, 2000 0.042 Percent of families with female head with children under age 18, 2000 –0.040 Percent of population age 25–64 without high school education, 2000 –0.091 Percent of occupied housing units built pre-1950, occupied by a poverty household, 2000 0.969 Percent of occupied housing units built pre-1970, occupied by a poverty renter household, 2000 0.731 Percent of housing units overcrowded, 2000 –0.375 Percent of population age 16–64 employed, 2000 (negative equates with good targeting to need) 0.119 Percent of persons age 16 or older in labor force and unemployed, 2000 –0.118 Percent households heat with wood or bottled gas, 2000 0.236

Table 3-13 shows states with high and low need on factor 2. The high-need states are states known for having small mining, industrial, and farming towns that have lost economic strength over the past several decades. The less-needy states on this factor are states with more recent population growth.

Table 3-13. Examples of High- and Low-Need States on Factor 2

Highest Need Score Lowest Need Score West Virginia 1.98 Maryland –0.68 South Dakota 1.67 Colorado –0.73 New York 1.59 Delaware –1.04 Vermont 1.54 Utah –1.25 Montana 1.33 Connecticut –1.30 Pennsylvania 1.32 Arizona –1.50 Kansas 1.24 Hawaii –1.55 North Dakota 1.22 Nevada –1.85 Oklahoma 1.16 Florida –1.90 Factor 2: Old housing with poor occupant Maine 1.05 Alaska –2.54

Factor 3—Infrastructure Need

Factor 3 shows the relative level of infrastructure need as proxied in the U.S. Census data by the portion of households heating with wood and bottled gas. Interestingly, this factor also has a high correlation with female-headed households with children.

CDBG Formula Targeting to Community Development Need 33 Table 3-14. Correlation of Individual Need Variables to Nonentitlement Underlying Factor 3 Correlation Percent of persons in poor families or headed by elderly poor person, 2000 –0.047 Percent of poor persons in census tracts with greater than 40 percent poverty, 2000 –0.184 Percent of families with female head with children under age 18, 2000 0.594 Percent of population age 25–64 without high school education, 2000 0.280 Percent of occupied housing units built pre-1950, occupied by a poverty household, 2000 –0.153 Percent of occupied housing units built pre-1970, occupied by a poverty renter household, 2000 –0.085 Percent of housing units overcrowded, 2000 –0.166 Percent of population age 16–64 employed, 2000 (negative equates with good targeting to need) 0.021 Percent of person age 16 and older in labor force and unemployed, 2000 –0.213 Percent households heat with wood or bottled gas, 2000 0.761

The states listed in Table 3-15 that rank high on factor 3 are communities with clear infrastructure need: Mississippi, Delaware, and New Mexico. The grantees that rank the lowest on this factor are largely states with relatively less infrastructure need, such as Massachusetts, Connecticut, and Pennsylvania. Analysis of American Housing Survey data, however, shows many communities with infrastructure need are not represented by the number of households heating with wood or bottled gas. In regions of the country, for example, where electric heat is common, this variable misses much of the infrastructure need.

Table 3-15. Examples of High- and Low-Need States on Factor 3

Highest Need Score Lowest Need Score Mississippi 2.35 New York –0.65 Delaware 1.96 West Virginia –0.79 New Mexico 1.63 Hawaii –1.12 Alabama 1.41 Rhode Island –1.22 Missouri 1.26 New Jersey –1.49 Georgia 1.24 Pennsylvania –1.54 South Carolina 1.20 Connecticut –1.59 Arkansas 1.06 Massachusetts –1.67 North Carolina 1.01 Utah –1.97 Factor 3: Infrastructure Vermont 0.83 Puerto Rico –2.58

CDBG Formula Targeting to Community Development Need 34 Creating a Composite Needs Index for Nonentitlements

As with the entitlement communities, creating a single composite score out of the three factors requires weighting each factor. How important is each factor relative to the objectives of the CDBG program?

For the composite needs index used in Chapter 5 to measure how well the nonentitlement formula targets to community development need, the weight assigned to each factor to create a composite needs index score is as follows:

null Factor 1 is assessed a weight of 70 percent. Factor 1 explains 55 percent of the variance and correlates very well with 8 of the 10 variables. It targets very well toward the poverty and economic distress objectives of the CDBG statute.

null Factor 2 is assessed a weight of 25 percent. Factor 2 explains 17 percent of the variance and correlates well with 2 of the 10 variables. The two variables it correlates well with, pre-1970 housing occupied by poverty renters and pre-1950 housing occupied by a poverty household, are the variables that proxy the important community development needs associated with inadequate housing and aging infrastructure.

null Factor 3 is assessed a weight of 5 percent. Factor 3 explains 12 percent of the variance and correlates well with 2 of the 10 variables. As noted above, considerably more infrastructure need is present than is represented by households heating with wood or bottled gas. To lower the risk of creating substantial anomalies in targeting, the weight is relatively low on this factor.

Table 3-16 shows that the nonentitlement areas of Puerto Rico, Mississippi, and New Mexico are the most needy communities while Connecticut, Utah, and Massachusetts are the least needy.

Table 3-16. Examples of High- and Low-Need States on the Composite Needs Index

Highest Need Score Lowest Need Score Puerto Rico 3.77 Indiana –0.62 Mississippi 1.00 Maryland –0.66 New Mexico 0.99 Colorado –0.68 West Virginia 0.87 Nevada –0.70 Louisiana 0.83 New Hampshire –0.74 California 0.64 New Jersey –0.75 South Dakota 0.50 Wisconsin –0.76 Kentucky 0.48 Massachusetts –0.86 Oklahoma 0.47 Utah –0.89 Composite: .70 * Factor 1 .25 * Factor 2 .05 * Factor 3

Arizona 0.44 Connecticut –1.25

The composite needs index for states will be used as the “measuring stick” in Chapter 5 to assess how well the current nonentitlement formula targets toward community development need. This needs index is used in that chapter to answer the following two basic questions:

CDBG Formula Targeting to Community Development Need 35

1. Do states with similar needs index scores receive similar per capita grant amounts?

2. Do states with very high needs index scores get much larger grants on a per capita basis than states with very low needs index scores?

CDBG Formula Targeting to Community Development Need 36

CDBG Formula Targeting to Community Development Need 37 Chapter 4. CDBG Targeting to Need: Entitlement Communities

This chapter demonstrates how well the current Community Block Development Grant (CDBG) entitlement formula targets to the community development needs index developed in Chapter 3. 27 When this report describes “targeting” to need, it uses “per capita grants” to compare the relative funding of communities. This approach assumes that population is not a measure of need. For example, this assumption allows for comparing New York City’s (population 8,084,316) grant to that for East Orange, New Jersey’s (population 69,750). Their total grants are dramatically different, $219 million versus $2 million in Fiscal Year (FY) 2004, respectively. Their per capita grants, however, are comparable, $27.07 to $28.66. The premise of targeting is that a community with high need should get a larger per capita grant than a community with low need.

Over time, the current CDBG formula has degenerated in its ability to appropriately target funds to jurisdictions with community development need (Bunce, Neal, and Gardner 1983, Neary and Richardson 1995). The current formula does continue to target more funds per capita to communities with high-needs index scores relative to communities with low-needs index scores, but the targeting continues to weaken; this creates some troubling inequities. Specifically, an increasing number of relatively well-off communities are receiving more funding on a per capita basis than some very distressed communities. This chapter also describes which elements of the formula are most responsible for creating the funding inequities.

Most/Least

Richardson, Meehan, and Kelly (2003) include an extensive description of how the formula allocation changed when Census 2000 data were introduced. That report explores two key time periods: the 1-year change from FY 2002 to FY 2003 and the 10-year change from FY 1993 to FY 2003. This report examines how that redistribution of funds affected targeting to community development need for those same two time periods:

1. One-year change, from FY 2002 to “All 2000 Data.” 28 Three of the formula variables— poverty, pre-1940 housing, and overcrowding—are updated only once every 10 years. The transition from Census 1990 data to Census 2000 data for those variables occurred in the transition from the FY 2002 allocation to the FY 2003 allocation. The other two variables in the formula, population and growth lag, are updated every 1 to 2 years and did not change from FY 2002 to FY 2003. The first question is, therefore, how much of an effect does the once a decade change have on the formula’s targeting to need?

Table 4-1 shows that both before and after introducing Census 2000 data on poverty, overcrowding, and pre-1940 housing, the current formula does target to need. That is, on

27 For a similar analysis using individual indicators of need, such as poverty, crime, and population loss as well as need factor 1, see Appendix A. 28 In this report, “All 2000 Data” is used instead of FY 2003 because for this analysis, the appropriation level and number of entitlement grantees remain constant at the FY 2002 amount. The actual FY 2003 allocation, which used all Census 2000 data, and the numbers in this analysis are very similar because the appropriation and number of grantees did not change significantly between FY 2002 and FY 2003.

CDBG Formula Targeting to Community Development Need 38 average, the less needy communities receive relatively smaller grants on a per capita basis than the more needy communities. The table shows that for the FY 2002 allocation, the 89 least needy communities received $7.45 per capita while the 90 neediest communities received $33.51 per capita. Using a simple, most over least measure (Most/Least), the most needy communities on average receive 4.5 times greater funding on a per capita basis than the least needy communities in FY 2002.

Continuing a trend that began with introducing 1980 Census data into the formula (Bunce, Neal, and Gardner 1983), however, the introduction of new census data exacerbated targeting to need. When Census 2000 data for poverty, overcrowding, and pre-1940 housing are used in place of Census 1990 data, the difference in average per capita grant funding between the least needy and most needy grantees falls from 4.5 to 4.1.

Table 4-1. Impact of Introducing Census 2000 Data on Targeting to Community Development Need—Per Capita Grants by Needs Decile

Deciles of CD Need N FY 2002 All 2000 Data Percent Change Low 89 $7.45 $7.83 5.1 2 90 $8.78 $9.29 5.8 3 90 $10.92 $11.40 4.4 4 90 $11.81 $12.28 4.0 5 90 $13.36 $14.09 5.5 6 90 $15.47 $15.52 0.3 7 90 $17.64 $17.77 0.7 8 90 $18.72 $18.70 –0.1 9 90 $25.96 $25.71 –1.0 High 90 $33.51 $32.27 –3.7 Total 899 $17.88 $17.87 –0.1* Most/Least 4.5 4.1 Note: Per capita grants weighted on population. *This does not equal zero because the needs index includes only 899 of the 1,024 entitlement jurisdictions.

2. Change in targeting over a decade. Unlike poverty, pre-1940 housing, and overcrowding data that are updated only once every 10 years, population data are updated more frequently during the decade, usually every 1 to 2 years. Population impacts the remaining two variables of the formula, population (in Formula A) and growth lag (in Formula B). In addition, population is used to determine eligibility for CDBG entitlement status (see Chapter 2). As new communities that are currently funded under the nonentitlement program become eligible as entitlement communities, a reduction in share of funds available for the current entitlement communities is the result.

CDBG Formula Targeting to Community Development Need 39 Neary and Richardson (1995) documented the impact of introducing 1990 Census data into the formula. 29 To know the full impact of transitioning from all 1990 Census data to all 2000 Census data requires comparing the most versus least distribution for the 787 jurisdictions with needs data that were CDBG grantees in FYs 1993 and 2003. Table 4-2 illustrates this impact. It accounts for a reduction in funding share to these 787 communities due to the introduction of new entitlement communities and the impact of the change in data from Census 1990 to Census 2000 for all five variables used in the dual formula—population, poverty, overcrowding, growth lag, and pre-1940 housing.

Table 4-2. Impact of Introducing Census 2000 Data, Population Updates, and New Entitlements on Targeting to Community Development Need FY 1993 to FY 2003— Per Capita Grants by Needs Decile

Deciles of CD Need N All 1990 Data All 2000 Data Percent Change Low 70 $7.94 $8.10 2.0 2 75 $9.38 $9.43 0.5 3 80 $11.52 $11.51 –0.1 4 73 $12.15 $12.59 3.6 5 74 $14.35 $14.27 –0.6 6 86 $16.11 $15.53 –3.6 7 80 $18.58 $17.95 –3.4 8 78 $19.89 $18.96 –4.7 9 86 $26.84 $25.89 –3.5 High 85 $35.12 $32.33 –7.9 Total 787 $19.11 $18.33 –4.1* Most/Least 4.4 4.0 Note: Per capita grants weighted on population. *Most of this decrease is due to the introduction of new entitlement communities between 1993 and 2002.

Table 4-2 shows that the introduction of all the census data, which has also led to more entitlement grantees, has been particularly difficult for the neediest grantees, who experienced a decline in funding of nearly 8 percent, compared to small increases for the least needy grantees. The result for these 787 jurisdictions is a most/least ratio change from 4.4 to 4.0.

29 Neary and Richardson showed the impact introducing all Census 1990 data into the formula in FY 1993. In reality, all the Census 1990 data were not introduced until FY 1995.

CDBG Formula Targeting to Community Development Need 40 Regression Analysis

The most/least analysis is a simple approach to indicate how well the current formula targets to need. It does not, however, capture all the dimensions associated with targeting. Chapter 3 poses two key questions that will be answered in Chapter 4:

1. Do communities with similar needs index scores receive similar per capita grant amounts?

2. Do communities with very high needs index scores get much larger grants on a per capita basis than communities with very low needs index scores?

To some extent, the most/least analysis answers question 2, but with a lack of precision. To answer question 1, and answer question 2 more precisely, this study employs regression analysis.

Regression analysis provides two helpful measures, R-square and slope. The R-square enables this report to answer the first question: do communities with similar needs index scores receive similar per capita grant amounts? In a simple linear regression between two variables, the R- square estimates how similar the variance is between the variables. For example, are most jurisdictions with high needs scores also receiving relatively high per capita grants? If the answer is yes, the R-square is high. If, instead, little relationship exists between the needs scores and per capita grant amounts, the R-square is small. An R-square of 1.00 represents perfect targeting to need while an R-square of 0.00 indicates that no relationship at all exists between the needs index and the targeting of the current formula. The R-square tends to measure the fairness of the formula allocation. Locations with similar needs should get similar per capita grant amounts.

The slope enables answering the second question: do communities with very high needs index scores get much larger grants on a per capita basis than communities with very low needs index scores? The slope indicator in a regression is similar to the most/least concept presented in Tables 4.1 and 4.2. The greater the slope, the greater the difference in funding between the most and least needy grantees. That is, a slope of 0 would mean that, on a per capita basis, the least needy community received the same as the neediest. A slope of 10 would mean a community one standard deviation from the mean would receive $10 more per capita than the mean per capita grant.

Table 4-3. Regression Statistics of Targeting to Need Over Time

Targeting to: All 1990 Data* FY 2002** All 2000 Data** R-square 0.308 0.349 0.352 Slope 9.9 9.5 8.8 Places (unweighted) Constant 17.2 18.2 18.1 R-square 0.494 0.506 0.525 Slope 10.8 10.1 9.5 People (weighted on population) Constant 16.7 16.7 16.8 * Reflects only 787 jurisdictions with needs data that were grantees in FY 1993. ** Reflects 899 jurisdictions with needs data that were grantees in FY 2002.

CDBG Formula Targeting to Community Development Need 41 In the Places rows in Table 4-3, the R-square between per capita CDBG funding and need was 0.349 in FY 2002. This suggests that community need did not explain much of the variation in per capita funding between cities (although the R-square was somewhat improved from that for the same cities using all 1990 data). As will be illustrated later, this low R-square means that communities with similar needs receive quite different per capita grants. The low R-square suggests equity problems in the formula.

The Places rows in Table 4-3 treats all entitlement communities equally. Because a great deal of variation exists among the communities in terms of their size, however, it may be more appropriate to consider how well the formula targets to people living in communities with different needs. In the People rows in Table 4-3, each community is weighted by its population. This demonstrates that the formula performs somewhat better in targeting among the larger places than among individual jurisdictions.

While the measure of fairness, R-square, has improved slightly, the slope has declined from 9.9 to 8.8 for the unweighted regression (Places) and 10.8 to 9.4 for the regression weighted on population (People). Over the course of the decade, the slope has declined. The more needy communities are getting less on a per capita basis relative to the mean than they did a decade ago. The relatively less needy communities are receiving more on a per capita basis than they did a decade ago.

Table 4-3 also provides a constant. The constant represents the per capita grant for a jurisdiction with a needs score near the national average. Chapter 3 noted that grantees with less than average need levels receive negative scores, and grantees with above average needs scores receive positive needs scores. The constant becomes an important indicator when comparing relative funding levels between Formula A and B grantees below.

Charts

Charts 4-1 and 4-2 provide graphical presentations of these concepts. A fictional per capita grant amount with the same slope as the current allocation (8.8) that targets perfectly to the needs index—that is, an R-square of 1—is plotted as the solid line in Chart 4-1. The “bouncing” line represents how much the current per capita grants vary from the needs index. Communities of similar need, which should be receiving approximately the same amount per capita, are getting substantially different grant amounts than appropriate for their need.

CDBG Formula Targeting to Community Development Need 42 $0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Current Per Capita Grant Needs Index Per Capita Grant (slope 8.8) Low Need High Need

Chart 4-1. Current Formula Targeting to the Needs Index (Slope 8.8)

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Current Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart 4-2. Current Formula Targeting to the Needs Index (Slope 12.0)

CDBG Formula Targeting to Community Development Need 43 Chart 4-2 shows this same comparison but with the assumption that not only is there a desire that the formula be fair—similarly needy communities receive similar grant amounts—but that the neediest communities get substantially more on a per capita basis than the least needy. Chart 4-2 reflects a per capita allocation using the needs index; the slope increases from 8.8 in Chart 1 to 12.0 for Chart 2. 30 This higher slope is this study’s goal for developing a formula in Chapter 6 that is not only fairer but also allocates a greater share of the funds to the neediest grantees relative to the least needy.

To provide another way to assess how the current formula targets to community development need, Appendix A shows how the formula currently targets to individual components of the needs index, such as poverty and population loss.

Formulas A and B

With respect to targeting, a clear difference exists between Formula A and Formula B grantees. The lack of fairness, evidenced by the low R-square, is due largely to Formula B, and the low slope is primarily due to Formula A. Chart 4-3 shows the per capita grants for the Formula B communities relative to the needs index for Formula B communities and how that compares to the needs index for Formula A grantees and the per capita grants for Formula A grantees. The key lessons of Chart 4-3 are as follows:

null On average, Formula B grantees are more needy than Formula A grantees (the Formula B needs line is higher than the Formula A needs line).

null Formula B creates many anomalies where communities of the same need receive very different grant amounts. Most striking are the number of less needy communities getting much more on a per capita basis than communities of higher relative need (demonstrated by the “bouncing” of the Formula B current grants line).

null Formula B grantees tend to be funded at a higher level than their needs score (as shown by most of the bounces being above the needs line).

null Formula A does not have major anomalies, but the most needy grantees do not receive much more than the least needy grantees, as the relatively flat slope of the Formula A current grants line indicates).

null Formula A grantees with relatively high need are particularly underfunded relative to their needs score, as evidenced by the widening gap between the Formula A needs line and the Formula A grants line.

30 The R 2 relationship with need remains 1.000. The selection 12 as the slope is subjective, 10 or 15 could just as easily been chosen. This study selected 12 because when the original dual formula was implemented it had a slope of 12.72 relative to a needs index created for 483 entitlement cities (Bunce and Goldberg 1979, Table 17). A slope of 12 places the jurisdictions in the lowest needs decile near $4 per capita and jurisdictions in the highest needs decile near $36 per capita, a most/least ratio of 9.

CDBG Formula Targeting to Community Development Need 44 $0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Split by A and B Per Capita Grant B Current B Need A Current A Need Low Need High Need

Chart 4-3. Comparing Formula A and B Targeting to Need (Slope 12.0)

Table 4-4 provides the statistical evidence for Chart 4-3 using the unweighted (Places) regression results.

Formula A null High R-square (0.884, which indicates a low rate of anomalies and a high rate of fairness). null Low slope (6.2, indicating the most needy don’t get much more than the least needy). null A constant that is much lower than Formula B (12.8 compared to 25.5, showing that a Formula A grantee with average need receives $12.70 less per capita than an similar needy Formula B grantee).

Formula B null Low R-square (0.378, indicating a high rate of anomalies). null Reasonably high slope (10.3, indicating that the most needy generally get more than the less needy).

CDBG Formula Targeting to Community Development Need 45 Table 4-4. Regression Statistics for Targeting to Need by Formula for the Current Formula With All Census 2000 Data

Targeting to: Formula A Formula B R-square 0.884 0.378 Slope 6.2 10.3 Places (unweighted) Constant 12.8 25.5 R-square 0.924 0.490 Slope 6.7 9.6 People (weighted on population) Constant 12.9 22.9 Formula A: N=534; Formula B: N=365.

The funding inequity between Formula A and B grantees increases as the neediness of the Formula A jurisdiction grows. This is a product of the large difference between the Formula A and Formula B constant in Table 4-4 and the higher slope for Formula B relative to Formula A. Table 4-5 demonstrates this widening gap another way; this table shows the average per capita grants by needs decile for Formula A and Formula B grantees. In the lowest needs decile, the average Formula A grantee receives $6.36 per capita and the average Formula B grantee receives $9.89 per capita, a gap of $3.53. That gap widens to approximately $12 to $13 for grantees with average need and higher, except for needs decile 9 where the gap nears $20.

Table 4-5. Comparing Formula A and Formula B Average Per Capita Grant by Community Development Need Decile

Deciles of CD Need Formula A Formula B Gap (Formula B minus Formula A) Low $6.36 $9.89 $3.53 2 $7.54 $13.56 $6.02 3 $8.24 $17.51 $9.27 4 $10.36 $17.60 $7.24 5 $10.96 $23.06 $12.10 6 $12.47 $24.49 $12.02 7 $13.64 $27.28 $13.64 8 $15.65 $28.26 $12.61 9 $17.97 $37.86 $19.89 High $24.20 $35.92 $11.72 N=899; Per capita grants weighted on population.

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need 46 Identifying the Underlying Causes for Inequities in the Current Formula

Population

As described above, Formula A causes inequities because its allocation has a low slope. The single largest contributor to the low slope is the 25 percent weight on the population variable. The slope of the population variable is zero because population does not target community development need. While this report previously noted that Formula B sometimes targets large grants to low-need communities, the majority of low-need communities are funded under Formula A because of the population variable. This is because most low-need jurisdictions have fast-growing populations and newer housing stock, resulting in their receiving larger allocations with Formula A from the 25 percent weight on population than from any of the variables in Formula B.

Poverty

Poverty receives a 50 percent weight in Formula A and a 30 percent weight in Formula B. As demonstrated by the needs index, poverty is an extremely good indicator of a number of dimensions of community development need. Two problems, however, exist with the poverty measure. First, because poverty is a fixed national standard that does not take into account regional differences in the cost of living, it has a regional bias that favors places with low cost of living. Second, relatively low-need college towns receive relatively large per capita grants because off-campus college students are recorded as being in poverty, when in fact many of them receive unrecorded support from families.

Poverty is a constant dollar threshold nationwide. It does not take into account that it may cost more to live in some parts of the country than in other regions. That is, a person just above the poverty line in New York City who has to pay $1,000 in rent per month may be worse off, in terms of disposable income, than a person in poverty in Saginaw, Michigan, who pays $550 in rent each month. Cost of living is strongly related to the incomes in an area. Generally, if the median income for a metropolitan area is high, the cost of housing and other goods and services in the metropolitan area are also high.

Congress recognized this disparity in cost of living when it established guidelines for CDBG program eligibility, setting income limits based on the metropolitan area median income. Households with incomes less than 80 percent of median income are considered “low and moderate income” and eligible for assistance with funds from the CDBG program.

While the program uses these income thresholds to determine whether persons or households are eligible for the program, the formula uses the constant dollar standard of poverty. Among CDBG entitlement grantees, the national poverty rate is 13 percent. Similarly, among CDBG grantees, 13 percent of households have extremely low incomes, defined by having incomes less than 30 percent of their metropolitan area median income. 31

31 Data on the number of households with less than 30 percent of local median income are from a special tabulation of Census 2000 Data prepared for HUD by the U.S. Census Bureau using the Section 8 income limits.

CDBG Formula Targeting to Community Development Need 47 Table 4-6. Comparing Poverty Rate to Extremely Low-Income Rate by Region

Region Number of Entitlement Communities Percent Poverty Rate Percent Extremely Low Income Rate New England 73 14 19 New York/New Jersey 96 13 16 Mid-Atlantic 87 11 12 Southeast 164 13 12 Midwest 187 11 13 Southwest 106 16 13 Great Plains 30 11 12 Rocky Mountain 37 10 11 Pacific/Hawaii 183 14 12 Northwest/Alaska 40 10 11 Puerto Rico 21 43 22 Total 1024 13 13 Source: Census 2000 Special Tabulation Data for HUD

While the rates are similar nationally, some regions have a much lower rate of extremely low- income households than their poverty rate, which indicates relatively low local costs. High cost places have a much higher rate of very low-income households than poverty rate. Table 4-6 shows that in 6 of the 11 regions, the poverty rate is similar to the rate of households who are extremely low-income. In the New England and New York/New Jersey regions, however, the percent of extremely low-income household significantly exceeds the poverty rate. In these regions, poverty understates the level of need. The starkest example of the poverty rate overstating community development need is in Puerto Rico, where the rate of extremely low- income households in entitlement areas is nearly half the poverty rate.

The use of poverty also creates several anomalies in its allocation to some relatively small communities that receive most of their funding due to the “poverty” of college students living in off-campus housing. 32 Table 4-7 shows 28 cities where more than half of the population counted in poverty are college students. 33 The way census data are collected, these students indicate their income on their census form but do not report that they receive financial support from family. While the census counts the students in poverty, their level of true need, because of support from their families, is considerably less. A better measure of need for these communities is to look at the poverty rate for the noncollege student population.

For example, in State College, Pennsylvania, home to Pennsylvania State University, 74 percent of college students are in poverty as compared to12 percent of the remaining population. The college student poverty rate inflates State College’s total poverty rate to 47 percent, a poverty

32 In the official count of persons in poverty, the Census Bureau does not include institutionalized persons, persons living in military group quarters, persons living in college dormitories, or unrelated individuals under 15 years old. 33 Individuals who are enrolled in college, are in poverty, and are not living in families or dormitories.

CDBG Formula Targeting to Community Development Need 48 rate greater than the very distressed communities of Benton Harbor, Michigan (43 percent poverty rate), and Hidalgo County, Texas (42 percent poverty rate).

Table 4-7. Full-Time Enrolled College Students in Poverty

Percent College Students in Poverty Percent NonCollege Students in Poverty Percent All Persons in Poverty Percent. of Poverty Population College Students Ann Arbor, MI 58 7 17 65 Athens-Clarke County, GA 71 17 28 51 Auburn, AL 80 15 38 74 Berkeley, CA 61 11 20 55 Bloomington, IN 70 13 30 68 Boulder, CO 58 9 17 57 Bowling Green, OH 68 9 25 73 Cedar Falls, IA 63 8 17 61 Champaign, IL 67 10 22 63 Chapel Hill, NC 70 8 22 69 Charlottesville, VA 71 14 26 56 Chico, CA 68 16 27 52 College Station, TX 75 15 37 74 Corvallis, OR 60 12 21 52 Davis, CA 71 7 24 78 De Kalb, IL 63 10 21 63 East Lansing, MI 68 12 35 80 Fort Collins, CO 58 8 14 52 Iowa City, IA 65 9 22 68 Lawrence, KS 62 10 19 57 Madison, WI 59 8 15 52 Normal, IL 69 7 19 71 Provo, UT 72 15 27 55 San Marcos, TX 63 17 29 56 State College, PA 74 12 47 88 Tallahassee, FL 65 15 25 53 Urbana, IL 62 16 27 57 West Lafayette, IN 72 9 38 87 Source: Census 2000 Special Tabulation Data for HUD.

Pre-1940 Housing

Pre-1940 housing receives a 50 percent weight in Formula B. When the current dual formula was put in place, old housing was considered a good proxy of inadequate housing and old infrastructure. Over time, however, the more needy communities with old housing have been demolishing it, while wealthy communities have been renovating and even increasing (by

CDBG Formula Targeting to Community Development Need 49 converting warehouses into lofts, for example) the stock of old housing. Since this variable allocates 27 percent of all the CDBG funds, its declining targeting has led to some very well off communities getting substantially more funds on a per capita basis than some very distressed communities.

Table 4-8 provides some examples of low-need communities that have not experienced significant declines in their pre-1940 housing relative to high need communities that have. The resulting redistribution of funds on this variable from the high need communities to the low need communities was most severe when the 1990 Census data were introduced, but continues with the introduction of 2000 Census data. The very distressed Detroit, Michigan, for example, has had a 48 percent decline over the past 20 years in the number of housing units built before 1940. The relatively less needy Boston suburb of Newton, MA, on the other hand, has had only a 2 percent decline in pre-1940 housing units since 1980. As the total number of pre-1940 housing units decline, Newton’s relative share of the funding for those units has increased, while Detroit’s has decreased. It is pre-1940 housing that is responsible for a large number of funding anomalies.

Table 4-8. Comparing Change in Pre-1940 Housing Stock for Relatively High Need vs. Low Need Jurisdictions

1980 Census 1990 Census 2000 Census Percent Change 1980 to 2000 Low Need Newton, MA 17,364 17,190 16,946 –2 Oak Park, IL 16,351 16,403 15,654 –4 Royal Oak, MI 5,492 5,455 5,194 –5 Evanston, IL 15,389 15,249 14,298 –7

High Need Detroit, MI 214,968 146,748 112,022 –48 Benton Harbor, MI 2,434 1,487 1,300 –47 East St. Louis, IL 6,387 2,911 3,191 –50 Gary, IN 13,422 8,737 8,127 –39 Newark, NJ 57,577 36,014 28,376 –51

Growth Lag

Growth lag, which measures slow population growth and loss of population since 1960, is generally a good indicator of community distress. It, too, however, creates some anomalies.

CDBG Formula Targeting to Community Development Need 50

Table 4-9. Jurisdictions with Growth Lag Funding Targeting to Community Development Need by Percentile

Percentiles of CD Need Entitlement Jurisdictions With Growth Lag Per Capita From Growth Lag Minimum Per Capita From Growth Lag Maximum Per Capita From Growth Lag Low 18 $4.33 $0.17 $17.58 2 18 $5.50 $0.14 $17.63 3 26 $5.76 $0.38 $18.68 4 28 $5.49 $0.18 $19.23 5 33 $7.09 $0.20 $17.75 6 24 $6.41 $2.45 $25.13 7 37 $9.44 $1.05 $21.46 8 40 $9.63 $0.05 $25.51 9 43 $15.68 $3.03 $43.75 High 46 $14.05 $1.43 $40.82 Total 313 $10.72 Most/Least 3.2

Table 4-9 shows by community development needs decile the average per capita dollar amount allocated to the 313 CDBG entitlement grantees that receive funding from growth lag. The majority of the grantees receiving funds under this variable are quite needy. On average, the needier a jurisdiction, the more funds it receives on a per capita basis from growth lag.

Over time, however, an increasing number of relatively well-off communities received funding from growth lag that is not consistent with their actual level of community development need. Many of these locations are fully developed suburbs not seeking to grow. Others are communities that have lost population through the decline of household sizes but in fact may still be experiencing growth in housing. Royal Oak, Michigan, for example, receives $17.58 per capita due to the growth lag variable alone. This is because it has lost 25 percent of its population since 1960. With a per capita income of nearly $31,000 and a poverty rate of 2 percent, however, the loss of this population does not reflect economic decline. 34 In the case of Royal Oak, population loss is actually a sign of affluence rather than decline; although the population declined 25 percent, the total number of occupied housing units increased by 27 percent between 1960 and 2000. This was made possible by a sharp decrease in average household size from 3.5 persons in 1960 to 2.1 in 2000. As a result, Royal Oak receives more on a per capita basis from

34 The per capita income for the Detroit-Ann Arbor-Flint, Michigan Consolidated Metropolitan Statistical Area (CMSA) was $24,275 in 1999, making Royal Oaks’ per capita income significantly higher than its surrounding communities.

CDBG Formula Targeting to Community Development Need 51 growth lag than Philadelphia, Pennsylvania ($16.93), which has a poverty rate of 18 percent and a per capita income of $16,509.

Table 4-10. Examples of Relatively Low-Need Communities with High Per Capita Growth Lag Grants

Need Indicators Name Per Capita Grant Amount Due to Growth Lag Percent Population Change 1960 to 2000 Per Capita Income Percent Population in Poverty Redford, MI $18.68 –28 $22,263 4 Tonawanda Town, NY $17.63 –26 $20,947 5 Royal Oak, MI $17.58 –25 $30,990 2 Portsmouth, NH $16.21 –23 $27,540 6 St Clair Shores, MI $13.94 –18 $25,009 3 Wauwatosa, WI $13.63 –17 $28,834 3 Lakewood, OH $12.59 –14 $23,945 6 Medford, MA $12.51 –14 $24,707 4 Westland, MI $11.28 –11 $22,615 5 Haverford, PA $11.05 –10 $29,749 2 West Allis, WI $11.01 –10 $20,914 5 Newton, MA $10.71 –9 $45,708 3 Penn Hills, PA $10.66 –9 $20,161 6

Another growth lag issue is that for some very needy jurisdictions, it may in fact target too much funding relative to their need. That is, some very needy places receive very large CDBG grants as a result of growth lag. Other equally needy places without as much population loss, however, receive considerably less. For example, St, Louis, Missouri, receives $41 per capita from growth lag for an overall per capita grant amount of $73. Detroit, a needier Formula B city as measured by the community development needs index, receives $29 on growth lag and an overall per capita grant amount of $49. More striking, Miami, Florida, has a similar level of need to Detroit and higher than St. Louis, but is a Formula A community that does not receive funds due to growth lag. Miami has an overall grant of only $28. That is, Miami’s total per capita grant is only 40 percent as much as St. Louis, although Miami ranks as having relatively higher need on the needs index. Any correction to the formula to improve fairness will almost certainly result in a decrease in funding for St. Louis and an increase in funding for Miami.

Summary

The CDBG formula continues to target more funds to the most needy grantees relative to the least needy grantees. As measured against the community development needs index developed in Chapter 3, however, the average amount of funds being allocated to the most needy communities decreased with the introduction of Census 2000 data while the average per capita grant to the least needy grantees increased. In addition, the formula continues to manifest a significant degree

CDBG Formula Targeting to Community Development Need 52 of unfairness, with similarly needy grantees receiving substantially different per capita grant amounts. The unfairness in the formula is largely due to (1) Formula B grantees receiving substantially more than similarly needy Formula A grantees and (2) the pre-1940 and growth lag variables in Formula B. The declining relative share of funds for the neediest communities relative to the least needy is due to the high weight on the population variable in Formula A.

CDBG Formula Targeting to Community Development Need 53 Chapter 5. CDBG Targeting to Need: States (Nonentitlements)

This chapter shows that, with the exception of Puerto Rico, the current Community Development Block Grant (CDBG) nonentitlement formula does not target well to community development need.

Most/Least

Richardson, Meehan, and Kelly (2003) discuss changes in the formula allocation following the introduction of 2000 Census data. The report explores two key periods: the change over 1 year, from Fiscal Year (FY) 2002 to FY 2003, and the change over 10 years, from FY 1993 to FY 2003. This report examines how redistributing funds affected targeting to community development need for those same two periods:

1. Change in targeting over 1 year from FY 2002 to “All 2000 Data.” 35 Three of the formula variables—poverty, pre-1940 housing, and overcrowding—are updated only once every 10 years. The transition from 1990 Census data to 2000 Census data for those variables occurred in the transition from the FY 2002 allocation to the FY 2003 allocation. The other variable in the formula—population—is updated every 1 to 2 years; it did not change from FY 2002 to FY 2003. The first question is, how much of an effect does the once-a-decade change have on the formula’s targeting to need?

Table 5-1 shows the change in per capita allocations due to the replacing of 1990 Census data on poverty, pre-1940 housing, and overcrowding with 2000 Census data. When arranged by community development needs quintile, introducing the new data results in a small shift of funds from the more needy states to the less needy states.

Table 5-1 Impact of Introducing 2000 Census Data on Targeting to Community Development Need Per Capita Grants* by Needs Quintile

Quintile N FY 2002 All 2000 Data Change Low 10 $9.85 $10.07 2.2% 2 10 $11.10 $11.12 0.2% 3 11 $11.28 $11.40 1.1% 4 10 $12.59 $12.41 -1.4% High 10 $15.85 $15.68 -1.0% Total 51 $12.09 $12.09 Most/Least 1.6 1.6 *The denominators for per capita grants are based on 2000 population counts for all columns.

35 The term “All 2000 Data” is used instead of saying FY 2003 because for this analysis the appropriation level and number of entitlement grantees are held constant at the FY 2002 amount. The actual FY 2003 allocation using all 2000 census data and the numbers used in this analysis are very similar because the appropriation and number of grantees did not change significantly between FY 2002 and FY 2003.

CDBG Formula Targeting to Community Development Need 54 2. Change in targeting over 10 years from FY 1993 to FY 2003. Unlike the other variables in the formula, updates occur to population data more frequently during the decade, usually every 1 to 2 years. Population affects both formulas. In addition, population determines eligibility for CDBG entitlement status (see Chapter 2). As new communities currently receiving funds under the nonentitlement program become eligible as entitlement communities, relatively more funds become available to share among the remaining balance of nonentitlement areas nationwide.

Table 5-2 shows the 10-year period, combining the changes in Table 5-1 with the population changes and the loss of population to be served caused by new entitlements on the nonentitlement side of the formula. Not surprisingly, comparing Table 5-1 to Table 5-2 shows that population updates and the introduction of new entitlements have only a minimum impact on reduced targeting. The introduction of 2000 Census data for poverty, overcrowding, and pre-1940 housing causes most of the small shift in funds from the most needy to least needy states.

Table 5-2 Impact of Introducing 2000 Census Data, Population Updates, and New Entitlements on Targeting to Community Development Need FY 1993 to FY 2003 Per Capita Grants* by Needs Quintile

Quintile N All 1990 Data All 2000 Data Change Low 10 $9.85 $10.07 2.1% 2 10 $11.06 $11.12 0.5% 3 11 $11.13 $11.40 2.3% 4 10 $12.71 $12.41 -2.4% High 10 $15.92 $15.68 -1.5% Total 51 $12.09 $12.09 Most/Least 1.6 1.6 *The denominators for per capita grants are based on 2000 population counts for all columns

Most striking about Tables 5-1 and 5-2 is the very small difference in funding between the least needy ($10.07) and the most needy ($15.68), a ratio of only 1.6. In the nonentitlement formula, the most needy states do not get much more on a per capita basis than the least needy states.

Regression Analysis

The most/least analysis is a simple approach to showing how well the current formula targets to need. That approach, however, does not capture all dimensions associated with targeting. In Chapter 3, we noted that Chapter 5 would need to answer the following two key questions:

1. Do states with similar needs index scores receive similar per capita grant amounts?

2. Do states with very high needs index scores get much larger grants on a per capita basis than states with very low needs index scores?

CDBG Formula Targeting to Community Development Need 55 To some extent, the most/least analysis answers the second question, but with some lack of precision. To answer the first question, and more precisely answer the second question, we use regression analysis.

Regression analysis provides us with two helpful measures: R-square and slope. The R-square enables us to determine if states with similar needs index scores receive similar per capita grant amounts. In a simple linear regression between two variables, the R-square estimates how similar the variance is between the variables. For example, are states with high needs score also receiving relatively high per capita grants? If yes, then the R-square is high. On the other hand, if no relationship exists between needs scores and current per capita grants, the R-square is small. An R-square of 1.00 represents perfect targeting to need while an R-square of 0.00 indicates no relationship at all between the needs index and the current formula. The R-square tends to measure the fairness of the formula allocation. States with similar need should get similar per capita grant amounts.

The slope allows us to determine if states with very high needs index scores get much larger grants on a per capita basis than states with very low needs index scores. The slope indicator in a regression is similar to the most/least concept presented in Tables 5-1 and 5-2: the greater the slope, the greater the difference in funding between the most and least needy grantees. A slope of “0” would mean the least needy community received the same as the most needy community on a per capita basis. A slope of 4 would mean a state that is one standard deviation from the mean would get $4 more per capita than the mean per capita grant.

The portion of Table 5-3 referring to “Places” shows the R-square for per capita CDBG funding and need was 0.699 in FY 2002. This suggests that state need was moderately good at explaining the per capita funding variation between states. This measure suggests the current formula is relatively fair; it does not create large funding differences between similarly needy states. As we will show below, however, this finding is somewhat misleading.

The “Places” portion of Table 5-3 treats all states equally. Since a great deal of variation exists among the states in terms of their size, however, it might be more appropriate to consider how well the formula targets to people living in states with different needs. The “People” portion of Table 5-3 weights each state by its population, demonstrating that the formula does a somewhat worse job in targeting among the nonentitled states with large populations. Both measures show that the R-square—the measure of fairness—declines with the introduction of 2000 Census data.

Table 5-3 Regression Estimate of Targeting to Need Over Time

Targeting to: All 1990 Data FY 2002 All 2000 Data R-square 0.690 0.699 0.661 Slope 5.3 4.8 4.9 Places (unweighted) Constant 12.2 12.2 12.3 R-square 0.638 0.659 0.621 Slope 5.0 4.5 4.7 People (weighted on population) Constant 12.1 12.1 12.1

CDBG Formula Targeting to Community Development Need 56

The slope measure changed very little between the FY 2002 allocation and the introduction of 2000 Census data: 4.8 to 4.9, somewhat counter to the earlier most/least analysis.

As alluded to above, however, Table 5-3 is somewhat deceptive. The R-square and slope shown in Table 5-3 are principally driven by the very needy Puerto Rico, which receives a very large per capita grant. If Puerto Rico is removed from the analysis, very little targeting of the current formula to need occurs, with an R-square of 0.294 and a slope of 2.4. Thus, beyond Puerto Rico, the nonentitlement formula does a relatively poor job of targeting to the more needy of the 50 states.

Table 5-4 Regression Estimate of Targeting to Need With and Without Puerto Rico With 2000 Census 2000

Targeting to: With Puerto Rico Without Puerto Rico R-square 0.661 0.294 Slope 4.9 2.4 Places (unweighted) Constant 12.3 12.0 R-square 0.621 0.281 Slope 4.7 2.2 People (weighted on population) Constant 12.1 11.8

Charts

Presenting a chart showing the current targeting of the formula to need can help understand the R-square and slope concepts above. The two graphs in Chart 5-1 explain the targeting of the current formula to the community development needs index line. The graph at the left shows the needs index with a slope of 4.7, matching the current slope for the formula. By looking at this first graph, we can see that the uniqueness of Puerto Rico (the spike at the far right of the chart) among the states in terms of both its level of need and the amount of funds it receives on a per capita basis. The graph also shows that, for the remaining 50 states, very little relationship exists between grant amounts and the needs index.

The chart on the right shows this same comparison but with the assumption that the formula should be fair—similarly needy communities get similar grant amounts—but that the neediest get substantially more on a per capita basis than the least needy. Thus, the graph on the right reflects the needs index with a slope of 8.0. 36 This chart more clearly shows how the nonentitlement allocation appears to have very little relationship to the community development needs index, except in respect to Puerto Rico.

36 This slope is subjective. Selecting 8 is based on the assumption that we want the formula to target relatively more funds to the most needy states.

CDBG Formula Targeting to Community Development Need 57 Chart 5-1. Current Nonentitlement Formula Targeting to the Needs Index

Formula A and Formula B

Table 5-4 compares the targeting of Formula A and Formula B. In the entitlement analysis of Chapter 4, we showed that Formula A had a high degree of fairness (a high R-square) but a low slope relative to Formula B. Formula B had a low degree of fairness but a reasonably high slope. Nonentitlements follow a very different pattern. Excluding Puerto Rico, Formula A and Formula B are equally bad at targeting to need. Both have a low R-square of less than 0.4 and low slopes of less than 3.0.

Table 5-4 Regression Estimate of Targeting to Need by Formula for the Current Nonentitlement Formula with all 2000 Census Data

Targeting to: Formula A Formula A without Puerto Rico Formula B R-square 0.778 0.322 0.341 Slope 6.0 2.5 2.8 Places (unweighted) Constant 11.4 11.5 12.5 R-square 0.817 0.441 0.304 Slope 6.3 3.0 2.8 People (weighted on population) Constant 10.7 11.1 12.5

Chart 5-2 graphically presents the findings from Table 5-4. With the exception of Puerto Rico (the spike at the right-hand side of the Formula A chart), which appropriately gets a very high per capita grant, in both cases a low-need state is nearly as likely to get a relatively higher per capita grant as a high-need state. Needs Index with Current Slope of 4.7 $0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Pe r Ca pita Gra n t Current Per Capita Grant Need (Slope 4.7) Low Need High Need

Needs Index with Higher Slope of 8.0 $0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Pe r Ca pita Gra n t Current Per Capita Grant Need (Slope 8.0) Low Need High Need

CDBG Formula Targeting to Community Development Need 58

Chart 5-2. Comparing Nonentitlement Formula A and B Targeting to Need

Table 5-5 shows the per capita grants by needs quintile. When Puerto Rico is excluded from the analysis, very little difference exists in per capita grant amounts between the least needy and most needy for either Formula A or Formula B. In addition, unlike entitlements, very little difference exists between Formula B and Formula A per capita grants within each of the need quintiles.

Table 5-5 Nonentitlement Per Capita Grants by Need Quintile by Formula (All 2000 Census Data)

Quintiles of Need Formula A Formula A Without Puerto Rico Formula B Low $8.94 $8.94 $10.27 2 $11.45 $11.45 $11.04 3 $9.94 $9.94 $12.56 4 $11.79 $11.79 $14.68 High $16.03 $13.45 $13.07 Total Average $12.53 $11.69 $11.66

Formula A $0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Formula A Grantees Per Capita Grant Current Per Capita Grant Need (Slope 8.0) Low Need High Need Formula B $0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Formula B Grantees Pe r Ca pita Gra n t Current Per Capita Grant Need (Slope 8.0) Low Need High Need

CDBG Formula Targeting to Community Development Need 59 Problems in the Nonentitlement Formula

Population

As shown above, both Formula A and Formula B have low slopes. The largest contributors to the low slope are the 25 percent weight on the population variable in Formula A and the 20 percent weight on population in Formula B. Population simply represents the size of a place, not a measure of its need. The characteristics of the population must be analyzed to know whether the jurisdiction is needy. Because per capita grant amounts are used to compare the fairness of allocations to similarly needy jurisdictions with different populations, by definition the slope of the population variable is zero.

Poverty

Poverty receives a 50 percent weight in Formula A and a 30 percent weight in Formula B. As demonstrated by the needs index, poverty is an extremely good indicator of a number of dimensions of community development need. The poverty measure suffers from the following two problems:

1. Poverty remains a constant dollar threshold nationwide, and does not take into account that it may cost more to live in some parts of the country than in others. A person living in Connecticut and paying $800 per month in rent may be worse off in terms of disposable income than a person living in poverty in Puerto Rico paying $300 per month in rent. Cost of living relates strongly to the incomes in an area. Generally, if a metropolitan area or nonmetropolitan county enjoys a high median income, its cost of housing and other goods and services are also high.

Congress recognized this disparity in cost of living when it established guidelines for CDBG program eligibility, establishing income limits based on the local area median income. Households with incomes less than 80 percent of median income are considered low and moderate income and eligible for assistance with funds from the CDBG program.

While the program uses these income thresholds to determine whether persons or households are eligible for the program, the formula uses the constant dollar standard of poverty to allocate funds. CDBG nonentitlement grantees share an average poverty rate of 12 percent. Similarly, 11 percent of CDBG nonentitlement grantee households have extremely low incomes, as defined by having incomes less than 30 percent of their area median income. 37

Table 5-6 shows that some regions are probably undercounted in terms of need associated with low-income households while others probably are overcounted. Specifically, states in the New England region on average have more extremely low-income persons than is represented by poverty. On the other hand, Puerto Rico, the states in the Southwest

37 Data on number of households less than 30 percent of local median income are from a special tabulation of 2000 census data prepared for HUD by the U.S. Census Bureau using the Section 8 income limits.

CDBG Formula Targeting to Community Development Need 60 region, and the states in the Pacific region have poverty rates that exceed their rate of extremely low-income households. This suggests that using poverty as a single measure to allocate CDBG funds likely understates the need in the New England region while overstating the need in Puerto Rico, the Southwest, and the Pacific.

Table 5-6 Comparing Poverty Rate to Extremely Low Income Rate by Region for Nonentitlement Areas

Region N Poverty Rate Extremely Low Income Rate New England 6 6% 10% New York/New Jersey 2 9% 10% Mid-Atlantic 5 11% 10% Southeast 8 14% 12% Midwest 6 8% 9% Southwest 5 16% 12% Great Plains 4 10% 10% Rocky Mountain 6 11% 10% Pacific/Hawaii 4 15% 12% Northwest/Alaska 4 12% 10% Puerto Rico 1 55% 24% TOTAL 51 12% 11%

2. Off-campus college students in poverty do not pose as significant a problem for nonentitlements but their inclusion does cause some small difference in funding between states.

Pre-1940 Housing

In declining areas of states, old housing likely will be demolished or abandoned over time, while more affluent areas renovate the old housing. As a result, pre-1940 housing in nonentitlement areas has weakened over time as a measure of community development need.

Summary

The nonentitlement formula targets very well to the community development need of Puerto Rico. For the remaining 50 states, however, very little relationship exists between a state’s level of community development need and its current per capita grant formula allocation.

CDBG Formula Targeting to Community Development Need 61 Chapter 6. CDBG Alternative Formulas

This chapter provides three options for modifying the Community Development Block Grant (CDBG) entitlement formula allocation and two options for modifying the CDBG nonentitlement formula. The funding implications associated with each option are also explained. All of these alternatives assume that the funding split between entitlements and nonentitlements would be held constant at 70/30. Chapter 8 describes making changes to the 70/30 split, including using a single formula for both entitlements and nonentitlements. Chapter 9 explains how the entitlement and nonentitlement options from this chapter and the single formula option in Chapter 8 are combined into four overall alternative formulas.

Goals for Formula Alternatives

Developing a funding formula requires an understanding of the program’s goals. The alternatives in this chapter are based on three goals:

1. Improve Targeting to community development need. Chapters 4 and 5 demonstrate how the formula has substantial inequities in how it targets to community development need. All the alternatives suggested are based on the presumption of wanting to decrease or eliminate the number of funding inequities in the current formula.

2. Simplify the formula. The current formula is quite complicated, difficult to explain, and somewhat difficult to administer. A simplified formula would allow the allocations to be more transparent and possibly create a greater sense of fairness.

3. Minimize redistribution of funds. The goal of most block grant programs is to enable jurisdictions to have a steady and predictable flow of resources to address program objectives. Any change to the CDBG formula will cause a redistribution of funds and thus increase or decrease that predictable flow of resources. Jurisdictions that lose funds are likely to experience a painful adjustment period.

Summarizing Entitlement Formula Alternatives

All three formula alternatives explained below improve targeting to need. The alternatives presented offer policymakers various degrees of tradeoffs among the three goals stated above. Basically, the alternatives presented do the following:

Entitlement Alternative 1. This alternative “tweaks” or makes minor adjustments to the existing formula by correcting the problems in Formulas A and B that lead to large inequities in funding among grantees in each formula. For example, pre-1940 housing is replaced by “housing older than 50 years occupied by a person in poverty.” It does not, however, correct the funding inequities between Formulas A and B. This option causes the least redistribution of funds but makes the formula even more complicated than it is currently. It is similar to the alternative presented in 1995 by Neary and Richardson.

CDBG Formula Targeting to Community Development Need 62 Entitlement Alternative 2. This alternative creates a very simple single formula. The formula uses four widely available and easily understandable variables to allocate the funds. The variables are poverty, female-headed households with children, housing older than 50 years occupied by a household in poverty, and overcrowding. This option dramatically improves targeting to need, including correcting funding inequities between Formulas A and B. It only modestly increases the slope of the allocation, however. By improving fairness in the funding allocation without raising the slope, some very needy Formula B communities experience significant funding decreases. For example, Detroit’s grant is reduced from $49 per capita to $38 per capita to align it with similarly needy Miami, whose grant increases from $28 per capita to $41 per capita.

Entitlement Alternative 3. This alternative adds an adjustment factor to entitlement alternative 2. It uses the same four variables as entitlement alternative 2 but shifts the weights on some variables and adds an adjustment factor that assigns extra weight to fiscal stress. This alternative raises the weight on older housing occupied by a poverty household and reduces the weight on overcrowding, as compared to alternative 2, to put additional emphasis on places facing age and decline problems versus locations with growing immigrant populations. It also adjusts grants upwards for jurisdictions with a low per capita income relative to their metropolitan per capita income and adjusts grants downwards for jurisdictions with a high per capita income relative to their metropolitan per capita income. Overall, this increases the amount of funds the more needy grantees receive at the expense of the least needy grantees and benefits several of the older declining cities. For example, Detroit’s grant increases to $51 per capita while Miami’s increases to $44 per capita, Newport Beach’s per capita grant, however, falls to $3 per capita; its current grant is $6 per capita, and its alternative 2 grant is $4 per capita.

All three alternatives improve targeting to need but also significantly redistribute funds. Alternative 3 provides the largest redistribution of funds, while alternative 1 offers the smallest.

Entitlement Alternative 1—Tweaking the Current Formula

Alternative 1 is based on the analysis in Chapter 4 that identifies the significant problems of each of the dual formulas. Alternative 1 does not correct the historic inequities in funding between Formulas A and B; it simply corrects the anomalies in each formula.

Formula A

The problems with Formula A, as detailed in Chapter 4, and the solutions recommended for alternative 1 are as follows:

1. Problem: Low slope. The more needy a Formula A grantee, the more underfunded it is relative to its need.

Solution: Reduce the weight on population from 0.25 to 0.10, and increase the weight on poverty to 0.60 and on overcrowding to 0.30.

CDBG Formula Targeting to Community Development Need 63 Analysis: Population does not target to need; it simply targets to population regardless of need. Poverty and overcrowding are both good indicators of need among Formula A grantees.

2. Problem: College students in poverty. Although full-time college students are generally supported by their family, the Census Bureau reports them as being in poverty. 38

Solution: Change the definition of poverty to “persons living in family households or elderly-headed households living in poverty.”

Analysis: This corrects the formula so that college towns no longer receive disproportionately large allocations relative to their actual level of community development need.

Formula B

The problems with Formula B, as detailed in Chapter 5, and the solutions recommended for alternative 1 are as follows:

1. Problem: Pre-1940 housing occupied by higher income households. As time has passed, needy communities have demolished pre-1940 housing while less needy places have renovated their older housing.

Solution: Replace the variable with “housing 50 years or older occupied by a poverty household.”

Analysis: This new variable targets to needy cities with older infrastructure and dilapidated housing.

2. Problem: College students in poverty. As in the description in Formula A, full-time college students are often counted as being in poverty when they actually do have a source of support not captured by the census—their families.

Solution: Change the definition of poverty to “persons living in family households or elderly-headed households living in poverty.”

Analysis: This corrects the formula so that college towns no longer receive disproportionately large allocations relative to their actual level of community development need.

3. Problem: Less needy places with population loss or slow growth. Growth lag funds communities whose populations since 1960 are growing at a slower pace than the national growth rate for entitlement cities. Some of these communities were built out in

38 Students living in dormitories are not counted in the current census population counts on poverty; students living in housing units, however, are counted.

CDBG Formula Targeting to Community Development Need 64 1960, however, and intentionally implement policies to discourage growth, simply have no more land for growth, or have had a large decrease in household size even though they are economically very strong.

Solution: Reduce growth lag funding for communities with high per capita incomes and low poverty rates. Specifically, reduce a community’s growth lag score if its per capita income is greater than 125 percent of the national per capita income, and its poverty rate (using the new definition of poverty) is less than 75 percent of the average for entitlement communities. If a community’s per capita income is more than 125 percent of the national per capita income, its growth lag is reduced according to its poverty rate. A poverty rate of 75 percent of the average for entitlement communities receives full funding while a poverty rate of 50 percent of the average gets no funding. For communities with poverty rates between 50 and 75 percent, the reduction is proportional.

Analysis: This reduces high funding to most low-need communities created by growth lag, which otherwise targets well to need.

4. Problem: Extremely high per capita grants due to growth lag. Because of growth lag, a number of very needy grantees receive very large per capita grants that are well above their needs-index-based funding level.

Solution: Reduce the weight on growth lag from 20 percent to 10 percent, and increase the weight on poverty from 30 percent to 40 percent.

Analysis: This tends to make funding levels for Formula B communities with similarly high needs more similar.

These adjustments significantly improve the targeting of the formula to need. Chart 6-1, as compared to Chart 4-2, shows that alternative 1 has fewer anomalies, especially regarding overfunding the least needy grantees. The left side of the chart demonstrates this by the per capita grants for alternative 1 clustered fairly close to the needs index line. Big differences in per capita allocations continue to exist between higher need, similar needy grantees; the increasingly larger spikes on the right side of the chart illustrate this.

CDBG Formula Targeting to Community Development Need 65

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Alternative 1 Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart 6-1. Alternative 1 Targeting to Need

Chart 6-2 and Table 6-1 show that alternative 1’s slope for Formula A grantees is closer to the desired slope, moving the more needy Formula A grantees much closer to the needs line than currently. At the same time, the r-square increases for Formula B by “trimming” some of the anomalies.

Table 6-1. Regression Estimate of Targeting to Need by Overall and by Formula for Alternative 1

Targeting to: Overall Formula A Formula B R-square 0.645 0.929 0.599 Slope 11.5 8.9 12.8 Places (unweighted) Constant 17.2 13.8 20.8 R-square 0.777 0.948 0.711 Slope 11.9 9.3 12.6 People (weighted on population) Constant 16.4 14.1 19.5

CDBG Formula Targeting to Community Development Need 66

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Split by A and B Pe r C a p i t a Gra n t B Alternative 1 B Need A Alternative 1 A Need Low Need High Need

Chart 6-2. Alternative 1 Targeting to Need by Formulas A and B

Entitlement Alternative 2—Arriving at the Best Simple Formula for Targeting To Need

Alternative 2 is a new formula. The goal was to target well to the needs index using a simple formula. To achieve this goal, this analysis took these steps:

null Identify the variables available for each jurisdiction that explain the most variance in the needs index.

null Weight those variables by regressing them against an “allocation” that uses the needs index

Identifying the Variables

As explained in Chapter 3, the needs index for entitlement communities comprises 17 variables. This study used factor analysis to identify which variables had similar patterns of variance and extract that variance to create individual factors. That analysis produced three factors.

To identify variables for the alternative 2 formula, the variables that correlated the highest with each of the three factors from the needs index were identified. If several variables correlated highly with a factor, those variables with relatively low correlation with one another were identified.

CDBG Formula Targeting to Community Development Need 67

Table 6-2 shows the 17 variables used to create the needs index and how each one correlates with factor 1, from highest to lowest correlation. The right side of the table shows the variables identified as having high correlation with factor 1 but relatively low correlation with one another. That is, factor 1 correlates best with poverty (A), but it also correlates well with female-headed households with children (B) and pre-1950 poverty households (C), both of which have relatively low correlations with poverty given that they all correlate well with factor 1. Poverty is a particularly good measure of unemployment, concentrated poverty, and lower education levels.

Although poverty and female-headed households with children correlate with one another at only 0.54, they both have relatively good correlations with the crime measure, 0.64 and 0.66 respectively. This report contends that when combined, these factors offer a valid proxy for distress measured by crime. Pre-1950 housing occupied by a poverty household, although correlated with poverty at only 0.48, is a very good indicator of population loss since 1960 and, to a lesser extent, population loss since 1990. Although pre-1950 poverty housing and female- headed households with children have a relatively high correlation with one another, 0.72, the strength of female-headed households with children under 18 at targeting toward crime and the pre-1950 poverty variable’s strength at targeting toward population loss leads to including both as formula variables.

Table 6-2. Variables Correlating Well With Factor 1

Community Development Need Measures Factor 1 (A) Poverty Rate for Persons in Family and Elderly Households (B) Female- Headed Households With Children Under 18 (C) Pre-1950 Housing Occupied by Poverty Household Factor 1 1.00 0.91 0.74 0.73 Poverty rate for persons in family and elderly households, 2000 0.91 1.00 0.54 0.48 Unemployment rate, 2000 0.86 0.87 0.52 0.50 Pre-1970 housing occupied by poverty renter, 2000 0.86 0.61 0.78 0.91 Employed population age 16––64, 2000 –0.84 –0.89 –0.38 –0.40 Population age 25–64 without high school education, 2000 0.78 0.75 0.33 0.36 Female-headed households with children under age 18, 2000 0.74 0.54 1.00 0.72 Pre-1950 housing occupied by poverty household, 2000 0.73 0.48 0.72 1.00 Metropolitan Statistical Area (MSA) dissimilarity index multiplied by percent minority, 2000 0.72 0.61 0.37 0.29 Homicides, assaults, robberies per 1000 persons, 2001, Department of Justice Uniform Crime Reports (UCR) 0.71 0.64 0.66 0.46 Net per capita income change 1989 to 1999 –0.68 –0.57 –0.44 –0.38 Local per capita income/per capita income of MSA, 2000 –0.67 –0.41 –0.47 –0.44 Population loss since 1960 0.52 0.25 0.51 0.70 Concentrated poverty,* 2000 0.49 0.78 0.25 0.17 Overcrowded housing units, 2000 0.48 0.49 –0.07 –0.02 Persons per square mile, 2000 0.43 0.14 0.12 0.33 Population loss since 1990 0.43 0.22 0.48 0.53 Point change in poverty rate, 1990–2000 0.02 –0.40 –0.07 –0.03 *Percent of poor persons in jurisdictions concentrated in census tracts with more than 40 percent poverty.

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need 68

Factor 2 correlates best with overcrowding as a needs indicator (0.78). It also correlates well with places that are not losing population: –0.64 for population loss since 1960 and –0.62 for population loss since 1990. Population gain is a good measure of need only to the extent that population gain is creating fiscal stress, such as with the growth in number of low-wage immigrants; overcrowding captures this extremely well. Population gain without capturing the low-wage or poverty component of that growth is most likely an indicator of fiscal health than fiscal stress.

Table 6-3. Variables Correlating Well With Factor 2

Factor 2 Overcrowding Factor 2 1.00 0.78 Overcrowded housing units, 2000 0.78 1.00 Population loss since 1960 –0.64 –0.15 Population loss since 1990 –0.62 –0.15 Pre-1950 housing occupied by a poverty household, 2000 –0.49 –0.02 Population age 25–64 without a high school education, 2000 0.46 0.77 Female-headed households with children under age 18, 2000 –0.45 –0.07 MSA dissimilarity index multiplied by percent minority, 2000 0.40 0.68 Persons per square mile, 2000 0.33 0.45 Point change in poverty rate 1990 to 2000 0.32 0.02 Pre-1970 housing occupied by a poverty renter household, 2000 –0.31 0.18 Netper capita income change 1989 to 1999 –0.24 –0.43 Population age 16–64 employed, 2000 –0.21 –0.57 Local per capita income /per capita income of MSA, 2000 –0.14 –0.36 Poverty rate for persons in family and elderly households, 2000 0.05 0.49 Unemployment rate, 2000 0.02 0.44 Concentrated poverty*, 2000 –0.06 0.28 Homicides, assaults, robberies per 1000 persons, 2001, UCR –0.11 0.21 *Percent of poor persons in jurisdictions concentrated in census tracts with more than 40 percent poverty

Finally, factor 3 is an indicator of need for communities with high poverty concentrations but declining poverty rates. Poverty concentration could be potentially a good variable for the formula. It would have a similar problem to the growth lag variable of the current formula, however, specifically targeting large amounts of money to a few places. It would also have some regional bias in favor of very low cost-of-living jurisdictions, such as entitlement jurisdictions in Puerto Rico, where poverty rates are much higher than the rates of extreme low-income households. For these reasons, no variables based on factor 3 are included among the proposed formula variables. 39

39 See Table 3-7 for the correlations of the variables with factor 3.

CDBG Formula Targeting to Community Development Need 69 That leaves four variables for a simple entitlement formula:

null Family and elderly persons in poverty. null Female-headed households with children. null Housing built before 1950 occupied by a poverty household. null Overcrowding.

Weighting the Variables

The next step in the process is to weight these variables so that they best target to the needs index, a relatively simple exercise. As previous charts demonstrated, the needs index scores are already converted to per capita grant amounts. These per capita grant amounts are then multiplied by population to convert them to actual grant amounts. 40 Then, the grant amounts that individual jurisdictions would receive if funds were allocated only by the variable persons in family or elderly poverty households is calculated. Similar allocations are derived using female- headed households with children, housing built before 1950 occupied by poverty households, and overcrowding. A regression is run with the needs score grant calculation as the dependent variable and the four variables identified above as the independent variables. The result is as follows:

R 2 = 0.997

Family and elderly person in poverty = 0.529 Female-headed households with children = 0.128 Housing built before 1950 occupied by a poverty household = 0.185 Overcrowding =0 .196

Rounding these factors creates the following formula:

[0.5 Povfam (a) + 0.1 FHH (a) + 0.2 AgePov (a) +0 .2 Ocrowd (a) ] * Appropriations Povfam (ENT) FHH (ENT) AgePov (ENT) Ocrowd (ENT)

where: null (a) is the value for the jurisdiction. null (ENT) is the value for all entitlement jurisdictions (cities and urban counties). null Povfam is the number of persons in poverty living in family or elderly households. null FHH is the number of female-headed households with children. null AgePov is the number of housing units older than 50 years occupied by a poverty household. null Ocrowd is overcrowding.

In addition to departing from a dual formula, alternative 2 also changes the denominator from the sum of all metropolitan areas to the sum of all entitlement jurisdictions. The sum of all metropolitan areas made sense with a dual formula system because it meant that neither of the

40 To capture the universe of CDBG grantees, this study estimated needs scores for the 123 jurisdictions that do not have need scores under the standard need calculation. This is done with factor analysis that excludes (1) crime rates and (2) the dissimilarity index multiplied by the percent minority factors.

CDBG Formula Targeting to Community Development Need 70 dual formulas were allocating the full appropriation amount since the sum of the numerator—all entitlements—was less than the sum of the denominator—all metropolitan areas. With neither of the two formulas allocating all the appropriation, this reduced the amount of pro rata reduction needed to bring the “greater of” component of the dual formula in line with the actual appropriation. With a single formula, if a metropolitan total denominator is used, it is necessary to implement a pro rata increase to match the appropriation level. The need for a pro rata increase is avoided by simply allocating the funds based on a denominator that is the sum of the data for only the jurisdictions receiving funding.

As Chart 6-3 shows, this very simple formula allocates very well to need. In addition to dramatically reducing the number of anomalies in the formula, it also modestly increases the slope of the overall allocation, and it corrects for the historic inequities in funding between Formulas A and B grantees. This correction, however, comes at a significant cost to most Formula B communities, many with high community development need.

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Alternative 2 Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart 6-3. Alternative 2 Targeting to Need

Table 6-4 shows several very needy Formula A grantees and Formula B communities and demonstrates how the alternative 2 formula increases funding for the very needy Formula A communities but at some cost to the very needy Formula B communities. All but two of the needy Formula B communities listed in Table 6-4 have a funding decrease as a result of alternative 2. Table 6-8, later in this chapter, compares the overall funding redistribution caused by this alternative when compared to alternatives 1 and 3.

CDBG Formula Targeting to Community Development Need 71

Table 6-4. Comparing Impact of Alternative 2 on Needy Formula A and Formula B Grantees

Per Capita Grant High Need Formula A Grantees Needs Score Current Formula Alternative 2 Percent Change Hidalgo County, TX 2.58 $31.98 $45.84 43 Miami, FL 2.11 $27.94 $40.78 46 Santa Ana, CA 1.88 $25.25 $30.75 22 Long Beach, CA 1.44 $23.29 $33.33 43 Los Angeles, CA 1.43 $23.96 $33.06 38 Fresno, CA 1.42 $21.93 $31.22 42 Kern County, CA 1.05 $18.73 $26.00 39 El Paso, TX 0.93 $18.59 $27.08 46 Memphis, TN 0.91 $15.43 $24.94 62 Houston, TX 0.80 $18.93 $24.82 31 Per Capita Grant High Need Formula B Grantees Needs Score Current Formula Alternative 2 Change Newark, NJ 2.55 $40.08 $38.40 –4 Detroit, MI 2.12 $48.91 $38.44 –21 Cleveland, OH 1.68 $61.81 $39.18 –37 Baltimore, MD 1.60 $44.28 $31.46 –29 St Louis, MO 1.56 $72.97 $36.38 –50 New York, NY 1.54 $27.77 $34.05 23 Buffalo, NY 1.54 $68.15 $41.18 –40 Philadelphia, PA 1.50 $42.03 $34.41 –18 New Orleans, LA 1.48 $37.55 $38.05 1 Chicago, IL 1.32 $35.35 $29.34 –17

Alternative 3—Arriving at a Formula More Sharply Targeted to Need

As noted above, some very needy Formula B communities experience significant funding decreases using alternative 2. This is because correcting the Formula A and Formula B funding inequities means increasing grants for a large number of Formula A communities. This is true for both very needy and not-so-needy communities. Across the need spectrum, alternative 2 increases funding for Formula A at the expense of Formula B. Alternative 3 adjusts the alternative 2 approach so that very needy grantees receive larger per capita grants, and less needy grantees get smaller grants. Alternative 3 also make some adjustments to prevent very needy Formula B grantees from being as adversely impacted by the formula change in alternative 2.

Adjustment 1. Chapter 3 noted that the needs index is underrepresented in variables that measure decline relative to previous needs indexes. In addition, the CDBG statute clearly emphasizes the distress associated with decline more than it does the fiscal stress associated with immigrant

CDBG Formula Targeting to Community Development Need 72 growth. These arguments justify a shift in the weighting to provide 30 percent of the funds on old housing with a poverty household variable (a 10-point weight increase) and 10 percent of the funds on overcrowding (reducing the weight 10 points). This also results in a shift, relative to alternative 2, of more funds to the very needy Formula B communities.

Adjustment 2. To more sharply target funds to the neediest communities in each metropolitan area, applying an adjustment factor that increases grants for jurisdictions with low per capita incomes relative to their metropolitan area per capita income substantially increases the slope of the allocation. To ensure that this adjustment does not create anomalies, it is capped to prevent any jurisdiction’s grant from being increased or decreased by more than 25 percent. Employing this adjustment results in an overall increase in allocations such that a pro rata reduction must be used to keep the formula allocation within appropriation.

Applying these adjustments substantially increases the slope of the formula allocation relative to both the current formula and alternative 2, but with a modest sacrifice in targeting to need. The loss in targeting to the needs index is due almost entirely to shifting the weight from overcrowding to the old housing with poverty household variable. As noted above, however, the needs index probably understates the need of communities in decline. Chart 6-4 shows more variance from the needs index line relative to alternative 2, but this is primarily to benefit the most needy grantees.

$0 $10 $20 $30 $40 $50 $60 $70 Entitlement Grantees Per Capita Grant Alternative 3 Per Capita Grant Needs Index Per Capita Grant (slope 12.0) Low Need High Need

Chart 6-4. Alternative 3 Targeting to Need

CDBG Formula Targeting to Community Development Need 73

Table 6-5 indicates that, as with alternative 2, all the very needy Formula A communities gain funding under alternative 3. Unlike alternative 2, however, most of the very needy Formula B grantees also gain funding. Four do lose funding, but not as much as they would with alternative 2.

Table 6-5. Comparing Impact of Alternative 3 on Needy Formula A and Formula B Grantees

Per Capita Grant High Need Formula A Grantees Needs Score Current Formula Alternative 3 Percent Change Hidalgo County, TX 2.58 $31.98 $48.82 53 Miami, FL 2.11 $27.94 $43.80 57 Santa Ana, CA 1.88 $25.25 $28.78 14 Long Beach, CA 1.44 $23.29 $31.49 35 Los Angeles, CA 1.43 $23.96 $28.27 18 Fresno, CA 1.42 $21.93 $28.13 28 Kern County, CA 1.05 $18.73 $24.07 29 El Paso, TX 0.93 $18.59 $22.54 21 Memphis, TN 0.91 $15.43 $27.35 77 Houston, TX 0.80 $18.93 $22.75 20 Per Capita Grant High Need Formula B Grantees Needs Score Current Formula Alternative 3 Percent Change Newark, NJ 2.55 $40.08 $47.77 19 Detroit, MI 2.12 $48.91 $50.67 4 Cleveland, OH 1.68 $61.81 $54.38 –12 Baltimore, MD 1.60 $44.28 $42.12 –5 St. Louis, MO 1.56 $72.97 $49.56 –32 New York, NY 1.54 $27.77 $35.88 29 Buffalo, NY 1.54 $68.15 $58.47 –14 Philadelphia, PA 1.50 $42.03 $46.95 12 New Orleans, LA 1.48 $37.55 $43.31 15 Chicago, IL 1.32 $35.35 $36.59 4

Table 6-6 shows the overall redistribution of funds caused by the three alternative formulas by needs decile. Both alternatives 1 and 3 move significant funds from the least needy to the most needy grantees, while alternative 2 generally reduces funding for the least needy. Because alternative 2 corrects the funding anomalies between Formula A and Formula B, however, the more needy grantees receive relatively smaller funding increases.

CDBG Formula Targeting to Community Development Need 74 Table 6-6. Fund Redistribution by Needs Decile

Per Capita Grant Amount Percent Change from Current Percentiles of CD Need N Current Alternative 1 Alternative 2 Alternative 3 Alternative 1 Alternative 2 Alternative 3 Low 89 $7.83 $5.26 $5.75 $4.33 –33 –27 –45 2 90 $9.28 $7.54 $7.86 $6.51 –19 –15 –30 3 90 $11.39 $8.75 $9.17 $8.27 –23 –19 –27 4 90 $12.27 $11.27 $11.64 $10.71 –8 –5 –13 5 90 $14.09 $13.37 $13.67 $13.19 –5 –3 –6 6 90 $15.52 $14.80 $15.95 $15.27 –5 3 –2 7 90 $17.77 $17.16 $17.77 $17.51 –3 0 –1 8 90 $18.70 $20.40 $21.06 $20.61 9 13 10 9 90 $25.72 $26.67 $25.42 $27.20 4 –1 6 High 90 $32.27 $35.99 $33.68 $37.38 12 4 16 Total 899 $17.87 $17.85 $17.69 $17.94 Most/Least 4.1 6.8 5.9 8.6 Note: Per capita grants weighted on population.

Table 6-7 shows the regression coefficients for the formula alternatives in targeting to the needs index. All the alternatives dramatically improve targeting to the needs index, with alternative 2 offering the optimal fairness and alternative 3 providing the largest allocations— that is, the highest slope—to the most needy grantees.

Table 6-7. People and Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.352 0.645 0.891 0.794 Slope 8.8 11.5 10.4 12.8 Places (unweighted) Constant 18.1 17.2 16.6 17.3 R-square 0.525 0.777 0.947 0.857 Slope 9.5 11.9 10.8 12.8 People (weighted on population) Constant 16.8 16.4 16.4 16.4 N=899 for all regressions

Table 6-8 shows the overall redistribution of funds by percent of jurisdictions losing funds and gaining funds. As expected, if jurisdictions in the least needy category are losing an average of 30 to 45 percent of their funds, all these alternatives result in a large number of grantees that lose funding and a large number that gain funding. Alternative 1 results in fewer very large losers and fewer very large winners than the other alternatives because it is not correcting the gap in funding between similar needy Formula A and Formula B grantees.

CDBG Formula Targeting to Community Development Need 75

Table 6-8. Percent of Entitlement Grantees Gaining/Losing Funds by Formula Alternative

Alternative 1 Alternative 2 Alternative 3 Loss greater than 40 5.5 12.0 13.4 Loss 20 to 40 15.1 14.4 17.6 Loss 10 to 20 15.7 8.9 12.0 Loss 0 to 10 19.6 12.6 11.6 Gain 0 to 10 18.8 12.3 11.2 Gain 10 to 20 13.8 10.8 9.2 Gain 20 to 40 10.4 17.3 13.8 Gain greater than 40 1.1 11.7 11.2 Total 100.0 100.0 100.0 N=1024

Table 6-9 shows the fund redistribution by region. Generally speaking, the New England region loses the most and Puerto Rico gains the most under all these alternatives. Interestingly, alternatives 1 and 3 have similar patterns of regional redistribution.

Table 6-9. Fund Redistribution by Region

Per Capita Grant Amount Percent Change from Current Region N Current Alternative 1 Alternative 2 Alternative 3 Alternative 1 Alternative 2 Alternative 3 New England 73 $28.02 $23.01 $19.52 $24.37 –18 –30 –13 New York/New Jersey 96 $20.88 $20.75 $20.44 $21.82 –1 –2 5 Mid-Atlantic 87 $19.59 $17.51 $14.38 $16.28 –11 –27 –17 Southeast 164 $12.62 $13.34 $14.93 $14.04 6 18 11 Midwest 187 $18.93 $17.38 $15.10 $17.43 –8 –20 –8 Southwest 106 $15.17 $17.15 $19.20 $17.66 13 27 16 Great Plains 30 $17.77 $15.59 $14.02 $15.42 –12 –21 –13 Rocky Mountain 37 $11.49 $10.54 $11.40 $11.05 –8 –1 –4 Pacific/Hawaii 183 $15.94 $17.52 $18.90 $16.41 10 19 3 Northwest/Alaska 40 $12.60 $11.08 $11.89 $11.25 –12 –6 –11 Puerto Rico 21 $30.51 $40.29 $46.15 $39.92 32 51 31 Note: Per capita grants weighted on population.

Alternative 3’s second adjustment combined with pro rata reduction associated with alternative 3 tends to benefit poor jurisdictions in high cost-of-living locations, such as New England, at the expense of all the jurisdictions in places with lower costs of living, like the entitlement communities in the Puerto Rico region. This tends to correct for the bias in alternative 2 that favors places with very low costs of living over places with higher costs of living.

CDBG Formula Targeting to Community Development Need 76 Summarizing Nonentitlement Formula Alternatives

For nonentitlement communities, this report offers only two alternatives: one that tweaks the current formula and a simple alternative with three variables.

Nonentitlement Alternative 1. As with the entitlement alternative 1, this alternative makes minor adjustments to the existing formula by resolving the problems in Formulas A and B that lead to large inequities in funding among grantees under each formula. For example, pre-1940 housing is replaced by “housing older than 50 years occupied by a person in poverty.”

Nonentitlement Alternative 2. This alternative creates a very simple, single formula. The formula uses three widely available and easy-to-understand variables to allocate the funds. The variables are poverty, female-headed households with children, and housing older than 50 years occupied by a person in poverty.

Nonentitlement Alternative 1—Tweaking the Formula

Alternative 1 uses the analysis in Chapter 5 to identify the key problems of each of the dual formulas.

Formula A

The problems with Formula A, as detailed in Chapter 5, and the solutions recommended are as follows:

1. Problem: Low slope due to population variable.

Solution: Reduce the weight on population from 25 percent to 10 percent, and increase the weight on poverty to 65 percent.

Analysis: Population does not target to need; it simply targets to population regardless of need. Poverty is a good indicator of need among Formula A grantees.

2. Problem: College students in poverty. Although full-time college students living in nonfamily situations (off-campus housing, fraternities and sororities) are generally supported by their family, the census reports them as being in poverty.

Solution: Change the definition of poverty to “persons living in family households or elderly-headed households living in poverty.” This solution is also applies for the definition of poverty used in Formula B.

Analysis: This corrects the formula so that nonentitlements with significant college student populations no longer receive disproportionately large allocations relative to their actual level of community development need.

CDBG Formula Targeting to Community Development Need 77 Formula B

1. Problem: Pre-1940 housing occupied by higher income households. As time has passed, needy places have demolished pre-1940 housing while less needy locations have renovated their old housing.

Solution: Replace the variable with “housing 50 years or older occupied by a poverty household.”

Analysis: This new variable targets better to nonentitlement areas with older infrastructure and dilapidated housing that generally do not have the resources to address that need.

2. Problem: College students in poverty. See explanation under Formula A.

3. Problem: Low slope due to population variable.

Solution: Reduce the weight on population from 20 percent to 10 percent, and increase the weight on poverty to 40 percent.

Analysis: Population does not target to need; it simply targets to population regardless of need. Poverty is a good indicator of need.

Chart 6-5 shows the targeting to need as a result of these changes. A tremendous improvement in targeting is evident, with the alternative 1 per capita grants of nonentitlements tracking much more closely to the needs index than the current formula.

CDBG Formula Targeting to Community Development Need 78

$0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Per Capita Grant Alternative 1 Per Capita Grant Need (Slope 8.0) Low Need High Need

Chart 6-5. Nonentitlement Alternative 1 Targeting to Need

The regression analysis confirms this finding. Table 6-10 shows very clearly that the fairness (r- square) is greatly improved overall and for both Formulas A and B. The slope is also significantly improved, matching the target slope of 8.0 established with the needs index line.

Table 6-10. Regression Estimate of Targeting to Need Overall and by Formula for Nonentitlement Alternative 1

Targeting to: Overall Formula A Formula B R-square 0.838 0.838 0.905 Slope 8.1 8.6 5.7 Places (unweighted) Constant 12.5 13.0 11.7 R-square 0.851 0.861 0.886 Slope 7.9 9.0 5.4 People (weighted on population) Constant 12.1 11.8 11.5

Nonentitlement Alternative 2—Simple Formula for Targeting to Need

While alternative 1 does a very good job of improving targeting to need, nonentitlement alternative 2 is designed to improve targeting to need with a simple formula mechanism. It uses the same approach for developing a simple, single formula like that used for the entitlement alternative 2. First, a set of variables that correlate well with the needs index factors were identified, and then regression analysis was employed to weight those variables.

CDBG Formula Targeting to Community Development Need 79 Identifying the Variables

Table 6-11 shows the 10 variables used to create the nonentitlement needs index and how each one correlates with factor 1, from highest correlation to lowest correlation. Factor 1 correlates best with poverty, and poverty correlates well with unemployment, low education, concentrated poverty, and overcrowding.

Table 6-11. Variables That Correlate Well With Nonentitlement Factor 1

Community Development Need Measures Factor 1 Poverty Rate for Persons in Family and Elderly Households Factor 1 1.000 0.980 Poverty rate for persons in family and elderly households, 2000 0.980 1.000 Population age 16–64 employed, 2000 –0.959 –0.926 Unemployment Rate, 2000 0.933 0.908 Concentrated poverty, 2000* 0.864 0.908 Population age 25–64 without a high school education, 2000 0.846 0.819 Overcrowded housing units, 2000 0.804 0.759 Pre-1970 housing occupied by a poverty renter household, 2000 0.595 0.579 Female-headed households with children under age 18, 2000 0.564 0.478 Pre-1950 housing occupied by a poverty household, 2000 0.098 0.153 Percent households that heat with wood or bottled gas, 2000 0.067 0.077 *Percent of poor persons in jurisdictions concentrated in census tracts with more than 40 percent poverty.

Table 6-12. Variables Correlating Well With Nonentitlement Factor 2

Community Development Need Measures Factor 2 Pre-1950 Housing Occupied by Poverty Household Factor 2 1.000 0.969 Pre-1950 housing occupied by a poverty household, 2000 0.969 1.000 Pre-1970 housing occupied by a poverty renter household, 2000 0.731 0.741 Percent households that heat with wood or bottled gas, 2000 0.236 0.117 Population age 16–64 employed, 2000 0.119 0.013 Poverty rate for persons in family and elderly households, 2000 0.045 0.153 Concentrated poverty, 2000* 0.042 0.160 Female-headed households with children under age 18, 2000 –0.040 –0.066 Population age 25–64 without a high school education, 2000 –0.091 –0.052 Unemployment rate, 2000 –0.118 0.012 Overcrowded housing units, 2000 –0.375 –0.261 *Percent of poor persons in jurisdictions concentrated in census tracts with more than 40 percent poverty.

CDBG Formula Targeting to Community Development Need 80 As Table 6-12 shows, factor 2 has its high correlation with pre-1950 housing occupied by a poverty household; that correlates well with pre-1970 housing occupied by a poverty renter household.

Finally, factor 3 approximates infrastructure need and, as Table 6-13 shows, correlates best with units that heat with wood or bottled gas. Its next best correlation, 0.594, is with female-headed households with children. Because of the concern that using the proxy variable of heating with wood or bottled gas will create anomalies in funding due to likely regional bias, this report does not recommend its use. On both factors 1 and 3, however, female-headed households with children have moderately high correlations with the factors but not high correlation with either poverty or pre-1950 housing occupied by a poverty household. This suggests that some elements of community development need in nonentitlement areas that are not captured by poverty or pre- 1950 housing occupied by a person in poverty is captured by the variable female-headed households with children.

Table 6-13. Variables Correlating Well With Nonentitlement Factor 3

Community Development Need Measures Factor 3 Percent Households that Heat With Wood or Bottled Gas Female- headed Households with Children Under 18 Factor 3 1.000 0.761 0.594 Percent households that heat with wood or bottled gas, 2000 0.761 1.000 0.184 Female-headed households with children under age 18, 2000 0.594 0.184 1.000 Population age 25–64 without a high school education, 2000 0.280 0.111 0.652 Unemployment rate, 2000 –0.213 –0.054 0.371 Concentrated poverty, 2000* –0.184 0.073 0.281 Overcrowded housing units, 2000 –0.166 –0.017 0.306 Pre-1950 housing occupied by a poverty household, 2000 –0.153 0.117 –0.066 Pre-1970 housing occupied by a poverty renter household, 2000 –0.085 0.068 0.328 Poverty rate for persons in family and elderly households, 2000 –0.047 0.077 0.478 Population age 16–64 employed, 2000 0.021 0.021 –0.530 *Percent of poor persons in jurisdictions concentrated in census tracts with more than 40 percent poverty

That leaves with three variables for a simple nonentitlement formula:

null Family and elderly person in poverty. null Housing built before 1950 occupied by a poverty household. null Female-headed households with children.

CDBG Formula Targeting to Community Development Need 81 Weighting the Variables

Next, these variables are weighted to best target to the nonentitlement needs index using regression analysis. The results are as follows:

R 2 = 0.972

Family and elderly person in poverty = 0.624 Housing built before 1950 and occupied by a poverty household = 0.292 Female-headed households with children = 0.129

Rounding the coefficients results in the following formula:

[0.6 Povfam (a) + 0.1 FHH (a) + 0.3 AgePov (a) ] * Appropriations Povfam (NENT) FHH (NENT) AgePov (NENT)

where: • (a) is the value for the jurisdiction. • (NENT) is the value for all nonentitlement jurisdictions. • Povfam is the number of persons below the poverty line living in family or elderly households. • FHH is the number of female-headed households with children. • AgePov is the number of housing units older than 50 years and occupied by a poverty household.

$0 $5 $10 $15 $20 $25 $30 $35 $40 Nonentitlement Grantees Per Capita Grant Alternative 2 Per Capita Grant Need (Slope 8.0) Low Need High Need

Chart 6-6. Nonentitlement Alternative 2 Targeting to Need

CDBG Formula Targeting to Community Development Need 82 This very simple formula targets very well to need. In addition to dramatically reducing the number of anomalies in the formula, it also increases the slope of the overall allocation. Chart 6- 6 shows this alternative formula to allocate extremely closely to the needs index. Similarly, Table 6-14 demonstrates that it targets better than alternative 1, with an r-square of 0.947. It has a lower slope than alternative 1 (7.3 compared to 8.1), however, largely because it does not allocate as much to Puerto Rico as alternative 1.

Table 6-14. People and Place Targeting With Puerto Rico

Targeting to: Current Alternative 1 Alternative 2 R-square 0.661 0.838 0.947 Slope 4.9 8.1 7.3 Places (unweighted) Constant 12.3 12.5 12.3 R-square 0.621 0.851 0.931 Slope 4.7 7.9 7.1 People (weighted on population) Constant 12.1 12.1 12.1 N=51 for all regressions

Because Puerto Rico’s need is so much greater than the other states’, when it is included, the results tend to distort how well the formula targets to the other 50 state nonentitlements. When Puerto Rico is excluded from the regression analysis, as in Table 6-15, the value of the two alternatives is clear. The current formula has almost no targeting to need (r-square = 0.294 and slope= 2.4), alternative 1 improves the targeting and slope substantially (r-square = 0.697 and slope = 5.4), and alternative 2 has the best targeting (r-square=0.909 and slope=6.2).

Table 6-15. People and Place Targeting Without Puerto Rico

Targeting to: Current Alternative 1 Alternative 2 R-square 0.294 0.697 0.909 Slope 2.4 5.4 6.2 Places (unweighted) Constant 12.0 12.1 12.1 R-square 0.281 0.790 0.900 Slope 2.2 5.4 5.8 People (weighted on population) Constant 11.8 11.8 11.9 N=50 for all regressions

Table 6-16 shows that the funding reallocation from the less needy to the most needy grantees is similar for the two alternatives. The least needy grantees would suffer decreases of 26 and 27 percent, on average, while the neediest grantees would experience gains of 23 and 19 percent. Table 6–17 shows that alternative 2 causes larger shifts in funding than alternative 1; in both cases, however, the funding gains and losses are largely in the +/–20 percent range.

CDBG Formula Targeting to Community Development Need 83 Table 6-16. Nonentitlement Fund Redistribution by Needs Quintile

Per Capita Grant Percent Change From Current Percentiles of CD Need States Current Alternative 1 Alternative 2 Alternative 1 Alternative 2 Low 10 $10.07 $7.46 $7.31 –26 –27 2 10 $11.12 $9.93 $9.77 –11 –12 3 11 $11.40 $11.12 $11.71 –2 3 4 10 $12.41 $12.90 $13.02 4 5 High 10 $15.68 $19.29 $18.68 23 19 Total 51 $12.09 $12.09 $12.09 Most/Least 1.6 2.6 2.6 Note: Per capita grants weighted on population.

Table 6-17. Percent of Nonentitlement Grantees Gaining/Losing Funds by Nonentitlement Formula Alternatives

Percent Grant Change Alternative 1 Alternative 2 Loss greater than 40% 0.0 3.9 Loss 20 to 40% 17.6 15.7 Loss 10 to 20% 17.6 27.5 Loss 0 to 10% 3.9 3.9 Gain 0 to 10% 31.4 11.8 Gain 10 to 20% 17.6 7.8 Gain 20 to 40% 11.8 23.5 Gain greater than 40% 0.0 5.9 Total 100.0 100.0 N=51

Finally, Table 6-18 shows that, just as with the entitlement formula alternatives, the New England region loses the most, followed by the Midwest and New York/New Jersey region. Most of the nonentitlement areas in these regions receive substantial funding from the pre-1940 housing variable, and shifting this variable to pre-1950 housing occupied by poverty households has a significant negative impact on those grants. The Pacific/Hawaii region gains with alternative 1 but loses under alternative 2 because of overcrowding, which is a variable under alternative 1 but is not included in alternative 2.

CDBG Formula Targeting to Community Development Need 84 Table 6-18. Regional Shifts in Funding Due to Nonentitlement Alternatives 1 and 2

Average Per Capita Grant Percent Change from Current Region States Current Alternative 1 Alternative 2 Alternative 1 Alternative 2 New England 6 $11.40 $7.93 $7.69 –30 –33 New York/New Jersey 2 $14.12 $11.26 $11.11 –20 –21 Mid-Atlantic 5 $11.45 $11.72 $12.04 2 5 Southeast 8 $10.81 $11.91 $12.97 10 20 Midwest 6 $11.09 $8.96 $9.16 –19 –17 Southwest 5 $12.81 $14.99 $15.01 17 17 Great Plains 4 $11.97 $11.04 $11.31 –8 –6 Rocky Mountain 6 $10.43 $10.77 $10.86 3 4 Pacific/Hawaii 4 $15.09 $16.97 $12.84 12 –15 Northwest/Alaska 4 $11.52 $12.12 $11.66 5 1 Puerto Rico 1 $39.89 $52.31 $43.78 31 10 Total 51 $12.09 $12.09 $12.09

CDBG Formula Targeting to Community Development Need 85 Chapter 7. Impact of New Metropolitan Area Definitions

The Office of Management and Budget’s (OMB’s) new metropolitan area (MA) definitions could potentially add 78 cities and 12 urban counties to the Community Development Block Grant (CDBG) entitlement universe. In addition, the new definitions change the denominator totals for all the entitlement variables except growth lag. Although the new definitions are in effect for the Fiscal Year (FY) 2004 allocation, not all the potential jurisdictions have elected to become entitlements. This chapter describes the potential impact of the new OMB MA definitions along with the actual impact in FY 2004 of the new definitions on the current formula.

Background

Nearly every year, additional communities become eligible for CDBG entitlement status. Table 7-1 shows the annual growth of the number of entitlement grantees since the program began in FY 1975. Over the course of 30 years, the number of entitlement communities has almost doubled from 606 in FY 1975 to 1,105 grantees in FY 2004. Chapter 2 explains the criteria for a community to become eligible as an entitlement. Basically, all center cities/principal cities, 41

other cities in MAs with populations that exceed 50,000, and counties with populations greater than 200,000 (excluding entitlement cities in the county) are eligible.

Table 7-1. Number of CDBG Entitlement Grantees FYs, 1975–2004

FY Cities Urban Counties Total Increase From Previous Year FY Cities Urban Counties Total Increase From Previous Year 1975 533 73 606 -- 1990 741 125 866 8 1976 533 75 608 2 1991 757 125 882 16 1977 546 78 624 16 1992 758 131 889 7 1978 559 81 640 16 1993 756 133 889 None 1979 562 84 646 6 1994 802 135 937 48 1980 579 85 664 18 1995 808 138 946 9 1981 583 86 669 5 1996 815 139 954 8 1982 636 96 732 63 1997 834 141 975 21 1983 637 98 735 3 1998 841 145 986 11 1984 691 104 795 60 1999 842 147 989 3 1985 707 107 814 19 2000 859 149 1008 19 1986 711 116 827 13 2001 860 153 1013 5 1987 712 115 827 None 2002 865 159 1024 10 1988 736 121 857 30 2003 875 159 1034 11 1989 737 121 858 1 2004 941 164 1105 71 .

When new entitlement communities are added to the CDBG entitlement universe, their data move from being funded from the 30 percent nonentitlement pool of funds to the 70 percent

41 The OMB metropolitan area definitions eliminate the center city concept and replace it with principal city.

CDBG Formula Targeting to Community Development Need 86 entitlement pool of funds 42 . With no change in appropriation amounts, this means that entitlements have to share the same amount of funds among more grantees, while nonentitlements keep their 30 percent share of funds but serve fewer people.

Generally, there are substantial increases in the number of grantees when either new population estimates are provided or OMB changes the definitions of MAs. Sometimes, as in FY 2004, both events occur. Population counts are updated every 1 to 3 years, depending on when the Census Bureau makes them available. Once a decade, since the 1950 decennial census, the OMB reviews and revises the MA classification standards before applying them to new decennial census data.

OMB’s new standards for MAs based on Census 2000 data went into effect in May 2003. The latest OMB revision to the MA criteria is more comprehensive than the Census 1990 revisions. The most important changes concern the substitution of counties for towns as the building block for MAs in New England and the use of principal cities instead of central cities in naming MAs. Table 7-1 shows that the combination of these new definitions and the Census Bureau’s 2002 population estimates increased the number of entitlement grantees by 71—66 cities and 5 urban counties.

New England

Since the beginning of the MA program in 1950, OMB has used towns as the building block for MAs in New England while using counties elsewhere. OMB explained its decision to change to county areas in New England as a way to improve usability to producers and users of data; this would make data for MAs in all parts of the country directly comparable. The new rule means that, for the first time in the CDBG program, county areas in New England will meet the urban county statistical eligibility test. All the land area of an urban county must be included in an MA, and its population must be at least 200,000, excluding any CDBG-designated metropolitan cities. The potential impact of this change is the addition of 12 counties in New England, qualifying collectively for up to $45 million in CDBG funding. 43

The grant allocations for these urban counties will be higher than the typical new urban county elsewhere in the country. Typically, CDBG recognition occurs when a county’s population exceeds 200,000. Most New England counties have populations much higher than the minimum, ranging from 400,000 to 1 million. Because these New England county areas do not have organized county governments to administer the Urban County program, however, they need to explore the options for creating a consortium of cities and towns to manage an Urban County CDBG grant. This means that it may be some years before all the eligible urban counties join the program. Applying the new MA criteria to Census 2000 data does not statistically qualify any new urban counties in any other regions, but because the New England counties are so large, a potential exists for their inclusion in the formula to have a major effect.

42 Except if they come out of an existing urban county. These communities only effect the allocation of the urban county they are separating from. 43 Assumes the FY 2002 appropriation level with new MA denominators. Does not include Census 2002 population estimates.

CDBG Formula Targeting to Community Development Need 87

None of the 12 New England counties that are now eligible due to the change in OMB MA definition, however, were able to organize to become grantees in FY 2004. The five new urban counties created between FY 2003 and FY 2004 were not in New England and all are a result of the new 2002 population estimates, not the change in OMB MA definition. In terms of new urban counties, the new OMB MA definitions have yet to have an impact.

Principal Cities

OMB’s new procedures emphasize urbanized areas and urban clusters as the organizing entities for MAs. OMB concluded that the identification of central cities as required by the 1990 standards for qualifying and defining areas is no longer necessary. OMB also concluded that central cities have become less dominant in the local context over time. Nevertheless, the Office recognized that specific cities are important for analytical purposes as centers of employment, trade, entertainment, and other social and economic activities. Therefore, OMB developed statistical criteria for identifying principal cities and uses these cities to name MAs.

Table 7-2. New Principal Cities by Region

Region Number Eligible Number Included in FY 2004 Allocation Amount of Impact in FY 2004 ($000) New England 3 1 $542 New York/New Jersey 4 4 $2,562 Mid-Atlantic 8 8 $3,630 Southeast 20 13 $5,624 Midwest 11 9 $6,796 Southwest 3 3 $1,223 Great Plains 3 3 $1,239 Rocky Mountain 3 3 $1,633 Pacific/Hawaii 8 5 $2,498 Northwest/Alaska 9 7 $2,566 Puerto Rico 6 6 $9,260 Total 78 62 $37,578

The CDBG statute defines the scope of the “Metropolitan City” entitlement community category as being the MA central cities plus any other city of 50,000 or more population in an MA. OMB determined that, because the CDBG program is focused on economic growth centers, substituting principal cities for central cities was an appropriate technical change and issued regulations to substitute MA principal cities for central cities in the CDBG entitlement program.

Table 7-2 shows the regional distribution of the 78 new MA principal cities that are not already CDBG metropolitan cities or part of an existing urban county, and the 62 that elected to be

CDBG Formula Targeting to Community Development Need 88 included for the FY 2004 CDBG funding allocation. 44 The 62 that elected to be included in the FY 2004 CDBG allocation receive about $37.6 million.

Because none of these locations has populations of more than 50,000, they each have a relatively small impact on the formula. Collectively, however, their impact is relatively high for a single year. For comparison, over a 10-year period between FY 1993 and FY 2002, 81 entitlements were added that had not previously been part of an urban county. Of these, 15 were urban counties and 66 were new cities. These 81 entitlements received $79.8 million in FY 2002 (Richardson, Meehan, and Kelly. 2003).

The remaining four cities that became eligible for funding in FY 2004 did so because the Census 2002 population estimates indicated that their population exceeded 50,000.

“Grandfathering”

The new MAs also move the CDBG program in a new direction on “grandfathering,” or the continued designation as a Metropolitan City entitlement grantee, even though the jurisdiction does not meet the current standards. A grandfathering requirement in CDBG retains locations as grantees when their population falls below the threshold of 200,000 for urban counties and 50,000 for cities that are not central cities. Four former central cities that retain their place in an OMB-defined MA will be added to the group of grandfathered metropolitan cities. This aspect of grandfathering is not unprecedented because the four retain their classification as being parts of an MA. Nine other CDBG metropolitan city grantees will be removed from the MA roster all together. The nine will be OMB principal cities; however, they will be in “micropolitan,” rather than metropolitan, areas. Finally, two more CDBG metropolitan cities with populations less than 50,000 will be part metropolitan and part micropolitan. Each city is in two counties, with one county retaining MA status and the other being demoted by OMB to micropolitan status. The “grandfathering” of these 11 places means that the CDBG formula will have areas represented in the numerator that are not included in the denominator of the Formula A and Formula B calculations.

Formula Denominator

Chapter 2 describes the mechanics of the CDBG formula. One component of the CDBG formula is that the allocation of funds on four of the five CDBG variables (population, poverty, pre-1940 housing, and overcrowding) is based on a jurisdiction’s share of the metropolitan total on each of those variables. When the MA definition changes, so does the denominator.

The new MA definitions add 294 counties and remove 75 counties from the universe of counties included as metropolitan. Table 7-3 summarizes the national old and new metropolitan totals for each of the four applicable variables for the previous and current MA definitions. For all four variables, the metropolitan totals increase. An increasing denominator and a fixed numerator

44 In addition to the 78 cities noted, 16 other principal cities are enrolled participants in CDBG urban counties and will be eligible for metropolitan city designation when the urban county agreement is up for renewal. Cities coming out of urban counties have less effect on other entitlement grantees because their data are already accounted for in the entitlement side of the formula.

CDBG Formula Targeting to Community Development Need 89 result in every jurisdiction experiencing a decline in share. If the CDBG universe remains constant, a decline in share means that the pro rata reduction also decreases. That is, jurisdictions that are funded heavily under the variables with the smallest denominator, such as overcrowded housing, would experience increases in funding. Jurisdictions funded heavily by the poverty factor would experience decreases in funding.

Table 7-3. Changing MA National Totals for CDBG Variables, Census 2000 Data

Variable Denominator Total for Old MA Definition Denominator Total for New MA Definition Change Percent Change Population 229,192,836 236,197,894 7,005,058 3.1 Poverty 27,561,898 28,648,340 1,086,442 3.9 Overcrowding 5,551,631 5,666,143 114,512 2.1 Pre-1940 Housing 12,974,750 13,348,818 374,068 2.9

Of course, as noted above, the universe is not a constant. The new MA definitions also increase the number of entitlement grantees drawing from the 70 percent entitlement pot of funds. This takes away from all the existing entitlement grantees. Thus, jurisdictions largely funded by poverty take an even larger reduction in funding while jurisdictions primarily funded by overcrowding receive smaller funding increases, and sometimes even decreases. Chapter 8 describes the history of the 70/30 split and options for changing the split or eliminating it altogether.

CDBG Formula Targeting to Community Development Need 90

CDBG Formula Targeting to Community Development Need 91 Chapter 8. The 70/30 Split

Since 1981, nonentitled portions of states have received 30 percent of the Community Development Block Grant (CDBG) formula allocation while entitlement areas have received 70 percent. Chapter 7 revealed that many new cities and urban counties were added to the entitlement share of the formula from the nonentitlement share. This chapter offers several alternatives to the 70/30 split between entitlement and nonentitlement communities.

Background

Since 1981, the CDBG statute has required that 70 percent of CDBG funds allocated by formula go to entitlement jurisdictions, and the other 30 percent go to nonentitled communities. Since 1981, however, more and more communities have achieved entitlement status. The result is that an ever-increasing share of the population is served by 70 percent of the funds, while the 30 percent share serves a diminishing share of the population.

The original CDBG formula (Section 106 of the Housing and Community Development Act of 1974) allocated 80 percent of grant amounts to metropolitan areas (MAs) and 20 percent to non- MAs. “Hold harmless” communities—that is, nonentitlement communities funded under the prior programs’ classifications—were funded from the 80 percent share, and the remaining funds were allocated by formula to entitlement grantees. The entire metropolitan share was not allocated; the remainder of the 80 percent share was then distributed by formula to HUD field offices to be allocated to the MAs’ nonentitlement areas of the jurisdiction they served. Thus, the split between entitlements and nonentitlements could fluctuate, depending on the portion of the formula variables in MAs and entitlement communities (as well as the need to phase out the hold harmless grantees from the prior programs). In the early days of the CDBG program, this resulted in nonentitlement areas receiving between 20 and 25 percent of the funds.

In 1981, the Omnibus Budget Reconciliation Act offered states the option of administering the CDBG program for their nonentitled jurisdictions. This statute also established that nonentitled areas would receive 30 percent of the CDBG allocation available for formula distribution. The last major modification to the formula, it was first used for distributing funds in 1982.

Table 8-1. Population When the 70/30 Split Was Established

1982 Percent of: Entitled Areas Nonentitled Areas Population 55 45 Formula funds 70 30

It is instructive to note that when Congress established the entitlement and nonentitlement shares, this represented an increase in funding for nonentitlements and a decrease for entitlements. Previously, entitlements received approximately 75 percent of the funds; the 1981 enactment of the 70/30 split reduced this to 70 percent. Congress did this adjustment knowingly, stating in the legislative history of the Omnibus Reconciliation Act of 1981 “ the increased amount for nonentitled areas is more in keeping with their relative needs”. As Table 8-1 shows, even after

CDBG Formula Targeting to Community Development Need 92 this adjustment, only 55 percent of the population at the time was in entitlement jurisdictions. The CDBG per capita grant for nonentitlements was substantially less than that for entitlements.

Changes Since 1982

In the two decades since the 70/30 split was enacted, changes in entitlement geography and demographics have caused funding to shift more toward nonentitlement areas. In 1982, there were 732 entitlement jurisdictions. By 1993, this number grew to 889, a 21 percent increase. In 2004, the number is 1,105.

While the number of entitlement communities steadily increased, the 70 percent share has remained constant. As cities and counties grow to reach the threshold for entitlement status, they qualify for a share of the 70 percent entitlement share. Although communities sometimes lose population and drop below the threshold for entitlement status, Congress has always grandfathered them and enabled them to retain their entitlement status.

New entitlements do not necessarily indicate a transfer of population from nonentitlement areas to entitlement areas. Some new entitlements result from smaller, nonentitled locations meeting or exceeding the population thresholds, and thereby qualifying for entitlement status. Other new entitlements occur when cities that are part of urban counties (and therefore already entitled) becoming entitled separately. In these situations, the total population competing for the 70 percent entitlement share does not increase. The portion of the country drawing from the 70 percent entitlement share, however, will continue to grow.

Table 8-2. Change in Share of Population Since 1982

Percent of: Entitled Areas Nonentitled Areas 1982 Population 55 45 Poverty population 54 46 2003 Population 62 38 Poverty population 64 36 2004 Population 64 36 Poverty population 65 35

Table 8-2 illustrates the change in entitled areas relative to nonentitled areas since 1982. In 1982, the 70 percent share of the formula served 55 percent of the total population and 54 percent of the poverty population. By 2003, because a sufficient number of the previously nonentitlement areas become entitled, the 70 percent share served 62 percent of the total population and 64 percent of the population in poverty.

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need 93 The lower portion of Table 8-2 indicates that the flow of funding away from entitlement jurisdictions will continue when the new MA definitions are applied in 2004. 45 Whereas in 2003, the 70 percent entitlement share served 62 percent of the population, when the new MA definitions are applied, this same share will serve approximately 64 percent of the population.

Options for Determining Entitlement and Nonentitlement Shares

This report offers no criteria for determining whether the 70/30 split is appropriate. It also presents no arguments as to the relative share of CDBG that should go to entitlement areas versus nonentitlement areas. If when Congress enacted the 70/30 split, this share was appropriate, the present allocation has come to overfund the nonentitlement areas. In 2003, if entitlement grantees were funded on a per capita basis similar to in 1982, approximately 79 percent of the formula amounts should go to entitlements, compared with the actual 70 percent that is required by law. If the appropriate share is a per capita grant in nonentitlement areas that is equivalent to that in entitlement areas, however, the formula, while evolving in that direction, has not yet reached that distribution.

Retain the 70/30 Split

Despite the continued loss of funding share for entitlement areas, on a per capita or per person in poverty basis, entitlement areas still receive more than nonentitlement areas. Thus, it may be argued that no change is needed in the immediate future. When, as appears inevitable, the nonentitlement share of population or poverty population drops below 30 percent, it would seem appropriate to adjust the nonentitlement share of formula funds downward from 30 percent to reflect this decline in population. For example, if the population or poverty population of nonentitlement areas fell to 25 percent of the national total, it would make sense to adjust the 70/30 split to 75/25 to allow approximate per capita parity for entitlements and nonentitlements.

Adjust the 70/30 Split to Reflect the Changes in Population Since 1982

When Congress enacted the 70/30 split, it decided, in effect, that 70 percent of funds should go to the 55 percent of the population that lived in entitlement communities. In other words, every 1 percent of the population in entitlement areas ought to receive about 1.27 percent of the funds allocated by formula. The 70/30 split could be adjusted continually to reflect this ratio. Alternatively, a similar ratio based on any time since 1982 could be adopted. If the formula were to freeze the actual 2003 ratio, for example, it could be continually adjusted so that every 1 percent of the entitled portion of the population received 1.13 percent of the funds allocated by formula.

Adopt a Fair Share Formula

A fair share formula would automatically apportion formula funds between entitlement and nonentitlement areas. Rather than specify a static 70/30 split, a single formula could be used to

45 The Census 2002 population estimates are being applied in 2002; they are not accounted for in this table. As in past years, their affect is to further increase the portion of the population in entitlement jurisdictions.

CDBG Formula Targeting to Community Development Need 94 allocate all of the funds. Then, all jurisdictions would receive funds proportionate to their share of need as measured by the formula variables, and the entitlement/nonentitlement split would fluctuate annually. To implement this type of formula, it would probably be a good idea to make the entitlement and nonentitlement formulas more similar than they are now.

Entitlement alternatives 2 or 3 and nonentitlement alternative 2 in Chapter 6 provide one concept of a fair share formula that could be used to either determine the entitlement/nonentitlement split or eliminate the split completely and allocate the funds to entitlements and nonentitlements with a single formula. Entitlement alternatives 2 and 3 and nonentitlement alternative 2 share three common variables: poverty, pre-1950 housing occupied by a poverty household, and female- headed households with children. The entitlement formula alternatives include the additional variable of overcrowding.

If formula alternative 3 from Chapter 6 is used as a single formula for both entitlements and nonentitlements, with no funding split, the formula would look as follows:

(0.5 Povfam (a) + 0.1 FHH (a) + 0.3 AgePov (a) + 0.1 Ocrowd (a) ) * Appropriations Povfam(TOT) FHH (TOT) AgePov (TOT) Ocrowd (TOT)

where: null (a) is the value for the jusrisdiction. null (TOT) is the value for all grantees, entitlement and nonentitlement. null Povfam is the number of family and elderly person in poverty. null FHH is the number of female-headed households with children. null AgePov is the number of housing units older than 50 years and occupied by a poverty household. null Ocrowd is the number of overcrowded housing units.

The adjustment of entitlement alternative 3 is then applied where the per capita income Metropolitan Statistical Area/local per capita income (with caps) ratio remains constant at 1.0 for states. A pro rata adjustment is applied. The funding split is 69 percent for entitlements and 31 percent for nonentitlements. 46

46 Unlike the alternatives discussed in Chapter 6 that used the FY 2002 universe of grantees, this alternative uses the FY 2004 universe of grantees.

CDBG Formula Targeting to Community Development Need 95 Chapter 9. Conclusion

The National Research Council’s Panel on Statistical Issues in Allocating Funds by Formula (Louis, Jabine, and Gerstein 2003) recommends that policymakers periodically review formula allocation programs to assess whether they are performing as intended. For the Community Development Block Grant (CDBG) formula, there have been five major assessments of the formula since 1974.

The first assessment was used to develop the formula that has been in place since 1978. Subsequent assessments determined that over 30 years, the extent to which the variables used in the CDBG formula target toward community development need has declined. Over time, (1) an increasing number of jurisdictions with the same need receive substantially different grants, and (2) the amount of funds going to the neediest on a per capita basis has decreased, while the amount of funds going to the least needy on a per capita basis has increased. The formula, however, generally continues to target to need. Among the entitlement communities, on a per capita basis, the most needy 10 percent of communities receive four times as much as the least needy 10 percent of jurisdictions.

The entitlement formula’s declining targeting can be attributed to several items: (1) the formula factors in Formula B create significant anomalies where similarly needy communities get substantially different per capita grant amounts; (2) the formula factors in Formula A result in an allocation in which there are few anomalies but the most needy grantees do not receive much more on a per capita basis than the least needy grantees; and (3) across the board, a Formula A jurisdiction with the same need as a Formula B jurisdiction receives a smaller per capita grant amount.

The lack of targeting to need in the nonentitlement formula can largely be attributed to the difficulty of defining need for nonentitled areas. Because of this difficulty, the original nonentitlement formula was created as a simplified version of the entitlement allocation. The result is a nonentitlement formula that is very flat in its allocation to need because of a very high weight on population. In addition, the pre-1940 housing variable in Formula B and the overcrowding variable in Formula A appear to create several anomalies in targeting to the states. The one exception is Puerto Rico; Puerto Rico’s need is extremely high in nonentitled areas, and that need is appropriately targeted in the current formula.

One advantage of a formula allocation versus other funding methods, as identified by the National Research Council (Louis, Jabine, and Gerstein 2003), is that a formula creates “the appearance, if not always the reality, of a sound analytic process.” For the CDBG program, Chapters 6 and 8 of this report provide such a sound analytic process for creating, effectively, four different formula alternatives. The first three alternatives maintain separate formulas for the entitlement and nonentitlement program, retaining the current 70/30 split. The fourth alternative funds entitlements and nonentitlements under the same single formula. Appendix B provides the equations for each alternative.

CDBG Formula Targeting to Community Development Need 96 null Alternative 1. The current formula, with several technical adjustments to reduce the number of funding anomalies. This alternative combines the entitlement and nonentitlement alternative 1 options described in Chapter 6.

null Alternative 2. A simple formula designed to most effectively target to the needs index. This alternative combines the entitlement and nonentitlement alternative 2 options provided in Chapter 6.

null Alternative 3. A simple formula that allocates substantially more funds than alternative 2 to the most needy jurisdictions, particularly jurisdictions suffering from age and decline, and significantly fewer funds to the least needy jurisdictions. This alternative combines the entitlement alternative 3 and nonentitlement alternative 2 explained in Chapter 6.

null Alternative 4. A single formula based on alternative 3 that allocates all the formula funds using a single formula to both the entitlement and nonentitlement grantees. Chapter 8 contains a discussion of this alternative.

This report concludes that serious consideration should be given to changing the formula to improve its targeting to need. Any of the alternatives proposed in this report would accomplish this goal. The Department looks forward to working with the Congress, CDBG grantees, and other stakeholders to discuss these alternatives.

Finally, the National Research Council’s first recommendation regarding formula allocation programs states “…legislators should consider giving some flexibility to program agencies, especially in determining what data sources and procedures should be used to produce estimates of the components of allocation formulas” (Louis, Jabine, and Gerstein 2003). Allowing a degree of flexibility to HUD to make regulatory adjustments to the CDBG formula, as currently allowed under the HOME program, may, in the future, help to avoid the significant swings in funds necessary at this time to improve formula targeting.

CDBG Formula Targeting to Community Development Need A- 1 Appendix A. Targeting to Individual Measures of Need

Appendix A shows how well the current formula, the three alternatives for entitlements, and the two nonentitlement alternatives target to individual measures of community development need.

Entitlement Grantees

Factors

Table A-1. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.497 0.771 0.922 0.893 Slope 8.5 10.2 8.7 11.0 Factor 1 Constant 18.1 17.2 16.6 17.3 R-square 0.197 0.076 0.000 0.031 Slope –5.4 –3.2 –0.1 –2.1 Factor 2 Constant 18.1 17.2 16.6 17.3 R-square 0.074 0.016 0.002 0.004 Slope –3.3 –1.5 0.4 –0.8 Factor 3 Constant 18.1 17.2 16.6 17.3 N=899 for all regressions

Income Measures

Table A-2. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.303 0.617 0.892 0.733 Slope 89.8 127.1 125.2 139.8 Persons in family or elderly households in poverty Constant 8.5 3.8 3.4 2.5 R-square 0.469 0.582 0.620 0.715 Slope 137.0 151.4 128.1 169.4 Extremely Low- Income Households* Constant –0.1 –2.7 –0.2 –5.1 R-square 0.183 0.285 0.310 0.428 Slope 20.2 25.1 21.4 31.0 MSA per capita income/local per capita income Constant –3.8 –9.7 –6.4 –16.1 R-square 0.087 0.228 0.406 0.279 Slope 28.2 45.3 49.5 50.5 Concentrated poverty Constant 16.9 15.3 14.5 15.2 N=1,024 for all regressions *Family and elderly households with incomes less than 30% of HUD area median family income

CDBG Formula Targeting to Community Development Need A- 2 High Consumers of Support Services

Table A-3. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.158 0.391 0.615 0.503 Slope 51.1 79.8 81.9 91.2 Persons over 25 without a high school education Constant 9.9 4.6 3.6 2.8 R-square 0.364 0.446 0.410 0.540 Slope 462.3 507.6 399.0 563.3 Female-headed households with children under the age of 18 Constant 0.8 –1.6 1.9 –3.6 N=1,024 for all regressions

Decent Housing

Table A-4. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.745 0.715 0.473 0.672 Slope 324.1 315.0 209.9 308.2 Pre-1950 housing with poverty household Constant 7.3 6.9 9.8 7.2 R-square 0.614 0.690 0.609 0.733 Slope 240.9 253.3 195.0 263.3 Pre-1970 housing with a poverty renter household Constant 6.0 4.7 7.0 4.2 R-square 0.013 0.103 0.270 0.134 Slope 19.1 53.9 71.5 62.0 Overcrowded housing Constant 16.9 13.8 12.1 13.4 N=1,024 for all regressions

Crime

Table A-5. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.160 0.295 0.413 0.397 Slope 1.1 1.4 1.3 1.6 Crime* Constant 12.3 9.8 9.7 8.6 N=899 for all regressions null Number of murders, assaults with weapons, incidents of nonnegligent manslaughter, and robberies per 1,000 persons in 2001.

CDBG Formula Targeting to Community Development Need A- 3 Population Trends

Table A-6. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.648 0.475 0.164 0.288 Slope 99.1 84.2 40.1 66.1 Population loss, 1960–2000 Constant 14.2 14.1 15.2 14.9 R-square 0.368 0.283 0.106 0.182 Slope 249.6 217.3 109.0 175.7 Population loss, 1990–2000 Constant 15.3 14.9 15.6 15.5 N=1,024 for all regressions

Unemployment

Table A-7. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 Alternative 3 R-square 0.309 0.539 0.721 0.635 Slope 206.9 270.9 256.7 296.6 Unemployment Constant 4.7 –0.2 0.2 –1.8 N=1,024 for all regressions

State Grantees, Excluding Puerto Rico 47

Factors

Table A-8. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 R-square 0.181 0.743 0.705 Slope 1.6 4.8 4.7 Factor 1 Constant 12.0 12.3 12.2 R-square 0.161 0.050 0.226 Slope 0.9 0.7 1.6 Factor 2 Constant 11.8 11.7 11.6 R-square 0.001 0.097 0.215 Slope .065 1.1 1.7 Factor 3 Constant 11.8 11.7 11.6 N=50 for all regressions

47 As noted in Chapters 5 and 6, Puerto Rico’s very high need in nonentitlement areas relative to the other states distorts the regression estimates on the overall targeting of the nonentitlement formula.

CDBG Formula Targeting to Community Development Need A- 4 Income Measures

Table A-9. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 R-square 0.140 0.720 0.832 Slope 23.1 77.9 84.0 Persons in family or elderly households in poverty Constant 9.6 4.4 3.7 R-square 0.166 0.551 0.570 Slope 52.5 142.0 144.9 Extremely low- income households* Constant 6.1 –3.6 –4.0 R-square 0.142 0.332 0.370 Slope 13.1 29.7 31.5 Concentrated poverty Constant 11.3 10.5 10.4 N=50 for all regressions null Family and elderly households with incomes less than 30 percent of HUD area median family income.

High Consumers of Support Services

Table A-10. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 R-square 0.001 0.254 0.378 Slope 1.4 32.5 39.8 Persons age 25 to 64 without a high school education Constant 11.6 7.0 5.9 R-square 0.059 0.256 0.337 Slope 118.6 367.4 423.2 Female-headed households with children under the age of 18 Constant 8.7 2.1 0.5 N=50 for all regressions

Decent Housing

Table A-11. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 R-square 0.200 0.061 0.216 Slope 104.7 86.0 162.2 Pre-1950 housing with poverty household Constant 9.0 9.4 7.3 R-square 0.303 0.321 0.489 Slope 168.2 257.3 318.6 Pre-1970 housing with a poverty renter household Constant 7.2 4.8 3.0 R-square 0.164 0.408 0.061 Slope 32.5 76.1 29.5 Overcrowded housing Constant 10.6 9.0 10.6 N=50 for all regressions

CDBG Formula Targeting to Community Development Need A- 5 Unemployment

Table A-12. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 R-square 0.123 0.494 0.284 Slope 52.5 156.4 119.0 Unemployment Constant 8.9 3.3 5.2 N=50 for all regressions

Infrastructure

Table A-13. Place Targeting—Regression Statistics

Targeting to: Current Alternative 1 Alternative 2 R-square 0.026 0.097 0.168 Slope 5.0 14.5 19.1 Households using bottled gas or wood as primary heating fuel Constant 10.9 9.1 8.2 N=50 for all regressions

CDBG Formula Targeting to Community Development Need B-1 Appendix B. Impact of Alternatives on Individual Grantees

Individual Grants—Formula Targeting

Appendix B shows the individual grants for the alternative formulas presented in this report. For each grantee, this appendix specifies the actual Fiscal Year (FY) 2004 allocation, the allocation using the FY 2004 appropriation and grantee universe for each of the suggested four alternative grants, 48 and the percent change for each alternative when compared to the FY 2004 allocation.

For simplicity, alternative 1 combines entitlement alternative 1 and nonentitlement alternative 1. Similarly, alternative 2 is entitlement alternative 2 and nonentitlement alternative 2. Alternative 3 is entitlement alternative 3 and nonentitlement alternative 2. Alternative 4 is the single formula with no 70/30 funding split between entitlements and nonentitlements described in Chapter 8.

Chart B-1. FY 2004 Formula and the Four Alternatives

48 The base report is based on the FY 2002 appropriation amount and universe of grantees. These FY 2002 comparison runs did not subtract Native Americans living in Indian areas from the calculations; the formula runs in Appendix B, however, do. Entitlement Communities

Formula A:

[0.25 Pop (a) + 0.5 Pov (a) + 0.25 Ocrowd (a)] x $3.032 billion Pop (MA) Pov (MA) Ocrowd (MA)

Formula B for cities:

[0.2 GLag (a) + 0.3 Pov (a) + 0.5 Age (a)] x $3.032 billion GLag (MC) Pov (MA) Age (MA)

Formula B for urban counties:

[0.2 GLag (a) + 0.3 Pov (a) + 0.5 Age (a)] x $3.032 billion GLag (ENT) Pov (MA) Age (MA)

States (Nonentitlements)

Formula A:

[0.25 Pop (a) + 0.5 Pov (a) + 0.25 Ocrowd (a)] x $1.299 billion Pop (NEnt) Pov (NEnt) Ocrowd (NEnt)

Formula B:

(0.2 Pop (a) + 0.3 Pov (a) + 0.5 Age (a) ) x $1.299 billion Pop (NEnt) Pov (NEnt) Age (NEnt)

where:

null (a) is the value for the jurisdiction. null (MA) is the value for all Metropolitan Areas (MAs). null (MC) is the value for all entitlement cities. null (ENT) is the value for all entitlement jurisdictions (cities and urban counties). null (NEnt) is the value for all nonentitled areas nationwide.

null Pop is the total resident population. null Pov is the number of persons below the poverty level null Ocrowd is the number of overcrowded housing units. null Age is the number of housing units built before 1940. null Glag is the population growth lag.

CDBG Formula Targeting to Community Development Need B-2

Chart B-2. Alternative 1

Chart B-3. Alternative 2

Entitlement Communities

Formula A:

[0.1 Pop (a) + 0.6 Povfam (a) + 0.3 Ocrowd (a)] x $3.032 billion Pop (MA) Povfam (MA) Ocrowd (MA)

Formula B for cities:

[0.1 GLagadj (a) + 0.4 Povfam (a) + 0.5 Agepov (a) ] x $3.032 billion GLagadj (MC) Povfam (MA) Agepov (MA)

Formula B for urban counties:

[(0.1 GLagadj (a) + 0.4 Povfam (a) + 0.5 Agepov (a) ] x $3.032 billion GLagadj (ENT) Povfam (MA) Agepov (MA)

States (Nonentitlements)

Formula A:

[(0.1 Pop (a) + 0.65 Povfam (a) + 0.25 Ocrowd (a)] x $1.299 billion Pop (NEnt) Povfam (NEnt) Ocrowd (NEnt)

Formula B is:

[0.1 Pop (a) + 0.4 Povfam (a) + 0.5 Agepov (a) ] x $1.299 billion Pop (NEnt) Povfam (NEnt) Agepov (NEnt)

where: null (a) is the value for the jurisdiction. null (MA) is the value for all MAs. null (MC) is the value for all entitlement cities. null (ENT) is the value for all entitlement jurisdictions (cities and urban counties). null (NEnt) is the value for all nonentitled areas nationwide. null Pop is the total resident population. null Povfam is the number of persons in poverty living in a family or elderly household. null Ocrowd is the number of overcrowded housing units. null Agepov is the number of housing units built before 1950 with a poverty household. null Glagadj is the population growth lag adjusted down for communities with high per capita income and low poverty. Entitlement Communities

[0.5 Povfam (a) + 0.1 FHHKIDS (a) + 0.2 Ocrowd (a) + 0.2 Agepov (a)] x $3.032 billion Povfam (ENT) FHHKIDS (ENT) Ocrowd (ENT) Agepov (ENT)

States (Nonentitlements)

[0.6 Povfam (a) + 0.1 FHHKIDS (a) + 0.3 Agepov (a) ] x $1.299 billion Povfam (NEnt) FHHKIDS (NEnt) Agepov (NEnt)

where: null (a) is the value for the jurisdiction. null (ENT) is the value for all entitlement jurisdictions (cities and urban counties) null (NEnt) is the value for all nonentitled areas nationwide. null Povfam is the number of persons in poverty living in a family or elderly household. null Ocrowd is the number of overcrowded housing units. null Agepov is the number of housing units built before 1950 and occupied by a poverty household. null FHHKIDS is the number of female-headed households with children under the age of 18.

CDBG Formula Targeting to Community Development Need B-3

Chart B-3. Alternative 3

Chart B-4. Alternative 4

Entitlement Communities

[0.5 Povfam (a) + 0.1 FHHKIDS (a) + 0.1 Ocrowd (a) + 0.3 Agepov (a)] x $3.032 billion Povfam (ENT) FHHKIDS (ENT) Ocrowd (ENT) Agepov (ENT)

The entitlement calculation is then adjusted by the ratio of per capita income of the MSA over the per capita income for the jurisdiction, with caps such that no grant is adjusted upward greater than 25 percent and no grant is adjusted downward by more than 25 percent. Pro-rata reduction is used to bring the total grant into line with appropriation.

States (Nonentitlements)

[0.6 Povfam (a) + 0.1 FHHKIDS (a) + 0.3 Agepov (a) ] x $1.299 billion Povfam (NEnt) FHHKIDS (NEnt) Agepov (NEnt)

where: null (a) is the value for the jurisdiction. null (ENT) is the value for all entitlement jurisdictions (cities and urban counties). null (NEnt) is the value for all nonentitled areas nationwide. null Povfam is the number of persons in poverty living in a family or elderly household. null Ocrowd is the number of overcrowded housing units. null Agepov is the number of housing units built before 1950 and occupied by a poverty household. null FHHKIDS is the number of female-headed households with children under the age of 18.

Entitlement Communities and States (Nonentitlements) Under a Single Formula

[0.5 Povfam (a) + 0.1 FHHKIDS (a) + 0.1 Ocrowd (a) + 0.3 Agepov (a)] x $4.331 billion Povfam (ALL) FHHKIDS (ALL) Ocrowd (ALL) Agepov (ALL)

The calculation is then adjusted by the ratio of per capita income (PCI) of the Metropolitan Statistical Area (MSA) divided by the PCI for the jurisdiction (PCIMSA/PCILocal), with caps such that no grant is adjusted either upward or downward by more than 25 percent. All state grants are assigned a PCIMSA/PCILocal ratio of 1. Pro-rata reduction is used to bring the total grant into line with appropriation.

where: null (a) is the value for the jurisdiction. null (ALL) is the value for all 50 states, the District of Columbia, and Puerto Rico. null Povfam is the number of persons in poverty living in a family or elderly household. null Ocrowd is the number of overcrowded housing units. null Agepov is the number of housing units built before 1950 and occupied by a poverty household. null FHHKIDS is the number of female-headed households with children under the age of 18.

CDBG Formula Targeting to Community Development Need B-4

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Alabama Anniston, AL $807,000 $1,004,000 $726,000 $723,000 $702,000 24% -10% -10% -13% $33.92 $42.20 $30.53 $30.38 $29.52 Auburn, AL $860,000 $381,000 $465,000 $487,000 $473,000 -56% -46% -43% -45% $18.95 $8.40 $10.25 $10.73 $10.42 Bessemer, AL $850,000 $1,127,000 $1,015,000 $1,313,000 $1,272,000 33% 19% 54% 50% $28.95 $38.40 $34.56 $44.71 $43.33 Birmingham, AL $8,017,000 $8,525,000 $7,008,000 $8,920,000 $8,669,000 6% -13% 11% 8% $33.49 $35.61 $29.27 $37.26 $36.21 Decatur, AL $619,000 $668,000 $893,000 $923,000 $898,000 8% 44% 49% 45% $11.48 $12.39 $16.55 $17.12 $16.65 Dothan, AL $640,000 $718,000 $993,000 $836,000 $810,000 12% 55% 31% 27% $10.85 $12.17 $16.84 $14.17 $13.73 Florence, AL $514,000 $689,000 $694,000 $670,000 $648,000 34% 35% 30% 26% $14.35 $19.24 $19.39 $18.69 $18.10 Gadsden, AL $1,415,000 $1,530,000 $1,074,000 $1,233,000 $1,197,000 8% -24% -13% -15% $37.27 $40.29 $28.29 $32.49 $31.53 Hoover, AL $339,000 $252,000 $240,000 $150,000 $150,000 -26% -29% -56% -56% $5.28 $3.92 $3.74 $2.34 $2.33 Huntsville, AL $1,559,000 $1,518,000 $1,953,000 $1,689,000 $1,641,000 -3% 25% 8% 5% $9.59 $9.34 $12.02 $10.39 $10.10 Jefferson County, AL $2,556,000 $2,435,000 $3,279,000 $2,748,000 $2,673,000 -5% 28% 8% 5% $7.13 $6.79 $9.15 $7.67 $7.46 Mobile, AL $3,433,000 $4,448,000 $4,706,000 $4,416,000 $4,289,000 30% 37% 29% 25% $17.62 $22.83 $24.15 $22.66 $22.01 Mobile County, AL $2,427,000 $2,786,000 $3,502,000 $3,478,000 $3,371,000 15% 44% 43% 39% $11.82 $13.57 $17.06 $16.94 $16.42 Montgomery, AL $2,548,000 $2,831,000 $3,976,000 $3,710,000 $3,608,000 11% 56% 46% 42% $12.65 $14.05 $19.74 $18.42 $17.91 Opelika, AL $308,000 $350,000 $480,000 $434,000 $422,000 14% 56% 41% 37% $13.05 $14.85 $20.35 $18.38 $17.88

CDBG Formula Targeting to Community Development Need B-5

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Tuscaloosa, AL $1,114,000 $1,176,000 $1,340,000 $1,271,000 $1,237,000 6% 20% 14% 11% $14.07 $14.86 $16.93 $16.05 $15.62 Alabama State Program $30,041,000 $34,151,000 $39,787,000 $39,787,000 $40,330,000 14% 32% 32% 34% $11.24 $12.78 $14.89 $14.89 $15.09 TOTAL $58,047,000 $64,588,000 $72,132,000 $72,788,000 $72,389,000 11% 24% 25% 25% $12.94 $14.40 $16.08 $16.22 $16.14

Alaska Anchorage, AK $2,285,000 $2,157,000 $2,302,000 $1,802,000 $1,795,000 -6% 1% -21% -21% $8.49 $8.02 $8.56 $6.70 $6.67 Fairbanks, AK $305,000 $289,000 $361,000 $353,000 $349,000 -5% 18% 16% 14% $9.91 $9.39 $11.74 $11.46 $11.33 Alaska State Program $2,954,000 $2,867,000 $1,773,000 $1,773,000 $2,113,000 -3% -40% -40% -28% $10.59 $10.28 $6.36 $6.36 $7.58 TOTAL $5,544,000 $5,314,000 $4,437,000 $3,928,000 $4,257,000 -4% -20% -29% -23% $9.58 $9.18 $7.67 $6.79 $7.36

Arizona Chandler, AZ $1,610,000 $1,577,000 $1,577,000 $1,144,000 $1,142,000 -2% -2% -29% -29% $7.97 $7.81 $7.81 $5.66 $5.65 Flagstaff, AZ $742,000 $639,000 $718,000 $562,000 $555,000 -14% -3% -24% -25% $13.45 $11.59 $13.02 $10.18 $10.05 Gilbert, AZ $673,000 $547,000 $513,000 $373,000 $371,000 -19% -24% -45% -45% $4.99 $4.05 $3.80 $2.76 $2.75 Glendale, AZ $2,668,000 $2,883,000 $3,040,000 $2,850,000 $2,816,000 8% 14% 7% 6% $11.57 $12.50 $13.18 $12.36 $12.21 Maricopa County, AZ $3,306,000 $3,446,000 $3,404,000 $2,905,000 $2,847,000 4% 3% -12% -14% $8.52 $8.89 $8.78 $7.49 $7.34 Mesa, AZ $4,119,000 $4,215,000 $4,313,000 $3,874,000 $3,848,000 2% 5% -6% -7% $9.65 $9.88 $10.10 $9.08 $9.02 Peoria City, AZ $765,000 $689,000 $691,000 $499,000 $493,000 -10% -10% -35% -36% $6.21 $5.59 $5.61 $4.05 $4.00

CDBG Formula Targeting to Community Development Need B-6

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Phoenix, AZ $20,323,000 $23,050,000 $24,971,000 $22,934,000 $22,662,000 13% 23% 13% 12% $14.81 $16.80 $18.20 $16.72 $16.52 Pima County, AZ $3,033,000 $3,024,000 $3,128,000 $2,105,000 $2,063,000 0% 3% -31% -32% $8.28 $8.25 $8.54 $5.75 $5.63 Scottsdale, AZ $1,389,000 $1,132,000 $1,124,000 $705,000 $695,000 -18% -19% -49% -50% $6.44 $5.25 $5.21 $3.27 $3.22 Tempe, AZ $1,933,000 $1,549,000 $1,614,000 $1,290,000 $1,279,000 -20% -17% -33% -34% $12.12 $9.71 $10.12 $8.09 $8.02 Tucson, AZ $7,456,000 $7,736,000 $9,135,000 $9,744,000 $9,580,000 4% 23% 31% 28% $14.82 $15.38 $18.16 $19.36 $19.04 Yuma, AZ $1,117,000 $1,290,000 $1,406,000 $1,038,000 $1,025,000 15% 26% -7% -8% $13.90 $16.05 $17.50 $12.91 $12.76 Arizona State Program $14,406,000 $15,520,000 $12,159,000 $12,159,000 $13,328,000 8% -16% -16% -7% $13.92 $15.00 $11.75 $11.75 $12.88 TOTAL $63,540,000 $67,298,000 $67,794,000 $62,182,000 $62,703,000 6% 7% -2% -1% $12.01 $12.72 $12.81 $11.75 $11.85

Arkansas Bentonville, AR $204,000 $208,000 $253,000 $197,000 $193,000 2% 24% -4% -5% $8.47 $8.63 $10.51 $8.17 $8.01 Conway, AR $490,000 $388,000 $471,000 $473,000 $460,000 -21% -4% -4% -6% $10.67 $8.45 $10.26 $10.30 $10.02 Fayetteville, AR $761,000 $578,000 $737,000 $681,000 $665,000 -24% -3% -10% -13% $12.53 $9.53 $12.14 $11.22 $10.95 Fort Smith, AR $1,007,000 $1,128,000 $1,483,000 $1,208,000 $1,180,000 12% 47% 20% 17% $12.35 $13.84 $18.19 $14.82 $14.48 Hot Springs, AR $499,000 $771,000 $784,000 $846,000 $823,000 54% 57% 70% 65% $13.73 $21.20 $21.56 $23.28 $22.63 Jacksonville, AR $332,000 $361,000 $430,000 $473,000 $460,000 9% 29% 43% 39% $10.93 $11.88 $14.15 $15.58 $15.14 Jonesboro, AR $662,000 $640,000 $800,000 $684,000 $662,000 -3% 21% 3% 0% $11.64 $11.25 $14.07 $12.03 $11.63

CDBG Formula Targeting to Community Development Need B-7

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Little Rock, AR $2,023,000 $2,062,000 $2,927,000 $2,458,000 $2,397,000 2% 45% 22% 18% $10.99 $11.20 $15.90 $13.36 $13.02 North Little Rock, AR $890,000 $1,045,000 $1,150,000 $1,138,000 $1,108,000 17% 29% 28% 24% $14.83 $17.41 $19.16 $18.97 $18.46 Pine Bluff, AR $894,000 $1,124,000 $1,458,000 $1,429,000 $1,385,000 26% 63% 60% 55% $16.50 $20.74 $26.91 $26.38 $25.57 Rogers, AR $480,000 $535,000 $579,000 $445,000 $437,000 11% 21% -7% -9% $11.55 $12.88 $13.94 $10.72 $10.53 Springdale, AR $595,000 $666,000 $712,000 $633,000 $624,000 12% 20% 6% 5% $11.68 $13.07 $13.97 $12.42 $12.25 Texarkana, AR $383,000 $484,000 $636,000 $631,000 $610,000 26% 66% 65% 59% $13.55 $17.11 $22.50 $22.31 $21.57 West Memphis, AR $512,000 $639,000 $829,000 $980,000 $947,000 25% 62% 91% 85% $18.27 $22.79 $29.58 $34.95 $33.77 Arkansas State Program $22,524,000 $25,545,000 $28,268,000 $28,268,000 $28,959,000 13% 26% 26% 29% $11.69 $13.26 $14.67 $14.67 $15.03 TOTAL $32,256,000 $36,173,000 $41,517,000 $40,545,000 $40,910,000 12% 29% 26% 27% $11.90 $13.35 $15.32 $14.96 $15.10

California Alameda, CA $1,561,000 $824,000 $1,026,000 $828,000 $830,000 -47% -34% -47% -47% $21.40 $11.30 $14.07 $11.35 $11.38 Alameda County, CA $2,380,000 $2,372,000 $2,576,000 $2,079,000 $2,099,000 0% 8% -13% -12% $9.52 $9.48 $10.30 $8.31 $8.39 Alhambra, CA $1,677,000 $1,941,000 $2,162,000 $2,094,000 $2,115,000 16% 29% 25% 26% $19.13 $22.15 $24.66 $23.89 $24.12 Anaheim, CA $6,035,000 $7,165,000 $7,032,000 $6,551,000 $6,611,000 19% 17% 9% 10% $18.14 $21.54 $21.14 $19.70 $19.87 Antioch, CA $887,000 $927,000 $1,033,000 $1,105,000 $1,091,000 5% 16% 25% 23% $8.88 $9.29 $10.34 $11.06 $10.92 Apple Valley, CA $747,000 $862,000 $957,000 $831,000 $806,000 15% 28% 11% 8% $12.90 $14.89 $16.52 $14.34 $13.92

CDBG Formula Targeting to Community Development Need B-8

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Bakersfield, CA $3,933,000 $4,575,000 $5,278,000 $4,101,000 $4,026,000 16% 34% 4% 2% $15.07 $17.53 $20.23 $15.72 $15.43 Baldwin Park, CA $1,784,000 $2,214,000 $2,218,000 $2,098,000 $2,115,000 24% 24% 18% 19% $22.92 $28.45 $28.50 $26.96 $27.18 Bellflower, CA $1,441,000 $1,716,000 $1,823,000 $1,781,000 $1,791,000 19% 27% 24% 24% $19.34 $23.03 $24.47 $23.89 $24.03 Berkeley, CA $3,881,000 $2,421,000 $1,936,000 $1,957,000 $1,939,000 -38% -50% -50% -50% $37.45 $23.36 $18.68 $18.88 $18.71 Buena Park, CA $1,229,000 $1,404,000 $1,384,000 $1,280,000 $1,297,000 14% 13% 4% 6% $15.55 $17.77 $17.51 $16.20 $16.41 Burbank, CA $1,416,000 $1,539,000 $1,750,000 $1,170,000 $1,177,000 9% 24% -17% -17% $13.76 $14.95 $17.01 $11.37 $11.44 Camarillo, CA $430,000 $401,000 $381,000 $258,000 $257,000 -7% -11% -40% -40% $7.23 $6.74 $6.41 $4.34 $4.33 Carlsbad, CA $601,000 $528,000 $554,000 $349,000 $347,000 -12% -8% -42% -42% $6.94 $6.10 $6.40 $4.03 $4.00 Carson, CA $1,333,000 $1,495,000 $1,460,000 $1,293,000 $1,319,000 12% 9% -3% -1% $14.34 $16.09 $15.71 $13.91 $14.19 Cerritos, CA $471,000 $479,000 $424,000 $245,000 $250,000 2% -10% -48% -47% $8.95 $9.10 $8.06 $4.65 $4.75 Chico, CA $1,039,000 $758,000 $952,000 $960,000 $942,000 -27% -8% -8% -9% $15.77 $11.50 $14.44 $14.56 $14.29 Chino, CA $733,000 $798,000 $778,000 $599,000 $603,000 9% 6% -18% -18% $10.48 $11.40 $11.13 $8.56 $8.62 Chino Hills, CA $516,000 $496,000 $462,000 $271,000 $271,000 -4% -10% -47% -48% $7.14 $6.86 $6.39 $3.75 $3.74 Chula Vista, CA $2,379,000 $2,659,000 $2,753,000 $2,669,000 $2,674,000 12% 16% 12% 12% $12.27 $13.71 $14.20 $13.76 $13.79 Citrus Heights, CA $798,000 $789,000 $837,000 $736,000 $729,000 -1% 5% -8% -9% $9.01 $8.91 $9.45 $8.31 $8.24 Compton, CA $2,502,000 $3,208,000 $3,618,000 $3,825,000 $3,782,000 28% 45% 53% 51% $26.18 $33.57 $37.86 $40.02 $39.58

CDBG Formula Targeting to Community Development Need B-9

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Concord, CA $1,260,000 $1,293,000 $1,348,000 $1,215,000 $1,221,000 3% 7% -4% -3% $10.06 $10.32 $10.77 $9.70 $9.75 Contra Costa County, CA $4,144,000 $3,962,000 $4,270,000 $2,845,000 $2,834,000 -4% 3% -31% -32% $7.69 $7.35 $7.92 $5.28 $5.26 Corona, CA $1,437,000 $1,557,000 $1,574,000 $1,042,000 $1,045,000 8% 10% -27% -27% $10.39 $11.26 $11.38 $7.53 $7.55 Costa Mesa, CA $1,655,000 $1,776,000 $1,729,000 $1,428,000 $1,441,000 7% 4% -14% -13% $15.03 $16.12 $15.70 $12.97 $13.09 Cupertino City, CA $459,000 $465,000 $421,000 $224,000 $230,000 1% -8% -51% -50% $9.18 $9.29 $8.42 $4.48 $4.59 Daly City, CA $1,511,000 $1,635,000 $1,549,000 $1,332,000 $1,387,000 8% 3% -12% -8% $14.83 $16.05 $15.20 $13.08 $13.62 Davis, CA $988,000 $423,000 $476,000 $399,000 $400,000 -57% -52% -60% -60% $15.38 $6.59 $7.42 $6.22 $6.23 Downey, CA $1,810,000 $2,126,000 $2,199,000 $1,898,000 $1,926,000 17% 21% 5% 6% $16.48 $19.36 $20.02 $17.28 $17.54 El Cajon, CA $1,526,000 $1,752,000 $1,925,000 $1,976,000 $1,955,000 15% 26% 29% 28% $15.97 $18.33 $20.14 $20.68 $20.46 El Centro, CA $808,000 $1,021,000 $1,119,000 $887,000 $876,000 26% 38% 10% 8% $21.44 $27.10 $29.69 $23.54 $23.24 El Monte, CA $3,266,000 $4,140,000 $4,360,000 $4,356,000 $4,342,000 27% 34% 33% 33% $27.24 $34.52 $36.36 $36.32 $36.21 Elk Grove, CA $442,000 $391,000 $395,000 $292,000 $291,000 -11% -11% -34% -34% $5.88 $5.21 $5.25 $3.89 $3.87 Encinitas, CA $491,000 $437,000 $447,000 $276,000 $274,000 -11% -9% -44% -44% $8.21 $7.31 $7.48 $4.62 $4.59 Escondido, CA $2,105,000 $2,421,000 $2,459,000 $2,385,000 $2,387,000 15% 17% 13% 13% $15.49 $17.82 $18.09 $17.55 $17.56 Fairfield, CA $1,000,000 $1,056,000 $1,140,000 $993,000 $985,000 6% 14% -1% -2% $9.81 $10.36 $11.18 $9.74 $9.66 Fontana, CA $2,246,000 $2,674,000 $2,688,000 $2,593,000 $2,591,000 19% 20% 15% 15% $15.64 $18.62 $18.72 $18.06 $18.05

CDBG Formula Targeting to Community Development Need B-10

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Fountain Valley, CA $432,000 $427,000 $388,000 $278,000 $282,000 -1% -10% -36% -35% $7.78 $7.69 $6.98 $5.00 $5.07 Fremont, CA $2,041,000 $2,098,000 $1,914,000 $1,213,000 $1,245,000 3% -6% -41% -39% $9.87 $10.14 $9.25 $5.86 $6.02 Fresno, CA $9,186,000 $11,218,000 $13,124,000 $11,919,000 $11,680,000 22% 43% 30% 27% $20.63 $25.20 $29.48 $26.77 $26.23 Fresno County, CA $5,818,000 $6,929,000 $7,592,000 $6,012,000 $5,923,000 19% 30% 3% 2% $16.17 $19.26 $21.10 $16.71 $16.46 Fullerton, CA $1,831,000 $1,966,000 $1,953,000 $1,636,000 $1,652,000 7% 7% -11% -10% $14.21 $15.26 $15.16 $12.70 $12.82 Garden Grove, CA $3,160,000 $3,757,000 $3,631,000 $3,337,000 $3,380,000 19% 15% 6% 7% $18.87 $22.44 $21.69 $19.93 $20.19 Gardena, CA $1,118,000 $1,306,000 $1,386,000 $1,303,000 $1,311,000 17% 24% 17% 17% $18.74 $21.90 $23.24 $21.84 $21.97 Gilroy City, CA $583,000 $674,000 $689,000 $663,000 $667,000 16% 18% 14% 14% $13.51 $15.62 $15.97 $15.36 $15.45 Glendale, CA $3,978,000 $4,726,000 $5,119,000 $3,839,000 $3,866,000 19% 29% -3% -3% $19.95 $23.70 $25.67 $19.25 $19.39 Glendora City, CA $414,000 $408,000 $428,000 $277,000 $277,000 -2% 3% -33% -33% $8.19 $8.06 $8.47 $5.48 $5.48 Goleta, CA $326,000 $298,000 $284,000 $185,000 $190,000 -9% -13% -43% -42% $11.39 $10.42 $9.92 $6.47 $6.62 Hanford, CA $644,000 $761,000 $879,000 $693,000 $680,000 18% 37% 8% 6% $14.52 $17.17 $19.82 $15.63 $15.34 Hawthorne, CA $2,076,000 $2,495,000 $2,685,000 $2,603,000 $2,622,000 20% 29% 25% 26% $24.16 $29.03 $31.25 $30.29 $30.52 Hayward, CA $2,087,000 $2,304,000 $2,322,000 $2,168,000 $2,206,000 10% 11% 4% 6% $14.62 $16.14 $16.27 $15.19 $15.46 Hemet, CA $837,000 $948,000 $1,045,000 $980,000 $959,000 13% 25% 17% 15% $13.21 $14.96 $16.48 $15.46 $15.14 Hesperia, CA $851,000 $973,000 $1,004,000 $942,000 $925,000 14% 18% 11% 9% $12.70 $14.52 $14.98 $14.05 $13.81

CDBG Formula Targeting to Community Development Need B-11

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Huntington Beach, CA $1,684,000 $1,633,000 $1,616,000 $1,021,000 $1,023,000 -3% -4% -39% -39% $8.69 $8.42 $8.34 $5.27 $5.28 Huntington Park, CA $1,935,000 $2,471,000 $2,654,000 $2,636,000 $2,650,000 28% 37% 36% 37% $30.73 $39.23 $42.14 $41.86 $42.08 Inglewood, CA $2,709,000 $3,311,000 $3,859,000 $4,038,000 $4,025,000 22% 42% 49% 49% $23.56 $28.80 $33.57 $35.13 $35.01 Irvine, CA $1,521,000 $1,270,000 $1,203,000 $719,000 $728,000 -16% -21% -53% -52% $9.38 $7.83 $7.42 $4.43 $4.49 Kern County, CA $6,351,000 $7,693,000 $8,863,000 $8,209,000 $8,049,000 21% 40% 29% 27% $17.66 $21.39 $24.65 $22.83 $22.38 La Habra, CA $984,000 $1,149,000 $1,185,000 $1,151,000 $1,158,000 17% 20% 17% 18% $16.40 $19.15 $19.76 $19.19 $19.30 La Mesa, CA $539,000 $487,000 $569,000 $501,000 $498,000 -10% 6% -7% -8% $9.81 $8.86 $10.36 $9.12 $9.06 Laguna Niguel, CA $412,000 $360,000 $345,000 $200,000 $201,000 -13% -16% -51% -51% $6.53 $5.71 $5.48 $3.17 $3.19 Lake Forest, CA $594,000 $572,000 $530,000 $334,000 $339,000 -4% -11% -44% -43% $7.72 $7.43 $6.89 $4.33 $4.40 Lakewood, CA $886,000 $964,000 $1,006,000 $744,000 $750,000 9% 14% -16% -15% $10.93 $11.89 $12.41 $9.18 $9.25 Lancaster, CA $1,629,000 $1,875,000 $2,136,000 $2,244,000 $2,197,000 15% 31% 38% 35% $13.07 $15.05 $17.14 $18.01 $17.63 Livermore, CA $556,000 $538,000 $573,000 $434,000 $432,000 -3% 3% -22% -22% $7.26 $7.03 $7.48 $5.67 $5.64 Lompoc, CA $618,000 $715,000 $781,000 $805,000 $798,000 16% 26% 30% 29% $14.93 $17.27 $18.86 $19.45 $19.29 Long Beach, CA $10,522,000 $12,540,000 $15,137,000 $14,312,000 $14,213,000 19% 44% 36% 35% $22.27 $26.54 $32.04 $30.29 $30.09 Los Angeles, CA $86,758,000 $102,678,000 $120,194,000 $102,860,000 $102,553,000 18% 39% 19% 18% $22.84 $27.03 $31.64 $27.08 $26.99 Los Angeles County, CA $36,270,000 $42,505,000 $46,030,000 $33,764,000 $33,711,000 17% 27% -7% -7% $15.89 $18.63 $20.17 $14.79 $14.77

CDBG Formula Targeting to Community Development Need B-12

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Lynwood, CA $1,908,000 $2,406,000 $2,509,000 $2,460,000 $2,467,000 26% 32% 29% 29% $26.73 $33.70 $35.15 $34.46 $34.56 Madera, CA $1,150,000 $1,472,000 $1,629,000 $1,750,000 $1,712,000 28% 42% 52% 49% $24.88 $31.85 $35.26 $37.86 $37.04 Marin County, CA $1,960,000 $1,724,000 $2,053,000 $1,488,000 $1,482,000 -12% 5% -24% -24% $7.92 $6.96 $8.29 $6.01 $5.98 Marysville, CA $184,000 $203,000 $273,000 $270,000 $264,000 10% 49% 47% 44% $14.70 $16.22 $21.83 $21.53 $21.09 Merced, CA $1,499,000 $1,852,000 $2,156,000 $2,043,000 $2,006,000 24% 44% 36% 34% $21.97 $27.15 $31.60 $29.95 $29.40 Milpitas City, CA $711,000 $759,000 $669,000 $507,000 $530,000 7% -6% -29% -25% $11.16 $11.92 $10.50 $7.96 $8.32 Mission Viejo, CA $611,000 $539,000 $504,000 $301,000 $303,000 -12% -18% -51% -50% $6.34 $5.60 $5.23 $3.12 $3.14 Modesto, CA $2,854,000 $3,267,000 $3,695,000 $3,013,000 $2,969,000 14% 29% 6% 4% $14.02 $16.05 $18.15 $14.80 $14.58 Montebello, CA $1,276,000 $1,551,000 $1,702,000 $1,721,000 $1,724,000 22% 33% 35% 35% $20.06 $24.39 $26.76 $27.06 $27.11 Monterey, CA $277,000 $225,000 $261,000 $171,000 $171,000 -19% -6% -38% -38% $9.34 $7.58 $8.81 $5.75 $5.76 Monterey Park, CA $1,178,000 $1,400,000 $1,488,000 $1,393,000 $1,399,000 19% 26% 18% 19% $19.05 $22.64 $24.07 $22.54 $22.63 Moreno Valley, CA $2,082,000 $2,454,000 $2,569,000 $2,462,000 $2,431,000 18% 23% 18% 17% $13.81 $16.28 $17.04 $16.33 $16.13 Mountain View, CA $834,000 $827,000 $757,000 $425,000 $440,000 -1% -9% -49% -47% $11.91 $11.81 $10.80 $6.07 $6.29 Napa City, CA $834,000 $884,000 $946,000 $861,000 $862,000 6% 13% 3% 3% $11.12 $11.78 $12.61 $11.48 $11.49 National City, CA $1,324,000 $1,644,000 $1,806,000 $1,831,000 $1,833,000 24% 36% 38% 38% $23.84 $29.61 $32.51 $32.97 $33.00 Newport Beach, CA $437,000 $289,000 $293,000 $195,000 $194,000 -34% -33% -55% -56% $5.60 $3.69 $3.75 $2.49 $2.48

CDBG Formula Targeting to Community Development Need B-13

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Norwalk, CA $1,875,000 $2,228,000 $2,216,000 $2,061,000 $2,095,000 19% 18% 10% 12% $17.67 $21.00 $20.89 $19.42 $19.75 Oakland, CA $9,961,000 $10,153,000 $11,838,000 $13,779,000 $13,653,000 2% 19% 38% 37% $24.73 $25.21 $29.39 $34.21 $33.90 Oceanside, CA $2,199,000 $2,454,000 $2,520,000 $2,246,000 $2,243,000 12% 15% 2% 2% $13.26 $14.80 $15.19 $13.54 $13.52 Ontario, CA $2,927,000 $3,496,000 $3,610,000 $3,521,000 $3,526,000 19% 23% 20% 20% $17.73 $21.18 $21.87 $21.33 $21.36 Orange, CA $1,607,000 $1,794,000 $1,795,000 $1,483,000 $1,485,000 12% 12% -8% -8% $12.21 $13.63 $13.64 $11.27 $11.29 Orange County, CA $5,106,000 $5,182,000 $5,100,000 $3,237,000 $3,245,000 1% 0% -37% -36% $9.04 $9.17 $9.03 $5.73 $5.74 Oxnard, CA $3,306,000 $3,942,000 $3,869,000 $3,631,000 $3,659,000 19% 17% 10% 11% $18.57 $22.15 $21.74 $20.40 $20.56 Palm Desert, CA $415,000 $402,000 $411,000 $251,000 $249,000 -3% -1% -39% -40% $9.36 $9.07 $9.26 $5.67 $5.62 Palm Springs, CA $606,000 $632,000 $695,000 $444,000 $439,000 4% 15% -27% -28% $13.61 $14.19 $15.60 $9.98 $9.85 Palmdale, CA $1,783,000 $2,106,000 $2,223,000 $2,264,000 $2,229,000 18% 25% 27% 25% $14.34 $16.94 $17.87 $18.20 $17.93 Palo Alto, CA $816,000 $368,000 $412,000 $271,000 $271,000 -55% -49% -67% -67% $14.18 $6.39 $7.16 $4.70 $4.70 Paradise, CA $272,000 $272,000 $337,000 $284,000 $277,000 0% 24% 4% 2% $10.17 $10.17 $12.58 $10.62 $10.35 Paramount City, CA $1,464,000 $1,850,000 $1,913,000 $1,846,000 $1,853,000 26% 31% 26% 27% $25.92 $32.75 $33.86 $32.67 $32.80 Pasadena, CA $2,694,000 $2,529,000 $3,180,000 $2,151,000 $2,142,000 -6% 18% -20% -20% $19.28 $18.10 $22.76 $15.40 $15.33 Petaluma, CA $426,000 $403,000 $450,000 $369,000 $367,000 -5% 6% -13% -14% $7.71 $7.30 $8.15 $6.69 $6.64 Pico Rivera, CA $1,105,000 $1,329,000 $1,371,000 $1,332,000 $1,343,000 20% 24% 21% 22% $17.04 $20.49 $21.14 $20.54 $20.71

CDBG Formula Targeting to Community Development Need B-14

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Pittsburg, CA $783,000 $873,000 $938,000 $950,000 $949,000 12% 20% 21% 21% $12.94 $14.43 $15.49 $15.70 $15.67 Pleasanton City, CA $341,000 $273,000 $255,000 $152,000 $153,000 -20% -25% -55% -55% $5.15 $4.13 $3.85 $2.30 $2.31 Pomona, CA $3,436,000 $4,201,000 $4,465,000 $4,495,000 $4,483,000 22% 30% 31% 30% $22.38 $27.36 $29.08 $29.27 $29.19 Porterville, CA $851,000 $1,044,000 $1,227,000 $1,183,000 $1,161,000 23% 44% 39% 36% $20.60 $25.27 $29.70 $28.64 $28.11 Rancho Cucamonga, CA $1,180,000 $1,144,000 $1,169,000 $698,000 $696,000 -3% -1% -41% -41% $8.21 $7.96 $8.13 $4.86 $4.85 Redding, CA $1,006,000 $1,042,000 $1,289,000 $1,150,000 $1,122,000 4% 28% 14% 12% $11.74 $12.16 $15.04 $13.43 $13.10 Redlands, CA $687,000 $705,000 $840,000 $553,000 $547,000 3% 22% -19% -20% $10.29 $10.56 $12.59 $8.29 $8.20 Redondo Beach, CA $499,000 $420,000 $497,000 $331,000 $331,000 -16% 0% -34% -34% $7.58 $6.38 $7.55 $5.03 $5.03 Redwood City, CA $885,000 $933,000 $928,000 $726,000 $748,000 5% 5% -18% -15% $11.89 $12.53 $12.46 $9.75 $10.05 Rialto, CA $1,608,000 $1,950,000 $2,051,000 $2,064,000 $2,041,000 21% 28% 28% 27% $16.64 $20.19 $21.23 $21.36 $21.13 Richmond, CA $1,657,000 $1,919,000 $2,377,000 $2,634,000 $2,612,000 16% 43% 59% 58% $16.16 $18.72 $23.18 $25.69 $25.47 Riverside, CA $4,040,000 $4,382,000 $4,868,000 $4,035,000 $4,007,000 8% 20% 0% -1% $14.73 $15.98 $17.75 $14.71 $14.61 Riverside County, CA $12,028,000 $13,705,000 $14,257,000 $11,748,000 $11,598,000 14% 19% -2% -4% $12.96 $14.77 $15.37 $12.66 $12.50 Rosemead, CA $1,384,000 $1,732,000 $1,866,000 $1,897,000 $1,895,000 25% 35% 37% 37% $25.18 $31.52 $33.96 $34.52 $34.49 Roseville, CA $587,000 $513,000 $555,000 $389,000 $388,000 -13% -6% -34% -34% $6.40 $5.59 $6.04 $4.24 $4.23 Sacramento, CA $6,974,000 $7,862,000 $9,731,000 $10,484,000 $10,302,000 13% 40% 50% 48% $16.02 $18.06 $22.36 $24.09 $23.67

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need B-15

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Sacramento County, CA $7,971,000 $8,404,000 $9,245,000 $7,765,000 $7,654,000 5% 16% -3% -4% $11.29 $11.90 $13.09 $11.00 $10.84 Salinas, CA $3,004,000 $3,600,000 $3,600,000 $3,407,000 $3,431,000 20% 20% 13% 14% $20.20 $24.20 $24.20 $22.90 $23.07 San Bernardino, CA $4,274,000 $5,264,000 $6,150,000 $6,694,000 $6,575,000 23% 44% 57% 54% $22.30 $27.47 $32.10 $34.93 $34.31 San Bernardino County, CA $8,897,000 $10,312,000 $11,367,000 $10,682,000 $10,518,000 16% 28% 20% 18% $14.85 $17.21 $18.97 $17.83 $17.55 San Buenaventura, CA $1,062,000 $1,082,000 $1,241,000 $1,039,000 $1,034,000 2% 17% -2% -3% $10.25 $10.44 $11.97 $10.02 $9.98 San Diego, CA $18,260,000 $19,394,000 $21,544,000 $17,519,000 $17,435,000 6% 18% -4% -5% $14.50 $15.40 $17.10 $13.91 $13.84 San Diego County, CA $5,712,000 $5,903,000 $6,187,000 $4,596,000 $4,565,000 3% 8% -20% -20% $9.70 $10.03 $10.51 $7.81 $7.75 San Francisco, CA $25,256,000 $15,602,000 $15,507,000 $15,658,000 $15,699,000 -38% -39% -38% -38% $33.06 $20.42 $20.30 $20.49 $20.55 San Joaquin County, CA $4,246,000 $4,698,000 $5,306,000 $4,241,000 $4,189,000 11% 25% 0% -1% $12.08 $13.37 $15.10 $12.07 $11.92 San Jose, CA $12,146,000 $13,352,000 $13,086,000 $11,771,000 $11,981,000 10% 8% -3% -1% $13.49 $14.83 $14.53 $13.07 $13.31 San Leandro, CA $895,000 $920,000 $1,027,000 $979,000 $997,000 3% 15% 9% 11% $11.10 $11.41 $12.74 $12.15 $12.36 San Luis Obispo County, CA $2,526,000 $2,093,000 $2,445,000 $2,217,000 $2,191,000 -17% -3% -12% -13% $10.78 $8.93 $10.44 $9.47 $9.35 San Marcos City, CA $811,000 $909,000 $867,000 $806,000 $806,000 12% 7% -1% -1% $13.05 $14.64 $13.95 $12.97 $12.98 San Mateo, CA $963,000 $968,000 $999,000 $788,000 $803,000 1% 4% -18% -17% $10.47 $10.53 $10.87 $8.57 $8.73 San Mateo County, CA $3,460,000 $3,436,000 $3,490,000 $2,361,000 $2,396,000 -1% 1% -32% -31% $9.23 $9.16 $9.31 $6.30 $6.39 Santa Ana, CA $8,363,000 $10,412,000 $10,223,000 $9,571,000 $9,646,000 24% 22% 14% 15% $24.35 $30.32 $29.77 $27.87 $28.09

CDBG Formula Targeting to Community Development Need B-16

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Santa Barbara, CA $1,319,000 $1,317,000 $1,547,000 $1,163,000 $1,164,000 0% 17% -12% -12% $14.76 $14.74 $17.31 $13.01 $13.02 Santa Clara, CA $1,298,000 $1,289,000 $1,227,000 $892,000 $921,000 -1% -5% -31% -29% $12.74 $12.65 $12.05 $8.76 $9.04 Santa Clara County, CA $2,143,000 $2,011,000 $2,029,000 $1,227,000 $1,232,000 -6% -5% -43% -43% $8.02 $7.53 $7.60 $4.59 $4.61 Santa Clarita, CA $1,361,000 $1,366,000 $1,344,000 $807,000 $808,000 0% -1% -41% -41% $8.48 $8.51 $8.37 $5.03 $5.03 Santa Cruz, CA $737,000 $613,000 $770,000 $747,000 $744,000 -17% 5% 1% 1% $13.69 $11.38 $14.31 $13.88 $13.82 Santa Maria, CA $1,529,000 $1,870,000 $1,952,000 $1,974,000 $1,956,000 22% 28% 29% 28% $19.11 $23.37 $24.40 $24.67 $24.45 Santa Monica, CA $1,635,000 $892,000 $1,062,000 $763,000 $761,000 -45% -35% -53% -53% $18.84 $10.28 $12.24 $8.79 $8.77 Santa Rosa, CA $1,532,000 $1,498,000 $1,633,000 $1,410,000 $1,410,000 -2% 7% -8% -8% $9.98 $9.76 $10.64 $9.19 $9.19 Santee, CA $388,000 $360,000 $391,000 $342,000 $341,000 -7% 1% -12% -12% $7.29 $6.77 $7.34 $6.43 $6.41 Seaside, CA $492,000 $563,000 $563,000 $540,000 $543,000 14% 14% 10% 10% $15.22 $17.40 $17.41 $16.71 $16.81 Simi Valley, CA $878,000 $853,000 $841,000 $620,000 $616,000 -3% -4% -29% -30% $7.53 $7.32 $7.21 $5.32 $5.29 Sonoma County, CA $2,435,000 $2,271,000 $2,619,000 $2,233,000 $2,224,000 -7% 8% -8% -9% $9.38 $8.75 $10.09 $8.60 $8.57 South Gate, CA $2,552,000 $3,211,000 $3,396,000 $3,322,000 $3,353,000 26% 33% 30% 31% $25.83 $32.51 $34.37 $33.62 $33.94 South San Francisco, CA $728,000 $784,000 $732,000 $625,000 $651,000 8% 1% -14% -11% $12.14 $13.07 $12.20 $10.43 $10.85 Stanislaus County, CA $2,288,000 $2,705,000 $3,063,000 $2,656,000 $2,619,000 18% 34% 16% 14% $16.02 $18.94 $21.45 $18.60 $18.34 Stockton, CA $5,022,000 $6,100,000 $7,076,000 $6,962,000 $6,840,000 21% 41% 39% 36% $19.11 $23.21 $26.92 $26.49 $26.02

CDBG Formula Targeting to Community Development Need B-17

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Sunnyvale, CA $1,504,000 $1,551,000 $1,412,000 $849,000 $885,000 3% -6% -44% -41% $11.60 $11.96 $10.89 $6.55 $6.82 Thousand Oaks, CA $831,000 $770,000 $733,000 $436,000 $434,000 -7% -12% -48% -48% $6.77 $6.27 $5.97 $3.55 $3.54 Torrance, CA $1,436,000 $1,458,000 $1,474,000 $846,000 $860,000 2% 3% -41% -40% $10.14 $10.30 $10.41 $5.98 $6.07 Tulare, CA $819,000 $1,013,000 $1,127,000 $986,000 $969,000 24% 38% 20% 18% $17.81 $22.04 $24.51 $21.45 $21.07 Turlock, CA $890,000 $976,000 $1,081,000 $914,000 $906,000 10% 22% 3% 2% $14.44 $15.84 $17.54 $14.83 $14.69 Tustin, CA $977,000 $1,085,000 $1,027,000 $711,000 $731,000 11% 5% -27% -25% $14.23 $15.80 $14.96 $10.36 $10.65 Union City, CA $785,000 $855,000 $788,000 $687,000 $703,000 9% 0% -12% -10% $11.23 $12.24 $11.27 $9.83 $10.06 Upland, CA $855,000 $927,000 $1,042,000 $667,000 $660,000 8% 22% -22% -23% $12.05 $13.06 $14.67 $9.40 $9.30 Vacaville, CA $686,000 $655,000 $674,000 $546,000 $545,000 -5% -2% -20% -21% $7.33 $7.00 $7.20 $5.84 $5.83 Vallejo, CA $1,438,000 $1,537,000 $1,863,000 $1,726,000 $1,724,000 7% 30% 20% 20% $12.00 $12.83 $15.56 $14.41 $14.39 Ventura County, CA $2,450,000 $2,714,000 $2,871,000 $2,350,000 $2,351,000 11% 17% -4% -4% $12.03 $13.33 $14.10 $11.54 $11.55 Victorville, CA $1,032,000 $1,225,000 $1,382,000 $1,460,000 $1,428,000 19% 34% 41% 38% $14.57 $17.29 $19.51 $20.62 $20.16 Visalia, CA $1,413,000 $1,659,000 $1,852,000 $1,202,000 $1,181,000 17% 31% -15% -16% $14.58 $17.13 $19.11 $12.40 $12.19 Vista, CA $1,443,000 $1,663,000 $1,700,000 $1,655,000 $1,653,000 15% 18% 15% 15% $15.76 $18.16 $18.57 $18.07 $18.05 Walnut Creek, CA $396,000 $315,000 $306,000 $185,000 $186,000 -20% -23% -53% -53% $6.06 $4.82 $4.68 $2.83 $2.85 Watsonville, CA $1,031,000 $1,264,000 $1,358,000 $1,365,000 $1,366,000 23% 32% 32% 33% $22.10 $27.09 $29.11 $29.26 $29.29

CDBG Formula Targeting to Community Development Need B-18

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 West Covina, CA $1,450,000 $1,616,000 $1,556,000 $1,211,000 $1,232,000 11% 7% -16% -15% $13.46 $15.00 $14.45 $11.25 $11.44 Westminster, CA $1,512,000 $1,787,000 $1,735,000 $1,631,000 $1,640,000 18% 15% 8% 8% $16.89 $19.97 $19.39 $18.22 $18.32 Whittier, CA $1,149,000 $1,293,000 $1,418,000 $1,110,000 $1,115,000 13% 23% -3% -3% $13.45 $15.14 $16.59 $12.99 $13.05 Woodland, CA $701,000 $776,000 $828,000 $825,000 $825,000 11% 18% 18% 18% $13.79 $15.25 $16.29 $16.22 $16.23 Yorba Linda, CA $325,000 $279,000 $250,000 $150,000 $149,000 -14% -23% -54% -54% $5.32 $4.56 $4.09 $2.45 $2.44 Yuba City, CA $635,000 $721,000 $833,000 $728,000 $718,000 14% 31% 15% 13% $13.45 $15.27 $17.63 $15.43 $15.21 California State Program $49,911,000 $53,918,000 $39,579,000 $39,579,000 $45,382,000 8% -21% -21% -9% $15.53 $16.77 $12.31 $12.31 $14.12 TOTAL $553,750,000 $606,191,000 $642,593,000 $564,983,000 $569,091,000 9% 16% 2% 3% $15.78 $17.27 $18.31 $16.10 $16.21

Colorado Adams County, CO $1,988,000 $1,949,000 $2,038,000 $1,597,000 $1,585,000 -2% 2% -20% -20% $8.11 $7.96 $8.32 $6.52 $6.47 Arapahoe County, CO $1,221,000 $1,086,000 $1,214,000 $882,000 $877,000 -11% -1% -28% -28% $7.59 $6.75 $7.55 $5.48 $5.45 Arvada, CO $618,000 $529,000 $585,000 $552,000 $540,000 -14% -5% -11% -13% $6.05 $5.17 $5.73 $5.40 $5.29 Aurora, CO $2,951,000 $3,104,000 $3,357,000 $3,370,000 $3,359,000 5% 14% 14% 14% $10.32 $10.85 $11.74 $11.78 $11.74 Boulder, CO $1,141,000 $633,000 $804,000 $807,000 $799,000 -45% -30% -29% -30% $12.12 $6.72 $8.53 $8.57 $8.48 Centennial, CO $380,000 $248,000 $223,000 $153,000 $150,000 -35% -41% -60% -61% $3.82 $2.50 $2.24 $1.53 $1.51 Colorado Springs, CO $3,101,000 $2,886,000 $3,599,000 $3,248,000 $3,192,000 -7% 16% 5% 3% $8.35 $7.77 $9.69 $8.75 $8.60

CDBG Formula Targeting to Community Development Need B-19

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Denver, CO $11,025,000 $9,697,000 $10,490,000 $10,888,000 $10,750,000 -12% -5% -1% -2% $19.67 $17.30 $18.72 $19.43 $19.18 Douglas County, CO $694,000 $473,000 $401,000 $261,000 $257,000 -32% -42% -62% -63% $4.06 $2.77 $2.35 $1.53 $1.51 Fort Collins, CO $1,219,000 $713,000 $893,000 $920,000 $902,000 -42% -27% -25% -26% $9.78 $5.72 $7.17 $7.38 $7.23 Grand Junction, CO $407,000 $413,000 $503,000 $476,000 $466,000 1% 24% 17% 14% $9.43 $9.56 $11.65 $11.02 $10.79 Greeley, CO $1,031,000 $963,000 $1,218,000 $1,212,000 $1,189,000 -7% 18% 18% 15% $12.56 $11.73 $14.83 $14.76 $14.48 Jefferson County, CO $1,362,000 $1,058,000 $1,179,000 $890,000 $877,000 -22% -13% -35% -36% $5.62 $4.36 $4.86 $3.67 $3.62 Lakewood, CO $1,125,000 $1,004,000 $1,167,000 $1,036,000 $1,025,000 -11% 4% -8% -9% $7.83 $6.98 $8.12 $7.20 $7.13 Longmont, CO $648,000 $643,000 $726,000 $507,000 $501,000 -1% 12% -22% -23% $8.23 $8.17 $9.22 $6.45 $6.37 Loveland, CO $347,000 $304,000 $372,000 $376,000 $370,000 -12% 7% 8% 7% $6.28 $5.50 $6.73 $6.81 $6.69 Pueblo, CO $1,971,000 $2,440,000 $2,305,000 $2,564,000 $2,503,000 24% 17% 30% 27% $19.06 $23.59 $22.29 $24.80 $24.20 Westminster, CO $681,000 $595,000 $607,000 $502,000 $501,000 -13% -11% -26% -26% $6.57 $5.74 $5.86 $4.85 $4.84 Colorado State Program $13,006,000 $12,719,000 $12,275,000 $12,275,000 $13,278,000 -2% -6% -6% 2% $9.06 $8.86 $8.55 $8.55 $9.25 TOTAL $44,916,000 $41,456,000 $43,955,000 $42,516,000 $43,120,000 -8% -2% -5% -4% $9.97 $9.21 $9.76 $9.44 $9.57

Connecticut Bridgeport, CT $3,946,000 $3,965,000 $3,660,000 $4,590,000 $4,499,000 0% -7% 16% 14% $28.16 $28.30 $26.12 $32.76 $32.11 Bristol, CT $714,000 $539,000 $570,000 $666,000 $652,000 -25% -20% -7% -9% $11.79 $8.90 $9.41 $11.00 $10.77

CDBG Formula Targeting to Community Development Need B-20

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Danbury, CT $756,000 $707,000 $868,000 $984,000 $979,000 -6% 15% 30% 29% $9.83 $9.19 $11.28 $12.80 $12.72 East Hartford, CT $748,000 $754,000 $759,000 $920,000 $903,000 1% 1% 23% 21% $15.07 $15.19 $15.28 $18.53 $18.20 Fairfield, CT $628,000 $195,000 $217,000 $198,000 $194,000 -69% -65% -68% -69% $10.88 $3.39 $3.76 $3.43 $3.36 Greenwich, CT $1,115,000 $333,000 $372,000 $283,000 $279,000 -70% -67% -75% -75% $18.05 $5.38 $6.03 $4.59 $4.51 Hamden Town, CT $602,000 $470,000 $509,000 $498,000 $488,000 -22% -15% -17% -19% $10.39 $8.11 $8.79 $8.60 $8.42 Hartford, CT $4,672,000 $5,642,000 $5,108,000 $6,513,000 $6,367,000 21% 9% 39% 36% $37.51 $45.30 $41.01 $52.29 $51.12 Manchester, CT $779,000 $576,000 $646,000 $662,000 $650,000 -26% -17% -15% -17% $14.14 $10.46 $11.72 $12.02 $11.80 Meriden, CT $1,094,000 $935,000 $899,000 $1,092,000 $1,067,000 -15% -18% 0% -2% $18.65 $15.93 $15.32 $18.61 $18.19 Middletown, CT $533,000 $408,000 $398,000 $430,000 $422,000 -24% -25% -19% -21% $12.07 $9.23 $9.01 $9.73 $9.57 Milford Town, CT $639,000 $246,000 $286,000 $248,000 $244,000 -61% -55% -61% -62% $11.95 $4.61 $5.36 $4.64 $4.56 New Britain, CT $2,266,000 $2,121,000 $1,698,000 $2,226,000 $2,181,000 -6% -25% -2% -4% $31.65 $29.62 $23.72 $31.09 $30.47 New Haven, CT $4,481,000 $4,446,000 $3,698,000 $4,823,000 $4,712,000 -1% -17% 8% 5% $36.09 $35.81 $29.78 $38.84 $37.95 New London, CT $1,086,000 $727,000 $531,000 $693,000 $680,000 -33% -51% -36% -37% $41.66 $27.90 $20.37 $26.60 $26.08 Norwalk, CT $1,107,000 $690,000 $899,000 $1,009,000 $999,000 -38% -19% -9% -10% $13.16 $8.20 $10.69 $11.99 $11.87 Norwich, CT $1,215,000 $818,000 $627,000 $801,000 $785,000 -33% -48% -34% -35% $33.75 $22.73 $17.41 $22.26 $21.80 Stamford, CT $1,300,000 $1,142,000 $1,397,000 $1,368,000 $1,362,000 -12% 7% 5% 5% $10.85 $9.53 $11.66 $11.41 $11.36

CDBG Formula Targeting to Community Development Need B-21

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Stratford, CT $796,000 $466,000 $377,000 $483,000 $474,000 -41% -53% -39% -40% $15.87 $9.29 $7.51 $9.63 $9.44 Waterbury, CT $2,713,000 $2,712,000 $2,440,000 $3,172,000 $3,101,000 0% -10% 17% 14% $25.15 $25.14 $22.61 $29.40 $28.74 West Hartford, CT $1,306,000 $371,000 $413,000 $334,000 $329,000 -72% -68% -74% -75% $21.28 $6.04 $6.73 $5.44 $5.36 West Haven, CT $852,000 $580,000 $656,000 $737,000 $727,000 -32% -23% -13% -15% $16.16 $10.99 $12.43 $13.98 $13.78 Connecticut State Program $15,862,000 $9,740,000 $9,496,000 $9,496,000 $9,865,000 -39% -40% -40% -38% $8.41 $5.17 $5.04 $5.04 $5.23 TOTAL $49,210,000 $38,584,000 $36,523,000 $42,227,000 $41,959,000 -22% -26% -14% -15% $14.22 $11.15 $10.55 $12.20 $12.13

Delaware Dover, DE $326,000 $327,000 $457,000 $420,000 $409,000 0% 40% 29% 26% $10.01 $10.03 $14.03 $12.88 $12.56 New Castle County, DE $2,888,000 $2,386,000 $2,951,000 $2,551,000 $2,508,000 -17% 2% -12% -13% $6.57 $5.43 $6.71 $5.80 $5.70 Wilmington, DE $2,999,000 $2,704,000 $2,106,000 $2,681,000 $2,617,000 -10% -30% -11% -13% $41.36 $37.29 $29.04 $36.97 $36.10 Delaware State Program $2,296,000 $2,400,000 $2,597,000 $2,597,000 $2,688,000 5% 13% 13% 17% $8.75 $9.14 $9.90 $9.90 $10.24 TOTAL $8,509,000 $7,817,000 $8,111,000 $8,249,000 $8,222,000 -8% -5% -3% -3% $10.54 $9.68 $10.05 $10.22 $10.18

District of Columbia Washington, DC $22,462,000 $18,635,000 $15,340,000 $15,807,000 $15,567,000 -17% -32% -30% -31% $39.35 $32.64 $26.87 $27.69 $27.27

Florida Boca Raton, FL $540,000 $451,000 $465,000 $301,000 $296,000 -16% -14% -44% -45% $6.98 $5.83 $6.01 $3.89 $3.82

CDBG Formula Targeting to Community Development Need B-22

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Boynton Beach, FL $636,000 $676,000 $701,000 $722,000 $712,000 6% 10% 14% 12% $9.99 $10.61 $11.01 $11.34 $11.18 Bradenton, FL $582,000 $615,000 $756,000 $862,000 $844,000 6% 30% 48% 45% $11.33 $11.98 $14.72 $16.78 $16.42 Brevard County, FL $1,964,000 $1,774,000 $1,915,000 $1,525,000 $1,482,000 -10% -2% -22% -25% $6.98 $6.31 $6.81 $5.42 $5.27 Broward County, FL $5,543,000 $6,033,000 $6,441,000 $5,350,000 $5,275,000 9% 16% -3% -5% $11.86 $12.91 $13.78 $11.44 $11.28 Cape Coral, FL $748,000 $690,000 $711,000 $722,000 $702,000 -8% -5% -3% -6% $6.63 $6.11 $6.30 $6.39 $6.22 Clearwater, FL $1,143,000 $1,116,000 $1,371,000 $1,193,000 $1,168,000 -2% 20% 4% 2% $10.55 $10.30 $12.66 $11.01 $10.79 Cocoa, FL $278,000 $322,000 $410,000 $474,000 $460,000 16% 47% 70% 65% $16.95 $19.60 $24.99 $28.89 $28.02 Collier County, FL $2,628,000 $2,741,000 $2,695,000 $2,354,000 $2,328,000 4% 3% -10% -11% $10.31 $10.75 $10.58 $9.24 $9.13 Coral Springs, FL $1,092,000 $1,128,000 $1,194,000 $890,000 $880,000 3% 9% -19% -19% $8.69 $8.98 $9.50 $7.08 $7.00 Davie, FL $764,000 $727,000 $772,000 $629,000 $622,000 -5% 1% -18% -19% $9.57 $9.11 $9.67 $7.88 $7.78 Daytona Beach, FL $999,000 $1,127,000 $1,400,000 $1,551,000 $1,513,000 13% 40% 55% 51% $15.46 $17.45 $21.67 $24.01 $23.43 Deerfield Beach, FL $731,000 $772,000 $823,000 $696,000 $681,000 6% 13% -5% -7% $11.14 $11.77 $12.55 $10.61 $10.38 Delray Beach, FL $700,000 $745,000 $820,000 $689,000 $679,000 6% 17% -2% -3% $11.24 $11.97 $13.17 $11.07 $10.90 Deltona, FL $589,000 $605,000 $634,000 $630,000 $617,000 3% 8% 7% 5% $7.98 $8.20 $8.59 $8.54 $8.36 Destin, FL $72,000 $53,000 $55,000 $35,000 $34,000 -26% -23% -52% -52% $6.18 $4.56 $4.74 $2.98 $2.95 Escambia County, FL $2,538,000 $2,685,000 $3,343,000 $3,291,000 $3,192,000 6% 32% 30% 26% $10.56 $11.18 $13.92 $13.70 $13.29

CDBG Formula Targeting to Community Development Need B-23

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Fort Pierce, FL $829,000 $995,000 $1,201,000 $1,361,000 $1,323,000 20% 45% 64% 60% $21.82 $26.19 $31.61 $35.82 $34.83 Fort Walton Beach, FL $176,000 $168,000 $207,000 $184,000 $180,000 -4% 17% 5% 2% $8.76 $8.37 $10.28 $9.16 $8.95 Fort Lauderdale, FL $2,357,000 $2,492,000 $2,897,000 $2,113,000 $2,081,000 6% 23% -10% -12% $14.90 $15.76 $18.31 $13.36 $13.16 Fort Myers, FL $812,000 $914,000 $1,100,000 $1,212,000 $1,187,000 13% 35% 49% 46% $16.25 $18.29 $22.02 $24.26 $23.75 Gainesville, FL $1,483,000 $1,062,000 $1,423,000 $1,503,000 $1,465,000 -28% -4% 1% -1% $15.58 $11.16 $14.96 $15.79 $15.39 Hialeah, FL $5,147,000 $6,277,000 $6,335,000 $6,030,000 $6,067,000 22% 23% 17% 18% $22.56 $27.51 $27.77 $26.43 $26.59 Hillsborough County, FL $7,074,000 $7,074,000 $7,687,000 $6,492,000 $6,392,000 0% 9% -8% -10% $9.58 $9.58 $10.41 $8.79 $8.65 Hollywood, FL $1,846,000 $1,966,000 $2,171,000 $1,900,000 $1,881,000 7% 18% 3% 2% $12.89 $13.73 $15.16 $13.27 $13.14 Jacksonville-Duval, FL $8,166,000 $8,443,000 $10,942,000 $10,563,000 $10,345,000 3% 34% 29% 27% $10.15 $10.49 $13.60 $13.13 $12.86 Kissimmee, FL $724,000 $791,000 $867,000 $887,000 $879,000 9% 20% 23% 21% $14.00 $15.30 $16.76 $17.15 $16.99 Lake County, FL $1,013,000 $957,000 $1,010,000 $926,000 $900,000 -5% 0% -9% -11% $6.77 $6.40 $6.75 $6.19 $6.02 Lakeland, FL $933,000 $964,000 $1,273,000 $1,134,000 $1,104,000 3% 36% 22% 18% $10.83 $11.19 $14.77 $13.16 $12.81 Largo, FL $568,000 $520,000 $587,000 $555,000 $540,000 -8% 3% -2% -5% $8.04 $7.36 $8.31 $7.86 $7.65 Lauderhill, FL $990,000 $1,146,000 $1,255,000 $1,262,000 $1,250,000 16% 27% 27% 26% $16.83 $19.48 $21.33 $21.46 $21.25 Lee County, FL $2,568,000 $2,493,000 $2,553,000 $1,985,000 $1,941,000 -3% -1% -23% -24% $8.21 $7.97 $8.16 $6.35 $6.21 Manatee County, FL $1,814,000 $1,766,000 $1,878,000 $1,674,000 $1,637,000 -3% 4% -8% -10% $8.20 $7.98 $8.49 $7.56 $7.40

CDBG Formula Targeting to Community Development Need B-24

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Margate, FL $510,000 $524,000 $535,000 $491,000 $486,000 3% 5% -4% -5% $9.31 $9.57 $9.76 $8.96 $8.87 Marion County, FL $2,059,000 $2,152,000 $2,351,000 $2,105,000 $2,039,000 5% 14% 2% -1% $9.40 $9.83 $10.74 $9.62 $9.31 Melbourne, FL $677,000 $642,000 $709,000 $699,000 $680,000 -5% 5% 3% 0% $9.17 $8.69 $9.61 $9.47 $9.22 Miami, FL $9,928,000 $11,963,000 $14,543,000 $15,636,000 $15,518,000 20% 46% 57% 56% $26.49 $31.92 $38.80 $41.72 $41.40 Miami Beach, FL $2,118,000 $2,292,000 $2,914,000 $1,947,000 $1,951,000 8% 38% -8% -8% $23.64 $25.58 $32.53 $21.74 $21.78 Miami-Dade County, FL $23,676,000 $27,354,000 $28,802,000 $21,127,000 $21,067,000 16% 22% -11% -11% $15.39 $17.78 $18.72 $13.73 $13.69 Miramar, FL $906,000 $964,000 $973,000 $919,000 $928,000 6% 7% 1% 2% $10.03 $10.66 $10.77 $10.17 $10.27 Naples, FL $137,000 $121,000 $120,000 $79,000 $77,000 -12% -12% -42% -44% $6.47 $5.71 $5.68 $3.74 $3.65 North Miami, FL $1,503,000 $1,818,000 $2,027,000 $2,071,000 $2,067,000 21% 35% 38% 37% $25.04 $30.28 $33.76 $34.50 $34.42 Ocala, FL $576,000 $612,000 $754,000 $682,000 $662,000 6% 31% 18% 15% $12.27 $13.03 $16.06 $14.53 $14.10 Orange County, FL $7,330,000 $7,310,000 $7,875,000 $6,718,000 $6,620,000 0% 7% -8% -10% $10.30 $10.27 $11.07 $9.44 $9.30 Orlando, FL $2,657,000 $2,881,000 $3,475,000 $3,051,000 $3,005,000 8% 31% 15% 13% $13.72 $14.87 $17.94 $15.75 $15.51 Palm Bay, FL $716,000 $719,000 $795,000 $857,000 $837,000 0% 11% 20% 17% $8.62 $8.66 $9.58 $10.32 $10.08 Palm Beach County, FL $8,274,000 $8,506,000 $9,053,000 $8,079,000 $7,961,000 3% 9% -2% -4% $9.31 $9.57 $10.19 $9.09 $8.96 Panama City, FL $477,000 $591,000 $642,000 $662,000 $643,000 24% 35% 39% 35% $12.99 $16.10 $17.49 $18.02 $17.51 Pasco County, FL $2,935,000 $2,943,000 $3,176,000 $3,352,000 $3,243,000 0% 8% 14% 11% $8.37 $8.40 $9.06 $9.57 $9.25

CDBG Formula Targeting to Community Development Need B-25

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Pembroke Pines, FL $1,086,000 $1,046,000 $1,039,000 $787,000 $788,000 -4% -4% -28% -27% $7.41 $7.13 $7.08 $5.37 $5.37 Pensacola, FL $1,133,000 $1,204,000 $1,098,000 $994,000 $968,000 6% -3% -12% -15% $20.51 $21.80 $19.88 $17.99 $17.52 Pinellas County, FL $3,701,000 $3,381,000 $3,915,000 $3,094,000 $3,014,000 -9% 6% -16% -19% $7.41 $6.77 $7.84 $6.20 $6.04 Plantation, FL $634,000 $570,000 $599,000 $404,000 $400,000 -10% -6% -36% -37% $7.47 $6.72 $7.06 $4.76 $4.72 Polk County, FL $3,646,000 $3,925,000 $4,459,000 $4,006,000 $3,910,000 8% 22% 10% 7% $10.24 $11.03 $12.53 $11.26 $10.99 Pompano Beach, FL $1,252,000 $1,360,000 $1,442,000 $1,199,000 $1,180,000 9% 15% -4% -6% $14.37 $15.61 $16.54 $13.76 $13.53 Port St. Lucie, FL $715,000 $696,000 $717,000 $770,000 $750,000 -3% 0% 8% 5% $7.26 $7.06 $7.27 $7.82 $7.61 Punta Gorda, FL $97,000 $80,000 $80,000 $53,000 $52,000 -18% -18% -45% -47% $6.06 $4.99 $4.97 $3.33 $3.23 Sarasota, FL $688,000 $701,000 $885,000 $906,000 $887,000 2% 29% 32% 29% $12.90 $13.14 $16.60 $17.00 $16.64 Sarasota County, FL $1,769,000 $1,551,000 $1,648,000 $1,357,000 $1,320,000 -12% -7% -23% -25% $6.29 $5.51 $5.86 $4.82 $4.69 Seminole County, FL $2,886,000 $2,629,000 $2,922,000 $2,196,000 $2,159,000 -9% 1% -24% -25% $7.56 $6.89 $7.66 $5.75 $5.66 St. Petersburg, FL $2,716,000 $2,995,000 $3,868,000 $3,885,000 $3,804,000 10% 42% 43% 40% $10.93 $12.05 $15.56 $15.63 $15.30 Sunrise, FL $895,000 $965,000 $1,025,000 $1,033,000 $1,020,000 8% 14% 15% 14% $10.12 $10.90 $11.58 $11.67 $11.53 Tallahassee, FL $2,310,000 $1,499,000 $1,880,000 $1,791,000 $1,752,000 -35% -19% -22% -24% $14.89 $9.66 $12.11 $11.54 $11.29 Tamarac, FL $509,000 $513,000 $535,000 $468,000 $459,000 1% 5% -8% -10% $8.86 $8.93 $9.31 $8.15 $7.99 Tampa, FL $4,505,000 $5,402,000 $6,592,000 $6,146,000 $6,025,000 20% 46% 36% 34% $14.30 $17.14 $20.92 $19.50 $19.12

CDBG Formula Targeting to Community Development Need B-26

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Titusville, FL $406,000 $401,000 $499,000 $523,000 $509,000 -1% 23% 29% 25% $9.87 $9.76 $12.13 $12.71 $12.37 Volusia County, FL $2,677,000 $2,573,000 $3,055,000 $2,702,000 $2,628,000 -4% 14% 1% -2% $8.41 $8.08 $9.60 $8.49 $8.26 West Palm Beach, FL $1,304,000 $1,420,000 $1,878,000 $2,192,000 $2,155,000 9% 44% 68% 65% $15.07 $16.42 $21.70 $25.34 $24.91 Winterhaven, FL $319,000 $341,000 $445,000 $377,000 $369,000 7% 39% 18% 16% $12.07 $12.90 $16.84 $14.27 $13.95 Florida State Program $33,334,000 $34,950,000 $30,703,000 $30,703,000 $32,498,000 5% -8% -8% -3% $10.76 $11.28 $9.91 $9.91 $10.49 TOTAL $189,108,000 $199,883,000 $215,919,000 $195,762,000 $195,084,000 6% 14% 4% 3% $11.32 $11.96 $12.92 $11.71 $11.67

Georgia Albany, GA $1,402,000 $1,610,000 $2,112,000 $2,148,000 $2,087,000 15% 51% 53% 49% $18.37 $21.09 $27.67 $28.15 $27.35 Athens-Clarke, GA $1,765,000 $1,207,000 $1,632,000 $1,664,000 $1,628,000 -32% -8% -6% -8% $16.99 $11.62 $15.71 $16.02 $15.67 Atlanta, GA $11,284,000 $10,879,000 $10,834,000 $10,019,000 $9,781,000 -4% -4% -11% -13% $26.56 $25.61 $25.50 $23.58 $23.02 Augusta, GA $2,755,000 $3,098,000 $4,272,000 $4,445,000 $4,324,000 12% 55% 61% 57% $13.93 $15.66 $21.59 $22.47 $21.85 Brunswick, GA $548,000 $625,000 $562,000 $704,000 $685,000 14% 3% 28% 25% $35.13 $40.04 $36.02 $45.13 $43.91 Clayton County, GA $2,182,000 $2,303,000 $2,669,000 $2,776,000 $2,747,000 6% 22% 27% 26% $9.70 $10.24 $11.87 $12.34 $12.21 Cobb County, GA $3,921,000 $3,457,000 $3,640,000 $2,678,000 $2,653,000 -12% -7% -32% -32% $6.65 $5.86 $6.17 $4.54 $4.50 Columbus-Muscogee, GA $2,189,000 $2,405,000 $2,763,000 $2,299,000 $2,231,000 10% 26% 5% 2% $11.77 $12.93 $14.86 $12.36 $12.00 Dalton, GA $487,000 $562,000 $593,000 $418,000 $416,000 15% 22% -14% -15% $16.29 $18.80 $19.84 $13.97 $13.91

CDBG Formula Targeting to Community Development Need B-27

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 DeKalb County, GA $6,893,000 $7,025,000 $8,044,000 $7,002,000 $6,938,000 2% 17% 2% 1% $10.67 $10.87 $12.45 $10.83 $10.74 Fulton County, GA $3,149,000 $3,106,000 $3,648,000 $2,386,000 $2,352,000 -1% 16% -24% -25% $8.91 $8.78 $10.32 $6.75 $6.65 Gainesville, GA $470,000 $545,000 $594,000 $519,000 $510,000 16% 26% 10% 9% $16.80 $19.49 $21.25 $18.56 $18.25 Gwinnett County, GA $4,827,000 $4,536,000 $4,453,000 $2,790,000 $2,784,000 -6% -8% -42% -42% $7.27 $6.83 $6.70 $4.20 $4.19 Hinesville, GA $367,000 $423,000 $503,000 $422,000 $410,000 15% 37% 15% 12% $12.02 $13.86 $16.47 $13.81 $13.44 Macon, GA $1,606,000 $2,457,000 $2,935,000 $3,452,000 $3,355,000 53% 83% 115% 109% $16.75 $25.63 $30.61 $36.01 $35.00 Marietta, GA $835,000 $850,000 $992,000 $906,000 $895,000 2% 19% 8% 7% $13.46 $13.70 $15.99 $14.61 $14.42 Rome, GA $620,000 $806,000 $844,000 $860,000 $840,000 30% 36% 39% 35% $17.60 $22.86 $23.94 $24.42 $23.83 Roswell, GA $550,000 $501,000 $496,000 $301,000 $299,000 -9% -10% -45% -46% $6.96 $6.34 $6.28 $3.81 $3.79 Savannah, GA $3,323,000 $3,721,000 $3,378,000 $4,175,000 $4,071,000 12% 2% 26% 22% $26.02 $29.14 $26.46 $32.70 $31.88 Valdosta, GA $718,000 $751,000 $1,026,000 $962,000 $935,000 5% 43% 34% 30% $16.06 $16.81 $22.95 $21.52 $20.92 Warner Robins, GA $543,000 $594,000 $725,000 $696,000 $678,000 9% 34% 28% 25% $10.33 $11.30 $13.80 $13.24 $12.90 Georgia State Program $47,121,000 $51,398,000 $52,398,000 $52,398,000 $54,479,000 9% 11% 11% 16% $10.49 $11.44 $11.67 $11.67 $12.13 TOTAL $97,555,000 $102,857,000 $109,113,000 $104,021,000 $105,098,000 5% 12% 7% 8% $11.40 $12.02 $12.75 $12.15 $12.28

Hawaii Honolulu, HI $11,856,000 $12,725,000 $12,661,000 $9,617,000 $9,739,000 7% 7% -19% -18% $13.23 $14.20 $14.13 $10.73 $10.87

CDBG Formula Targeting to Community Development Need B-28

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Hawaii State Program $6,137,000 $6,423,000 $3,619,000 $3,619,000 $4,569,000 5% -41% -41% -26% $17.59 $18.41 $10.37 $10.37 $13.10 TOTAL $17,993,000 $19,148,000 $16,280,000 $13,236,000 $14,308,000 6% -10% -26% -20% $14.45 $15.38 $13.08 $10.63 $11.49

Idaho Boise, ID $1,562,000 $1,389,000 $1,765,000 $1,440,000 $1,418,000 -11% 13% -8% -9% $8.23 $7.31 $9.30 $7.59 $7.47 Idaho Falls, ID $491,000 $491,000 $656,000 $584,000 $572,000 0% 34% 19% 16% $9.61 $9.61 $12.84 $11.43 $11.19 Lewiston, ID $323,000 $429,000 $430,000 $439,000 $428,000 33% 33% 36% 33% $10.59 $14.08 $14.10 $14.40 $14.04 Nampa, ID $613,000 $629,000 $745,000 $838,000 $823,000 3% 22% 37% 34% $10.17 $10.44 $12.36 $13.91 $13.66 Pocatello, ID $604,000 $803,000 $868,000 $861,000 $842,000 33% 44% 42% 39% $11.79 $15.67 $16.93 $16.80 $16.43 Idaho State Program $10,549,000 $10,876,000 $10,290,000 $10,290,000 $11,084,000 3% -2% -2% 5% $11.10 $11.44 $10.83 $10.83 $11.66 TOTAL $14,142,000 $14,618,000 $14,754,000 $14,453,000 $15,167,000 3% 4% 2% 7% $10.61 $10.96 $11.07 $10.84 $11.37

Illinois Arlington Heights, IL $363,000 $270,000 $235,000 $177,000 $176,000 -25% -35% -51% -51% $4.75 $3.54 $3.08 $2.32 $2.31 Aurora, IL $1,470,000 $1,533,000 $1,847,000 $1,819,000 $1,804,000 4% 26% 24% 23% $9.36 $9.77 $11.76 $11.59 $11.49 Belleville, IL $862,000 $677,000 $610,000 $757,000 $738,000 -21% -29% -12% -14% $20.86 $16.39 $14.76 $18.32 $17.85 Berwyn, IL $1,596,000 $985,000 $795,000 $996,000 $986,000 -38% -50% -38% -38% $29.94 $18.48 $14.91 $18.68 $18.49 Bloomington, IL $730,000 $637,000 $630,000 $607,000 $597,000 -13% -14% -17% -18% $10.83 $9.44 $9.34 $9.01 $8.85

CDBG Formula Targeting to Community Development Need B-29

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Bolingbrook, IL $372,000 $339,000 $340,000 $288,000 $286,000 -9% -9% -23% -23% $5.92 $5.40 $5.42 $4.58 $4.55 Champaign, IL $916,000 $657,000 $721,000 $778,000 $764,000 -28% -21% -15% -17% $13.19 $9.47 $10.38 $11.21 $11.01 Chicago, IL $100,851,000 $98,448,000 $83,622,000 $101,911,000 $100,044,000 -2% -17% 1% -1% $34.94 $34.11 $28.97 $35.31 $34.66 Chicago Heights, IL $684,000 $771,000 $790,000 $949,000 $932,000 13% 15% 39% 36% $20.98 $23.65 $24.22 $29.11 $28.58 Cicero, IL $1,631,000 $1,786,000 $2,241,000 $2,535,000 $2,516,000 10% 37% 55% 54% $19.36 $21.20 $26.60 $30.09 $29.87 Cook County, IL $12,693,000 $12,415,000 $14,502,000 $11,698,000 $11,565,000 -2% 14% -8% -9% $7.58 $7.42 $8.67 $6.99 $6.91 Danville, IL $1,168,000 $1,220,000 $854,000 $959,000 $936,000 4% -27% -18% -20% $35.01 $36.57 $25.59 $28.74 $28.04 Decatur, IL $1,772,000 $1,956,000 $1,659,000 $1,877,000 $1,825,000 10% -6% 6% 3% $22.19 $24.50 $20.78 $23.51 $22.85 DeKalb, IL $495,000 $283,000 $359,000 $421,000 $416,000 -43% -27% -15% -16% $12.34 $7.05 $8.96 $10.51 $10.36 Des Plaines, IL $416,000 $384,000 $395,000 $334,000 $334,000 -8% -5% -20% -20% $7.08 $6.55 $6.72 $5.69 $5.69 Downers Grove, IL $262,000 $155,000 $161,000 $115,000 $114,000 -41% -39% -56% -57% $5.36 $3.16 $3.29 $2.35 $2.32 DuPage County, IL $4,312,000 $3,804,000 $3,747,000 $2,448,000 $2,449,000 -12% -13% -43% -43% $6.30 $5.56 $5.48 $3.58 $3.58 East St Louis, IL $2,261,000 $2,125,000 $1,430,000 $1,826,000 $1,774,000 -6% -37% -19% -22% $72.95 $68.56 $46.13 $58.91 $57.24 Elgin, IL $1,015,000 $1,102,000 $1,265,000 $1,249,000 $1,248,000 9% 25% 23% 23% $10.51 $11.41 $13.10 $12.93 $12.92 Evanston, IL $2,395,000 $927,000 $886,000 $708,000 $699,000 -61% -63% -70% -71% $32.62 $12.63 $12.07 $9.65 $9.52 Joliet, IL $1,092,000 $1,167,000 $1,482,000 $1,803,000 $1,768,000 7% 36% 65% 62% $9.22 $9.86 $12.52 $15.23 $14.93

CDBG Formula Targeting to Community Development Need B-30

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Kane County, IL $1,423,000 $1,250,000 $1,284,000 $942,000 $933,000 -12% -10% -34% -34% $5.73 $5.04 $5.17 $3.80 $3.76 Kankakee, IL $707,000 $817,000 $777,000 $979,000 $955,000 16% 10% 38% 35% $26.02 $30.09 $28.61 $36.04 $35.17 Lake County, IL $3,061,000 $2,611,000 $2,794,000 $2,073,000 $2,050,000 -15% -9% -32% -33% $5.59 $4.77 $5.11 $3.79 $3.75 Madison County, IL $3,689,000 $3,536,000 $3,237,000 $3,721,000 $3,627,000 -4% -12% 1% -2% $13.92 $13.34 $12.22 $14.04 $13.69 McHenry County, IL $1,518,000 $1,252,000 $1,296,000 $1,061,000 $1,048,000 -18% -15% -30% -31% $5.32 $4.38 $4.54 $3.71 $3.67 Moline, IL $1,070,000 $809,000 $641,000 $638,000 $626,000 -24% -40% -40% -42% $24.76 $18.71 $14.83 $14.76 $14.48 Mount Prospect, IL $452,000 $448,000 $405,000 $276,000 $280,000 -1% -11% -39% -38% $8.06 $7.98 $7.21 $4.93 $4.99 Naperville, IL $583,000 $424,000 $371,000 $238,000 $235,000 -27% -36% -59% -60% $4.31 $3.13 $2.74 $1.76 $1.74 Normal, IL $487,000 $209,000 $267,000 $324,000 $317,000 -57% -45% -33% -35% $10.34 $4.43 $5.67 $6.88 $6.73 North Chicago, IL $380,000 $410,000 $475,000 $519,000 $512,000 8% 25% 36% 35% $10.53 $11.36 $13.17 $14.37 $14.17 Oak Lawn, IL $346,000 $313,000 $334,000 $312,000 $304,000 -9% -3% -10% -12% $6.24 $5.66 $6.04 $5.62 $5.49 Oak Park, IL $2,327,000 $523,000 $502,000 $409,000 $402,000 -78% -78% -82% -83% $45.10 $10.14 $9.73 $7.92 $7.80 Palatine Village, IL $501,000 $473,000 $441,000 $267,000 $269,000 -5% -12% -47% -46% $7.54 $7.13 $6.64 $4.02 $4.05 Pekin, IL $492,000 $377,000 $366,000 $406,000 $396,000 -23% -26% -17% -20% $14.72 $11.29 $10.95 $12.15 $11.84 Peoria, IL $2,304,000 $2,750,000 $2,507,000 $2,748,000 $2,673,000 19% 9% 19% 16% $20.45 $24.41 $22.25 $24.39 $23.73 Rantoul, IL $445,000 $291,000 $164,000 $172,000 $168,000 -35% -63% -61% -62% $34.22 $22.38 $12.61 $13.22 $12.90

CDBG Formula Targeting to Community Development Need B-31

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Rock Island, IL $1,409,000 $1,242,000 $796,000 $934,000 $911,000 -12% -44% -34% -35% $36.09 $31.80 $20.38 $23.92 $23.34 Rockford, IL $2,546,000 $2,775,000 $2,758,000 $3,053,000 $2,983,000 9% 8% 20% 17% $16.85 $18.37 $18.26 $20.21 $19.75 Schaumburg Village, IL $434,000 $353,000 $333,000 $202,000 $205,000 -19% -23% -53% -53% $5.79 $4.71 $4.44 $2.70 $2.73 Skokie, IL $648,000 $472,000 $486,000 $363,000 $362,000 -27% -25% -44% -44% $10.27 $7.48 $7.71 $5.75 $5.73 Springfield, IL $1,540,000 $1,456,000 $1,593,000 $1,632,000 $1,590,000 -5% 3% 6% 3% $13.77 $13.02 $14.25 $14.59 $14.22 St. Clair County, IL $1,726,000 $1,800,000 $2,367,000 $2,532,000 $2,456,000 4% 37% 47% 42% $9.44 $9.85 $12.95 $13.85 $13.44 Urbana, IL $565,000 $430,000 $497,000 $611,000 $599,000 -24% -12% 8% 6% $14.77 $11.24 $13.00 $15.98 $15.66 Waukegan, IL $1,287,000 $1,454,000 $1,680,000 $1,801,000 $1,786,000 13% 31% 40% 39% $14.09 $15.92 $18.40 $19.72 $19.56 Wheaton City, IL $293,000 $231,000 $221,000 $142,000 $141,000 -21% -25% -52% -52% $5.29 $4.17 $4.00 $2.57 $2.54 Will County, IL $1,588,000 $1,235,000 $1,355,000 $1,247,000 $1,224,000 -22% -15% -21% -23% $4.74 $3.69 $4.05 $3.73 $3.66 Illinois State Program $37,843,000 $32,694,000 $32,847,000 $32,847,000 $33,566,000 -14% -13% -13% -11% $12.76 $11.02 $11.08 $11.08 $11.32 TOTAL $207,020,000 $192,279,000 $179,367,000 $194,704,000 $192,587,000 -7% -13% -6% -7% $16.43 $15.26 $14.23 $15.45 $15.28

Indiana Anderson, IN $1,086,000 $1,013,000 $998,000 $1,091,000 $1,063,000 -7% -8% 0% -2% $18.45 $17.22 $16.95 $18.54 $18.06 Bloomington, IN $1,014,000 $719,000 $702,000 $824,000 $805,000 -29% -31% -19% -21% $14.49 $10.27 $10.03 $11.77 $11.50 Columbus, IN $355,000 $418,000 $453,000 $462,000 $452,000 18% 28% 30% 27% $9.16 $10.78 $11.70 $11.93 $11.67

CDBG Formula Targeting to Community Development Need B-32

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 East Chicago, IN $1,664,000 $1,622,000 $1,175,000 $1,517,000 $1,482,000 -3% -29% -9% -11% $52.44 $51.13 $37.04 $47.80 $46.71 Elkhart, IN $882,000 $774,000 $941,000 $1,036,000 $1,017,000 -12% 7% 18% 15% $17.03 $14.94 $18.17 $20.01 $19.63 Evansville, IN $3,553,000 $2,992,000 $2,096,000 $2,451,000 $2,391,000 -16% -41% -31% -33% $29.84 $25.13 $17.60 $20.58 $20.08 Fort Wayne, IN $3,053,000 $2,949,000 $3,178,000 $3,723,000 $3,634,000 -3% 4% 22% 19% $14.53 $14.04 $15.13 $17.72 $17.30 Gary, IN $4,469,000 $4,566,000 $3,488,000 $4,419,000 $4,308,000 2% -22% -1% -4% $44.27 $45.24 $34.55 $43.78 $42.67 Goshen, IN $335,000 $286,000 $360,000 $360,000 $355,000 -15% 8% 8% 6% $11.29 $9.63 $12.14 $12.14 $11.96 Hamilton County, IN $710,000 $502,000 $541,000 $387,000 $380,000 -29% -24% -45% -46% $4.38 $3.09 $3.34 $2.39 $2.34 Hammond, IN $2,774,000 $2,525,000 $1,808,000 $2,343,000 $2,296,000 -9% -35% -16% -17% $34.07 $31.02 $22.21 $28.78 $28.20 Indianapolis, IN $11,328,000 $11,412,000 $11,874,000 $12,837,000 $12,556,000 1% 5% 13% 11% $14.27 $14.38 $14.96 $16.17 $15.82 Kokomo, IN $1,192,000 $1,060,000 $826,000 $978,000 $954,000 -11% -31% -18% -20% $25.94 $23.07 $17.97 $21.29 $20.75 La Porte, IN $594,000 $402,000 $329,000 $365,000 $357,000 -32% -45% -39% -40% $27.90 $18.87 $15.47 $17.15 $16.77 Lafayette, IN $782,000 $778,000 $867,000 $899,000 $882,000 -1% 11% 15% 13% $12.91 $12.84 $14.31 $14.83 $14.55 Lake County, IN $1,609,000 $1,357,000 $1,707,000 $1,440,000 $1,415,000 -16% 6% -11% -12% $5.90 $4.97 $6.25 $5.28 $5.19 Michigan City, IN $866,000 $673,000 $563,000 $639,000 $623,000 -22% -35% -26% -28% $26.59 $20.66 $17.28 $19.62 $19.14 Mishawaka, IN $662,000 $532,000 $613,000 $672,000 $659,000 -20% -7% 1% 0% $13.72 $11.03 $12.71 $13.92 $13.66 Muncie, IN $1,697,000 $1,977,000 $1,427,000 $1,955,000 $1,906,000 16% -16% 15% 12% $25.25 $29.42 $21.24 $29.10 $28.36

CDBG Formula Targeting to Community Development Need B-33

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 New Albany, IN $866,000 $802,000 $676,000 $833,000 $810,000 -7% -22% -4% -6% $23.08 $21.37 $18.02 $22.19 $21.59 South Bend, IN $3,379,000 $2,977,000 $2,320,000 $2,766,000 $2,700,000 -12% -31% -18% -20% $31.71 $27.94 $21.77 $25.96 $25.34 Terre Haute, IN $2,227,000 $1,961,000 $1,310,000 $1,616,000 $1,576,000 -12% -41% -27% -29% $37.98 $33.45 $22.34 $27.55 $26.87 West Lafayette, IN $531,000 $324,000 $257,000 $306,000 $300,000 -39% -52% -42% -44% $18.26 $11.13 $8.85 $10.51 $10.31 Indiana State Program $36,840,000 $29,195,000 $30,490,000 $30,490,000 $31,458,000 -21% -17% -17% -15% $10.15 $8.04 $8.40 $8.40 $8.67 TOTAL $82,468,000 $71,817,000 $69,002,000 $74,410,000 $74,378,000 -13% -16% -10% -10% $13.39 $11.66 $11.20 $12.08 $12.08

Iowa Ames, IA $589,000 $350,000 $388,000 $417,000 $408,000 -41% -34% -29% -31% $11.57 $6.88 $7.61 $8.18 $8.02 Cedar Falls, IA $376,000 $342,000 $321,000 $345,000 $338,000 -9% -15% -8% -10% $10.26 $9.33 $8.75 $9.41 $9.22 Cedar Rapids, IA $1,549,000 $1,075,000 $1,144,000 $1,149,000 $1,127,000 -31% -26% -26% -27% $12.64 $8.78 $9.33 $9.38 $9.20 Council Bluffs, IA $1,302,000 $924,000 $839,000 $1,028,000 $1,007,000 -29% -36% -21% -23% $22.20 $15.76 $14.31 $17.52 $17.16 Davenport, IA $2,098,000 $2,091,000 $1,768,000 $2,055,000 $2,005,000 0% -16% -2% -4% $21.46 $21.39 $18.08 $21.02 $20.51 Des Moines, IA $5,108,000 $3,663,000 $3,025,000 $3,611,000 $3,549,000 -28% -41% -29% -31% $25.79 $18.49 $15.27 $18.23 $17.92 Dubuque, IA $1,481,000 $1,056,000 $718,000 $800,000 $782,000 -29% -51% -46% -47% $25.97 $18.51 $12.60 $14.03 $13.71 Iowa City, IA $804,000 $606,000 $559,000 $646,000 $634,000 -25% -30% -20% -21% $12.60 $9.50 $8.76 $10.12 $9.93 Sioux City, IA $2,276,000 $1,746,000 $1,406,000 $1,446,000 $1,420,000 -23% -38% -36% -38% $27.05 $20.75 $16.72 $17.18 $16.88

CDBG Formula Targeting to Community Development Need B-34

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Waterloo, IA $1,647,000 $1,527,000 $1,231,000 $1,315,000 $1,284,000 -7% -25% -20% -22% $24.31 $22.54 $18.18 $19.41 $18.96 Iowa State Program $30,975,000 $24,018,000 $22,886,000 $22,886,000 $23,453,000 -22% -26% -26% -24% $14.76 $11.44 $10.90 $10.90 $11.17 TOTAL $48,205,000 $37,399,000 $34,286,000 $35,697,000 $36,007,000 -22% -29% -26% -25% $16.42 $12.74 $11.68 $12.16 $12.26

Kansas Johnson County, KS $1,427,000 $1,093,000 $1,222,000 $840,000 $829,000 -23% -14% -41% -42% $5.23 $4.01 $4.48 $3.08 $3.04 Kansas City, KS $2,869,000 $3,092,000 $3,248,000 $3,976,000 $3,890,000 8% 13% 39% 36% $19.52 $21.04 $22.10 $27.05 $26.46 Lawrence, KS $963,000 $701,000 $782,000 $822,000 $807,000 -27% -19% -15% -16% $11.80 $8.59 $9.58 $10.08 $9.89 Leavenworth, KS $435,000 $307,000 $392,000 $477,000 $467,000 -30% -10% 10% 7% $12.28 $8.66 $11.08 $13.48 $13.19 Overland Park, KS $778,000 $573,000 $554,000 $355,000 $351,000 -26% -29% -54% -55% $4.91 $3.62 $3.50 $2.24 $2.22 Shawnee, KS $264,000 $191,000 $187,000 $131,000 $131,000 -27% -29% -50% -51% $5.01 $3.63 $3.55 $2.49 $2.48 Topeka, KS $2,388,000 $2,157,000 $1,849,000 $1,972,000 $1,928,000 -10% -23% -17% -19% $19.56 $17.66 $15.14 $16.15 $15.79 Wichita, KS $3,464,000 $4,111,000 $4,989,000 $4,912,000 $4,817,000 19% 44% 42% 39% $9.75 $11.58 $14.05 $13.83 $13.56 Kansas State Program $20,158,000 $18,627,000 $18,550,000 $18,550,000 $19,346,000 -8% -8% -8% -4% $13.54 $12.51 $12.46 $12.46 $12.99 TOTAL $32,746,000 $30,851,000 $31,774,000 $32,037,000 $32,567,000 -6% -3% -2% -1% $12.06 $11.37 $11.71 $11.80 $12.00

Kentucky Ashland, KY $842,000 $743,000 $489,000 $460,000 $446,000 -12% -42% -45% -47% $38.98 $34.40 $22.64 $21.31 $20.66

CDBG Formula Targeting to Community Development Need B-35

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Bowling Green, KY $676,000 $643,000 $863,000 $876,000 $852,000 -5% 28% 30% 26% $13.46 $12.79 $17.18 $17.45 $16.96 Covington, KY $2,018,000 $1,770,000 $1,169,000 $1,624,000 $1,585,000 -12% -42% -20% -21% $46.95 $41.17 $27.19 $37.79 $36.89 Elizabethtown, KY $193,000 $193,000 $251,000 $198,000 $193,000 0% 30% 3% 0% $8.36 $8.35 $10.87 $8.60 $8.36 Henderson, KY $306,000 $426,000 $498,000 $576,000 $558,000 39% 63% 88% 82% $11.16 $15.55 $18.18 $21.00 $20.35 Hopkinsville, KY $346,000 $455,000 $579,000 $604,000 $586,000 31% 67% 74% 69% $11.82 $15.53 $19.78 $20.62 $20.01 Jefferson County, KY $3,009,000 $2,736,000 $3,365,000 $2,692,000 $2,622,000 -9% 12% -11% -13% $6.74 $6.12 $7.53 $6.03 $5.87 Lexington-Fayette, KY $2,505,000 $2,294,000 $2,948,000 $2,797,000 $2,729,000 -8% 18% 12% 9% $9.50 $8.70 $11.18 $10.61 $10.35 Louisville, KY $11,324,000 $10,748,000 $7,339,000 $9,303,000 $9,070,000 -5% -35% -18% -20% $45.04 $42.75 $29.19 $37.00 $36.08 Owensboro, KY $635,000 $890,000 $934,000 $984,000 $956,000 40% 47% 55% 51% $11.72 $16.42 $17.24 $18.16 $17.65 Kentucky State Program $31,820,000 $39,521,000 $46,920,000 $46,920,000 $46,911,000 24% 47% 47% 47% $11.04 $13.71 $16.28 $16.28 $16.27 TOTAL $53,674,000 $60,418,000 $65,355,000 $67,034,000 $66,508,000 13% 22% 25% 24% $13.11 $14.76 $15.97 $16.38 $16.25

Louisiana Alexandria, LA $802,000 $1,310,000 $1,431,000 $1,416,000 $1,373,000 63% 78% 77% 71% $17.49 $28.56 $31.21 $30.89 $29.94 Baton Rouge, LA $5,096,000 $5,152,000 $6,804,000 $5,876,000 $5,722,000 1% 34% 15% 12% $13.18 $13.32 $17.60 $15.20 $14.80 Bossier City, LA $633,000 $691,000 $932,000 $923,000 $897,000 9% 47% 46% 42% $11.07 $12.09 $16.31 $16.14 $15.70 Houma-Terrebonne, LA $1,492,000 $1,768,000 $2,137,000 $1,964,000 $1,905,000 18% 43% 32% 28% $14.12 $16.73 $20.23 $18.59 $18.03

CDBG Formula Targeting to Community Development Need B-36

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Jefferson Parish, LA $4,403,000 $4,762,000 $5,815,000 $4,997,000 $4,876,000 8% 32% 13% 11% $11.52 $12.46 $15.21 $13.07 $12.75 Kenner, LA $827,000 $914,000 $1,046,000 $881,000 $860,000 11% 26% 6% 4% $11.73 $12.97 $14.83 $12.49 $12.20 Lafayette, LA $1,976,000 $1,999,000 $2,515,000 $2,127,000 $2,073,000 1% 27% 8% 5% $11.84 $11.98 $15.07 $12.74 $12.42 Lake Charles, LA $1,009,000 $1,349,000 $1,524,000 $1,466,000 $1,427,000 34% 51% 45% 41% $14.27 $19.08 $21.54 $20.73 $20.17 Monroe, LA $1,063,000 $1,283,000 $1,652,000 $1,637,000 $1,585,000 21% 55% 54% 49% $20.30 $24.50 $31.54 $31.26 $30.26 New Orleans, LA $18,071,000 $21,818,000 $18,145,000 $20,758,000 $20,261,000 21% 0% 15% 12% $38.15 $46.06 $38.31 $43.82 $42.77 Shreveport, LA $3,167,000 $3,879,000 $5,062,000 $4,821,000 $4,683,000 22% 60% 52% 48% $15.91 $19.49 $25.43 $24.22 $23.53 Slidell, LA $240,000 $249,000 $294,000 $254,000 $246,000 4% 23% 6% 2% $9.07 $9.41 $11.13 $9.60 $9.29 Thibodaux, LA $248,000 $308,000 $355,000 $323,000 $314,000 24% 43% 30% 27% $17.09 $21.23 $24.44 $22.24 $21.62 Louisiana State Program $34,125,000 $40,007,000 $42,495,000 $42,495,000 $43,705,000 17% 25% 25% 28% $14.04 $16.46 $17.48 $17.48 $17.98 TOTAL $73,152,000 $85,489,000 $90,207,000 $89,937,000 $89,925,000 17% 23% 23% 23% $16.32 $19.07 $20.13 $20.07 $20.06

Maine Auburn, ME $763,000 $651,000 $439,000 $471,000 $460,000 -15% -42% -38% -40% $32.97 $28.12 $18.97 $20.36 $19.89 Bangor, ME $1,252,000 $1,036,000 $625,000 $672,000 $656,000 -17% -50% -46% -48% $39.69 $32.84 $19.83 $21.30 $20.80 Lewiston, ME $1,251,000 $1,344,000 $841,000 $1,038,000 $1,015,000 7% -33% -17% -19% $35.09 $37.72 $23.60 $29.13 $28.47 Portland, ME $2,567,000 $1,879,000 $1,227,000 $1,389,000 $1,359,000 -27% -52% -46% -47% $40.18 $29.42 $19.22 $21.75 $21.27

CDBG Formula Targeting to Community Development Need B-37

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 South Portland, ME $542,000 $325,000 $217,000 $238,000 $233,000 -40% -60% -56% -57% $23.31 $13.99 $9.31 $10.23 $10.00 Maine State Program $16,856,000 $14,217,000 $14,318,000 $14,318,000 $14,488,000 -16% -15% -15% -14% $15.11 $12.75 $12.84 $12.84 $12.99 TOTAL $23,231,000 $19,453,000 $17,667,000 $18,126,000 $18,211,000 -16% -24% -22% -22% $17.97 $15.05 $13.67 $14.02 $14.09

Maryland Annapolis, MD $414,000 $378,000 $533,000 $457,000 $447,000 -9% 29% 10% 8% $11.44 $10.44 $14.71 $12.63 $12.36 Anne Arundel County, MD $2,577,000 $2,128,000 $2,468,000 $2,007,000 $1,970,000 -17% -4% -22% -24% $5.52 $4.56 $5.28 $4.30 $4.22 Baltimore, MD $28,468,000 $27,871,000 $20,156,000 $27,030,000 $26,378,000 -2% -29% -5% -7% $44.58 $43.64 $31.56 $42.33 $41.31 Baltimore County, MD $5,094,000 $4,390,000 $5,969,000 $5,369,000 $5,265,000 -14% 17% 5% 3% $6.61 $5.70 $7.75 $6.97 $6.84 Bowie City, MD $202,000 $120,000 $117,000 $97,000 $97,000 -41% -42% -52% -52% $3.88 $2.30 $2.25 $1.86 $1.86 Cumberland, MD $1,216,000 $1,110,000 $648,000 $785,000 $764,000 -9% -47% -35% -37% $57.68 $52.66 $30.72 $37.22 $36.24 Frederick, MD $469,000 $345,000 $476,000 $574,000 $564,000 -27% 1% 22% 20% $8.37 $6.15 $8.49 $10.24 $10.06 Gaithersburg, MD $545,000 $552,000 $558,000 $526,000 $531,000 1% 2% -3% -3% $9.68 $9.81 $9.91 $9.35 $9.44 Hagerstown, MD $1,159,000 $1,128,000 $897,000 $1,108,000 $1,078,000 -3% -23% -4% -7% $31.62 $30.76 $24.47 $30.24 $29.42 Harford County, MD $1,270,000 $1,082,000 $1,308,000 $1,254,000 $1,224,000 -15% 3% -1% -4% $5.58 $4.75 $5.74 $5.51 $5.37 Howard County, MD $1,409,000 $1,147,000 $1,216,000 $785,000 $776,000 -19% -14% -44% -45% $5.42 $4.41 $4.67 $3.02 $2.98 Montgomery County, MD $6,221,000 $5,892,000 $6,220,000 $4,826,000 $4,817,000 -5% 0% -22% -23% $7.40 $7.01 $7.40 $5.74 $5.73

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need B-38

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Prince Georges County, MD $7,445,000 $7,425,000 $8,930,000 $9,376,000 $9,364,000 0% 20% 26% 26% $9.54 $9.52 $11.44 $12.02 $12.00 Salisbury, MD $360,000 $406,000 $510,000 $617,000 $601,000 13% 42% 71% 67% $14.61 $16.46 $20.68 $25.04 $24.40 Maryland State Program $9,358,000 $8,243,000 $8,963,000 $8,963,000 $9,183,000 -12% -4% -4% -2% $7.86 $6.92 $7.53 $7.53 $7.71 TOTAL $66,207,000 $62,217,000 $58,967,000 $63,775,000 $63,061,000 -6% -11% -4% -5% $12.13 $11.40 $10.80 $11.68 $11.55

Massachusetts Arlington, MA $1,558,000 $285,000 $261,000 $259,000 $254,000 -82% -83% -83% -84% $36.97 $6.77 $6.19 $6.14 $6.03 Attleboro, MA $565,000 $381,000 $393,000 $390,000 $383,000 -33% -30% -31% -32% $13.09 $8.83 $9.11 $9.02 $8.88 Barnstable, MA $425,000 $368,000 $475,000 $470,000 $458,000 -13% 12% 11% 8% $8.70 $7.53 $9.72 $9.62 $9.37 Boston, MA $24,264,000 $20,365,000 $15,586,000 $18,890,000 $18,585,000 -16% -36% -22% -23% $41.18 $34.56 $26.45 $32.06 $31.54 Brockton, MA $1,723,000 $1,802,000 $1,921,000 $2,467,000 $2,413,000 5% 11% 43% 40% $18.05 $18.88 $20.13 $25.85 $25.29 Brookline, MA $1,918,000 $747,000 $645,000 $529,000 $523,000 -61% -66% -72% -73% $33.63 $13.10 $11.32 $9.27 $9.16 Cambridge, MA $3,817,000 $1,870,000 $1,556,000 $1,673,000 $1,650,000 -51% -59% -56% -57% $37.49 $18.37 $15.28 $16.43 $16.21 Chicopee, MA $1,561,000 $1,276,000 $949,000 $1,090,000 $1,065,000 -18% -39% -30% -32% $28.47 $23.28 $17.32 $19.87 $19.42 Fall River, MA $3,603,000 $3,532,000 $2,605,000 $3,656,000 $3,572,000 -2% -28% 1% -1% $38.88 $38.12 $28.11 $39.46 $38.55 Fitchburg, MA $1,414,000 $1,178,000 $889,000 $1,208,000 $1,182,000 -17% -37% -15% -16% $35.59 $29.65 $22.37 $30.40 $29.75 Framingham, MA $645,000 $549,000 $724,000 $770,000 $760,000 -15% 12% 19% 18% $9.65 $8.21 $10.84 $11.52 $11.37

CDBG Formula Targeting to Community Development Need B-39

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Gloucester, MA $942,000 $596,000 $452,000 $527,000 $515,000 -37% -52% -44% -45% $30.72 $19.42 $14.75 $17.18 $16.79 Haverhill, MA $1,253,000 $913,000 $843,000 $1,027,000 $1,005,000 -27% -33% -18% -20% $21.01 $15.32 $14.14 $17.22 $16.85 Holyoke, MA $1,636,000 $1,659,000 $1,429,000 $1,828,000 $1,784,000 1% -13% 12% 9% $41.03 $41.60 $35.85 $45.84 $44.75 Lawrence, MA $2,046,000 $2,577,000 $2,583,000 $3,271,000 $3,202,000 26% 26% 60% 57% $28.24 $35.57 $35.65 $45.14 $44.20 Leominster, MA $618,000 $553,000 $582,000 $646,000 $632,000 -11% -6% 4% 2% $14.75 $13.19 $13.89 $15.41 $15.09 Lowell, MA $2,815,000 $2,799,000 $2,632,000 $3,412,000 $3,347,000 -1% -6% 21% 19% $26.83 $26.68 $25.09 $32.53 $31.91 Lynn, MA $3,007,000 $2,650,000 $2,288,000 $2,954,000 $2,899,000 -12% -24% -2% -4% $33.56 $29.58 $25.53 $32.97 $32.36 Malden, MA $1,857,000 $1,087,000 $846,000 $1,082,000 $1,068,000 -41% -54% -42% -42% $33.07 $19.35 $15.06 $19.26 $19.02 Medford, MA $2,126,000 $980,000 $504,000 $706,000 $693,000 -54% -76% -67% -67% $38.56 $17.77 $9.15 $12.80 $12.56 New Bedford, MA $3,585,000 $3,914,000 $2,953,000 $4,125,000 $4,026,000 9% -18% 15% 12% $38.10 $41.60 $31.39 $43.84 $42.79 Newton, MA $2,700,000 $535,000 $522,000 $419,000 $410,000 -80% -81% -84% -85% $32.19 $6.38 $6.22 $4.99 $4.89 Northampton, MA $898,000 $543,000 $319,000 $311,000 $305,000 -39% -64% -65% -66% $30.99 $18.75 $11.02 $10.74 $10.53 Pittsfield, MA $1,793,000 $1,334,000 $815,000 $982,000 $959,000 -26% -55% -45% -47% $39.82 $29.63 $18.10 $21.82 $21.31 Plymouth, MA $478,000 $280,000 $359,000 $405,000 $396,000 -41% -25% -15% -17% $8.89 $5.21 $6.67 $7.53 $7.36 Quincy, MA $2,513,000 $1,187,000 $957,000 $970,000 $960,000 -53% -62% -61% -62% $28.18 $13.31 $10.73 $10.88 $10.76 Salem, MA $1,352,000 $827,000 $608,000 $743,000 $730,000 -39% -55% -45% -46% $32.08 $19.61 $14.42 $17.64 $17.32

CDBG Formula Targeting to Community Development Need B-40

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Somerville, MA $3,450,000 $2,097,000 $1,304,000 $1,770,000 $1,745,000 -39% -62% -49% -49% $44.85 $27.26 $16.96 $23.01 $22.68 Springfield, MA $5,007,000 $5,215,000 $4,628,000 $6,006,000 $5,854,000 4% -8% 20% 17% $32.96 $34.33 $30.46 $39.53 $38.53 Taunton, MA $1,022,000 $848,000 $819,000 $954,000 $930,000 -17% -20% -7% -9% $18.04 $14.98 $14.46 $16.83 $16.43 Waltham, MA $1,280,000 $813,000 $562,000 $700,000 $694,000 -37% -56% -45% -46% $21.67 $13.76 $9.52 $11.85 $11.75 Westfield, MA $539,000 $532,000 $546,000 $560,000 $547,000 -1% 1% 4% 1% $13.37 $13.20 $13.54 $13.89 $13.57 Weymouth, MA $940,000 $535,000 $434,000 $491,000 $480,000 -43% -54% -48% -49% $17.17 $9.77 $7.93 $8.97 $8.76 Worcester, MA $5,607,000 $5,314,000 $4,181,000 $5,554,000 $5,432,000 -5% -25% -1% -3% $32.05 $30.37 $23.90 $31.74 $31.05 Yarmouth, MA $175,000 $146,000 $180,000 $192,000 $187,000 -17% 3% 10% 7% $6.93 $5.77 $7.14 $7.61 $7.41 Massachusetts State Program $40,541,000 $26,721,000 $25,539,000 $25,539,000 $26,418,000 -34% -37% -37% -35% $11.36 $7.49 $7.16 $7.16 $7.40 TOTAL $129,673,000 $97,008,000 $82,890,000 $96,572,000 $96,063,000 -25% -36% -26% -26% $20.17 $15.09 $12.90 $15.02 $14.95

Michigan Ann Arbor, MI $1,308,000 $1,119,000 $1,082,000 $1,164,000 $1,154,000 -14% -17% -11% -12% $11.35 $9.71 $9.40 $10.10 $10.01 Battle Creek, MI $1,557,000 $1,443,000 $1,070,000 $1,196,000 $1,168,000 -7% -31% -23% -25% $29.02 $26.90 $19.94 $22.29 $21.78 Bay City, MI $1,742,000 $1,371,000 $827,000 $1,102,000 $1,076,000 -21% -53% -37% -38% $48.60 $38.25 $23.07 $30.75 $30.03 Benton Harbor, MI $572,000 $725,000 $625,000 $806,000 $783,000 27% 9% 41% 37% $51.76 $65.56 $56.56 $72.89 $70.85 Canton Twp., MI $434,000 $358,000 $351,000 $223,000 $220,000 -17% -19% -49% -49% $5.34 $4.40 $4.32 $2.74 $2.70

CDBG Formula Targeting to Community Development Need B-41

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Clinton Twp., MI $641,000 $575,000 $630,000 $602,000 $592,000 -10% -2% -6% -8% $6.68 $5.99 $6.57 $6.28 $6.17 Dearborn, MI $2,485,000 $2,498,000 $2,133,000 $1,977,000 $1,930,000 1% -14% -20% -22% $25.40 $25.54 $21.81 $20.21 $19.73 Dearborn Heights, MI $1,282,000 $867,000 $458,000 $369,000 $362,000 -32% -64% -71% -72% $22.09 $14.93 $7.90 $6.35 $6.24 Detroit, MI $45,828,000 $50,410,000 $35,975,000 $47,496,000 $46,373,000 10% -22% 4% 1% $49.54 $54.49 $38.89 $51.34 $50.13 East Lansing, MI $727,000 $438,000 $423,000 $552,000 $544,000 -40% -42% -24% -25% $15.71 $9.46 $9.15 $11.93 $11.77 Farmington Hills, MI $463,000 $376,000 $371,000 $250,000 $246,000 -19% -20% -46% -47% $5.69 $4.62 $4.55 $3.07 $3.03 Flint, MI $5,216,000 $5,373,000 $4,232,000 $5,447,000 $5,303,000 3% -19% 4% 2% $42.84 $44.13 $34.76 $44.73 $43.55 Genesee County, MI $2,257,000 $2,111,000 $2,759,000 $3,276,000 $3,194,000 -6% 22% 45% 42% $7.23 $6.76 $8.84 $10.49 $10.23 Grand Rapids, MI $4,737,000 $4,641,000 $4,191,000 $5,200,000 $5,089,000 -2% -12% 10% 7% $24.10 $23.61 $21.32 $26.45 $25.88 Holland, MI $386,000 $302,000 $391,000 $436,000 $430,000 -22% 1% 13% 11% $11.13 $8.72 $11.27 $12.58 $12.38 Jackson, MI $1,677,000 $1,478,000 $1,017,000 $1,394,000 $1,360,000 -12% -39% -17% -19% $47.22 $41.63 $28.64 $39.25 $38.30 Kalamazoo, MI $2,166,000 $2,011,000 $1,558,000 $2,054,000 $2,009,000 -7% -28% -5% -7% $28.55 $26.51 $20.54 $27.07 $26.49 Kent County, MI $1,838,000 $1,526,000 $1,778,000 $1,232,000 $1,209,000 -17% -3% -33% -34% $5.78 $4.80 $5.59 $3.88 $3.80 Lansing, MI $2,536,000 $2,524,000 $2,485,000 $3,067,000 $2,998,000 0% -2% 21% 18% $21.38 $21.28 $20.96 $25.86 $25.28 Lincoln Park, MI $989,000 $773,000 $450,000 $455,000 $447,000 -22% -54% -54% -55% $24.94 $19.49 $11.36 $11.48 $11.27 Livonia, MI $487,000 $379,000 $384,000 $261,000 $256,000 -22% -21% -46% -47% $4.85 $3.78 $3.83 $2.60 $2.55

CDBG Formula Targeting to Community Development Need B-42

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Macomb County, MI $1,984,000 $1,691,000 $1,991,000 $2,061,000 $2,022,000 -15% 0% 4% 2% $5.87 $5.00 $5.89 $6.10 $5.99 Midland, MI $303,000 $257,000 $344,000 $257,000 $250,000 -15% 13% -15% -18% $7.20 $6.11 $8.16 $6.12 $5.94 Monroe, MI $629,000 $534,000 $412,000 $501,000 $489,000 -15% -35% -20% -22% $28.55 $24.24 $18.70 $22.76 $22.21 Muskegon, MI $1,212,000 $1,196,000 $994,000 $1,292,000 $1,261,000 -1% -18% 7% 4% $30.74 $30.33 $25.20 $32.77 $31.98 Muskegon Heights, MI $569,000 $727,000 $548,000 $740,000 $721,000 28% -4% 30% 27% $47.99 $61.29 $46.18 $62.42 $60.82 Niles, MI $397,000 $303,000 $232,000 $291,000 $284,000 -24% -42% -27% -28% $33.16 $25.29 $19.34 $24.28 $23.76 Norton Shores, MI $153,000 $135,000 $146,000 $116,000 $113,000 -12% -5% -24% -26% $6.63 $5.83 $6.30 $5.01 $4.89 Oakland County, MI $3,811,000 $3,225,000 $3,837,000 $3,210,000 $3,154,000 -15% 1% -16% -17% $5.89 $4.99 $5.93 $4.96 $4.88 Pontiac, MI $1,900,000 $1,992,000 $1,876,000 $2,286,000 $2,240,000 5% -1% 20% 18% $28.73 $30.12 $28.36 $34.56 $33.88 Port Huron, MI $1,023,000 $919,000 $724,000 $973,000 $948,000 -10% -29% -5% -7% $31.67 $28.46 $22.42 $30.12 $29.33 Portage, MI $262,000 $203,000 $229,000 $164,000 $162,000 -22% -13% -37% -38% $5.80 $4.50 $5.07 $3.64 $3.58 Redford, MI $1,161,000 $772,000 $374,000 $317,000 $313,000 -34% -68% -73% -73% $22.65 $15.06 $7.30 $6.18 $6.10 Rochester Hills, MI $359,000 $292,000 $287,000 $202,000 $199,000 -19% -20% -44% -45% $5.23 $4.25 $4.18 $2.94 $2.90 Roseville, MI $672,000 $548,000 $453,000 $543,000 $531,000 -18% -33% -19% -21% $13.90 $11.33 $9.38 $11.24 $10.98 Royal Oak, MI $1,650,000 $258,000 $298,000 $277,000 $273,000 -84% -82% -83% -83% $27.86 $4.35 $5.04 $4.67 $4.61 Saginaw, MI $3,016,000 $3,115,000 $2,398,000 $3,154,000 $3,071,000 3% -20% 5% 2% $50.19 $51.83 $39.90 $52.49 $51.10

CDBG Formula Targeting to Community Development Need B-43

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Southfield, MI $629,000 $593,000 $702,000 $619,000 $611,000 -6% 12% -2% -3% $8.08 $7.62 $9.02 $7.96 $7.85 St. Clair Shores, MI $1,116,000 $680,000 $314,000 $337,000 $331,000 -39% -72% -70% -70% $17.79 $10.83 $5.00 $5.37 $5.27 Sterling Heights, MI $828,000 $770,000 $757,000 $726,000 $714,000 -7% -9% -12% -14% $6.56 $6.10 $6.00 $5.75 $5.66 Taylor, MI $620,000 $656,000 $839,000 $786,000 $767,000 6% 35% 27% 24% $9.41 $9.95 $12.74 $11.93 $11.64 Troy City, MI $429,000 $342,000 $310,000 $200,000 $201,000 -20% -28% -53% -53% $5.30 $4.23 $3.83 $2.47 $2.48 Warren, MI $1,053,000 $1,000,000 $1,230,000 $1,433,000 $1,405,000 -5% 17% 36% 33% $7.65 $7.26 $8.94 $10.41 $10.21 Washtenaw County, MI $906,000 $850,000 $1,001,000 $876,000 $861,000 -6% 10% -3% -5% $8.60 $8.07 $9.50 $8.31 $8.17 Waterford Twp., MI $451,000 $365,000 $449,000 $436,000 $429,000 -19% 0% -3% -5% $6.12 $4.95 $6.10 $5.91 $5.83 Wayne County, MI $6,543,000 $6,330,000 $6,303,000 $6,981,000 $6,836,000 -3% -4% 7% 4% $12.12 $11.72 $11.67 $12.93 $12.66 Westland, MI $1,270,000 $971,000 $744,000 $601,000 $593,000 -24% -41% -53% -53% $14.72 $11.26 $8.63 $6.96 $6.87 Wyoming, MI $573,000 $540,000 $670,000 $650,000 $643,000 -6% 17% 13% 12% $8.15 $7.68 $9.52 $9.25 $9.15 Michigan State Program $42,906,000 $34,545,000 $36,630,000 $36,630,000 $37,950,000 -19% -15% -15% -12% $10.47 $8.43 $8.94 $8.94 $9.26 TOTAL $155,753,000 $145,106,000 $128,285,000 $145,217,000 $144,117,000 -7% -18% -7% -7% $15.51 $14.45 $12.77 $14.46 $14.35

Minnesota Anoka County, MN $1,359,000 $1,118,000 $1,199,000 $1,177,000 $1,162,000 -18% -12% -13% -15% $5.49 $4.51 $4.84 $4.76 $4.69 Bloomington, MN $501,000 $394,000 $413,000 $302,000 $302,000 -21% -18% -40% -40% $5.96 $4.69 $4.91 $3.59 $3.59

CDBG Formula Targeting to Community Development Need B-44

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Coon Rapids, MN $374,000 $331,000 $374,000 $368,000 $362,000 -11% 0% -2% -3% $6.00 $5.31 $6.01 $5.90 $5.81 Dakota County, MN $2,058,000 $1,621,000 $1,810,000 $1,567,000 $1,552,000 -21% -12% -24% -25% $5.35 $4.21 $4.71 $4.08 $4.04 Duluth, MN $3,402,000 $2,757,000 $1,641,000 $1,868,000 $1,829,000 -19% -52% -45% -46% $39.37 $31.90 $18.99 $21.62 $21.17 Hennepin County, MN $3,514,000 $2,887,000 $3,120,000 $2,209,000 $2,195,000 -18% -11% -37% -38% $5.85 $4.81 $5.20 $3.68 $3.66 Minneapolis, MN $16,313,000 $11,040,000 $8,333,000 $9,808,000 $9,660,000 -32% -49% -40% -41% $43.43 $29.39 $22.18 $26.11 $25.72 Moorhead, MN $341,000 $254,000 $338,000 $381,000 $370,000 -26% -1% 12% 9% $10.47 $7.79 $10.37 $11.68 $11.37 Plymouth, MN $317,000 $213,000 $205,000 $127,000 $127,000 -33% -35% -60% -60% $4.71 $3.17 $3.04 $1.88 $1.89 Ramsey County, MN $1,286,000 $1,018,000 $1,137,000 $948,000 $937,000 -21% -12% -26% -27% $5.67 $4.49 $5.02 $4.18 $4.13 Rochester, MN $674,000 $591,000 $780,000 $714,000 $701,000 -12% 16% 6% 4% $7.45 $6.52 $8.62 $7.89 $7.75 St. Cloud, MN $576,000 $382,000 $470,000 $458,000 $450,000 -34% -18% -20% -22% $9.64 $6.39 $7.87 $7.67 $7.53 St. Louis County, MN $2,931,000 $2,122,000 $1,428,000 $1,505,000 $1,471,000 -28% -51% -49% -50% $26.00 $18.82 $12.67 $13.35 $13.05 St. Paul, MN $9,526,000 $6,507,000 $5,907,000 $7,228,000 $7,105,000 -32% -38% -24% -25% $33.54 $22.91 $20.80 $25.45 $25.01 Washington County, MN $960,000 $718,000 $763,000 $637,000 $628,000 -25% -21% -34% -35% $4.65 $3.48 $3.69 $3.08 $3.04 Minnesota State Program $24,290,000 $19,719,000 $19,622,000 $19,622,000 $20,338,000 -19% -19% -19% -16% $11.68 $9.48 $9.43 $9.43 $9.78 TOTAL $68,422,000 $51,671,000 $47,542,000 $48,920,000 $49,191,000 -24% -31% -29% -28% $13.68 $10.33 $9.51 $9.78 $9.84

CDBG Formula Targeting to Community Development Need B-45

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4

Mississippi Biloxi, MS $580,000 $687,000 $817,000 $773,000 $756,000 18% 41% 33% 30% $11.64 $13.79 $16.41 $15.52 $15.17 Gulfport, MS $928,000 $1,015,000 $1,319,000 $1,250,000 $1,216,000 9% 42% 35% 31% $12.80 $14.00 $18.19 $17.23 $16.77 Hattiesburg, MS $748,000 $795,000 $1,023,000 $1,066,000 $1,034,000 6% 37% 42% 38% $16.34 $17.38 $22.36 $23.28 $22.59 Jackson, MS $3,060,000 $3,573,000 $4,644,000 $4,687,000 $4,561,000 17% 52% 53% 49% $16.92 $19.75 $25.67 $25.91 $25.22 Moss Point, MS $214,000 $249,000 $341,000 $365,000 $355,000 17% 60% 70% 66% $13.83 $16.12 $22.06 $23.57 $22.95 Pascagoula, MS $376,000 $440,000 $561,000 $536,000 $520,000 17% 49% 43% 38% $14.47 $16.93 $21.59 $20.64 $20.02 Mississippi State Program $35,331,000 $41,512,000 $44,414,000 $44,414,000 $45,579,000 17% 26% 26% 29% $14.27 $16.76 $17.93 $17.93 $18.41 TOTAL $41,237,000 $48,272,000 $53,119,000 $53,091,000 $54,022,000 17% 29% 29% 31% $14.38 $16.84 $18.53 $18.52 $18.84

Missouri Columbia, MO $1,010,000 $793,000 $935,000 $954,000 $931,000 -21% -7% -6% -8% $11.61 $9.12 $10.75 $10.96 $10.70 Florissant, MO $274,000 $226,000 $282,000 $279,000 $275,000 -18% 3% 2% 0% $5.48 $4.52 $5.64 $5.57 $5.50 Independence, MO $911,000 $964,000 $1,245,000 $1,473,000 $1,439,000 6% 37% 62% 58% $8.06 $8.53 $11.01 $13.03 $12.73 Jefferson City, MO $381,000 $383,000 $441,000 $403,000 $392,000 0% 16% 6% 3% $9.75 $9.79 $11.28 $10.31 $10.02 Jefferson County, MO $1,379,000 $1,279,000 $1,536,000 $1,648,000 $1,609,000 -7% 11% 20% 17% $6.78 $6.29 $7.56 $8.11 $7.91 Joplin, MO $814,000 $890,000 $794,000 $798,000 $777,000 9% -2% -2% -5% $17.62 $19.27 $17.20 $17.27 $16.83

CDBG Formula Targeting to Community Development Need B-46

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Kansas City, MO $10,741,000 $9,918,000 $8,379,000 $9,582,000 $9,377,000 -8% -22% -11% -13% $24.22 $22.36 $18.89 $21.61 $21.14 Lees Summit, MO $367,000 $293,000 $329,000 $256,000 $250,000 -20% -10% -30% -32% $4.90 $3.92 $4.39 $3.42 $3.34 O'Fallon, MO $269,000 $206,000 $197,000 $179,000 $176,000 -24% -27% -34% -35% $4.51 $3.45 $3.31 $2.99 $2.94 Springfield, MO $1,637,000 $2,070,000 $2,230,000 $2,377,000 $2,317,000 26% 36% 45% 42% $10.84 $13.71 $14.77 $15.74 $15.34 St. Charles, MO $380,000 $328,000 $422,000 $385,000 $376,000 -14% 11% 1% -1% $6.25 $5.39 $6.94 $6.34 $6.19 St. Joseph, MO $2,132,000 $1,833,000 $1,272,000 $1,410,000 $1,376,000 -14% -40% -34% -35% $29.15 $25.05 $17.39 $19.28 $18.81 St. Louis, MO $24,897,000 $21,133,000 $12,465,000 $17,008,000 $16,607,000 -15% -50% -32% -33% $73.58 $62.46 $36.84 $50.27 $49.08 St. Louis County, MO $6,480,000 $5,903,000 $8,265,000 $6,755,000 $6,601,000 -9% 28% 4% 2% $7.00 $6.38 $8.93 $7.30 $7.13 St. Peters City, MO $232,000 $165,000 $174,000 $153,000 $150,000 -29% -25% -34% -35% $4.33 $3.07 $3.24 $2.85 $2.80 Missouri State Program $28,398,000 $33,048,000 $36,815,000 $36,815,000 $37,549,000 16% 30% 30% 32% $9.61 $11.19 $12.46 $12.46 $12.71 TOTAL $80,302,000 $79,431,000 $75,781,000 $80,474,000 $80,201,000 -1% -6% 0% 0% $14.16 $14.00 $13.36 $14.19 $14.14

Montana Billings, MT $843,000 $940,000 $1,180,000 $1,179,000 $1,148,000 12% 40% 40% 36% $9.16 $10.22 $12.82 $12.81 $12.48 Great Falls, MT $1,157,000 $1,283,000 $1,066,000 $1,101,000 $1,074,000 11% -8% -5% -7% $20.64 $22.88 $19.02 $19.64 $19.16 Missoula, MT $752,000 $983,000 $970,000 $1,071,000 $1,047,000 31% 29% 42% 39% $12.63 $16.52 $16.30 $17.99 $17.59 Montana State Program $8,012,000 $8,751,000 $9,158,000 $9,158,000 $9,444,000 9% 14% 14% 18% $12.07 $13.18 $13.79 $13.79 $14.22

CDBG Formula Targeting to Community Development Need B-47

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 TOTAL $10,764,000 $11,957,000 $12,374,000 $12,508,000 $12,712,000 11% 15% 16% 18% $12.35 $13.72 $14.20 $14.35 $14.59

Nebraska Lincoln, NE $2,131,000 $1,784,000 $2,242,000 $2,223,000 $2,185,000 -16% 5% 4% 3% $9.17 $7.68 $9.65 $9.57 $9.40 Omaha, NE $6,115,000 $5,640,000 $5,714,000 $5,830,000 $5,714,000 -8% -7% -5% -7% $15.31 $14.12 $14.31 $14.60 $14.31 Nebraska State Program $14,711,000 $12,803,000 $12,661,000 $12,661,000 $13,095,000 -13% -14% -14% -11% $13.46 $11.71 $11.58 $11.58 $11.98 TOTAL $22,957,000 $20,226,000 $20,617,000 $20,714,000 $20,993,000 -12% -10% -10% -9% $13.31 $11.73 $11.95 $12.01 $12.17

Nevada Carson City, NV $536,000 $553,000 $606,000 $505,000 $500,000 3% 13% -6% -7% $9.87 $10.19 $11.16 $9.30 $9.20 Clark County, NV $7,390,000 $7,551,000 $7,581,000 $6,064,000 $6,055,000 2% 3% -18% -18% $11.01 $11.25 $11.29 $9.03 $9.02 Henderson, NV $1,299,000 $1,119,000 $1,164,000 $796,000 $788,000 -14% -10% -39% -39% $6.30 $5.43 $5.65 $3.86 $3.82 Las Vegas, NV $6,122,000 $6,525,000 $6,776,000 $5,355,000 $5,320,000 7% 11% -13% -13% $12.04 $12.83 $13.32 $10.53 $10.46 North Las Vegas, NV $1,841,000 $2,131,000 $2,156,000 $2,128,000 $2,111,000 16% 17% 16% 15% $13.55 $15.68 $15.87 $15.66 $15.54 Reno, NV $2,424,000 $2,417,000 $2,673,000 $2,389,000 $2,384,000 0% 10% -1% -2% $12.74 $12.71 $14.05 $12.56 $12.53 Sparks, NV $729,000 $758,000 $781,000 $704,000 $707,000 4% 7% -3% -3% $9.89 $10.27 $10.59 $9.55 $9.59 Nevada State Program $3,176,000 $3,172,000 $2,240,000 $2,240,000 $2,548,000 0% -29% -29% -20% $9.74 $9.73 $6.87 $6.87 $7.82 TOTAL $23,517,000 $24,226,000 $23,976,000 $20,181,000 $20,413,000 3% 2% -14% -13% $10.86 $11.18 $11.07 $9.32 $9.42

CDBG Formula Targeting to Community Development Need B-48

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4

New Hampshire Dover, NH $425,000 $256,000 $256,000 $293,000 $287,000 -40% -40% -31% -32% $15.30 $9.22 $9.23 $10.54 $10.33 Manchester, NH $2,227,000 $1,834,000 $1,652,000 $2,079,000 $2,037,000 -18% -26% -7% -9% $20.54 $16.92 $15.24 $19.18 $18.79 Nashua, NH $890,000 $794,000 $872,000 $899,000 $882,000 -11% -2% 1% -1% $10.15 $9.05 $9.94 $10.25 $10.05 Portsmouth, NH $789,000 $300,000 $239,000 $233,000 $227,000 -62% -70% -70% -71% $37.49 $14.25 $11.37 $11.06 $10.81 Rochester, NH $369,000 $296,000 $329,000 $428,000 $418,000 -20% -11% 16% 13% $12.57 $10.10 $11.21 $14.58 $14.23 New Hampshire State Program $10,765,000 $7,003,000 $6,947,000 $6,947,000 $7,177,000 -35% -35% -35% -33% $10.76 $7.00 $6.94 $6.94 $7.17 TOTAL $15,465,000 $10,484,000 $10,295,000 $10,879,000 $11,027,000 -32% -33% -30% -29% $12.13 $8.22 $8.07 $8.53 $8.65

New Jersey Asbury Park, NJ $540,000 $722,000 $744,000 $933,000 $914,000 34% 38% 73% 69% $32.15 $43.02 $44.28 $55.56 $54.44 Atlantic City, NJ $1,651,000 $1,449,000 $1,269,000 $1,524,000 $1,502,000 -12% -23% -8% -9% $41.10 $36.07 $31.58 $37.94 $37.38 Atlantic County, NJ $1,708,000 $1,658,000 $2,029,000 $1,766,000 $1,735,000 -3% 19% 3% 2% $7.95 $7.72 $9.45 $8.22 $8.08 Bayonne, NJ $2,255,000 $1,600,000 $1,095,000 $1,331,000 $1,307,000 -29% -51% -41% -42% $36.60 $25.96 $17.78 $21.61 $21.22 Bergen County, NJ $12,648,000 $5,727,000 $7,166,000 $5,056,000 $5,019,000 -55% -43% -60% -60% $14.13 $6.40 $8.01 $5.65 $5.61 Bloomfield, NJ $1,350,000 $733,000 $505,000 $563,000 $557,000 -46% -63% -58% -59% $28.41 $15.42 $10.62 $11.85 $11.73 Brick Twp., NJ $438,000 $374,000 $419,000 $442,000 $433,000 -15% -4% 1% -1% $5.63 $4.81 $5.38 $5.68 $5.57

CDBG Formula Targeting to Community Development Need B-49

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Bridgeton, NJ $521,000 $652,000 $678,000 $849,000 $828,000 25% 30% 63% 59% $23.00 $28.76 $29.94 $37.46 $36.55 Burlington County, NJ $1,960,000 $1,607,000 $1,915,000 $1,566,000 $1,539,000 -18% -2% -20% -21% $5.33 $4.37 $5.21 $4.26 $4.18 Camden, NJ $3,425,000 $4,249,000 $3,876,000 $4,868,000 $4,758,000 24% 13% 42% 39% $42.98 $53.32 $48.64 $61.09 $59.71 Camden County, NJ $3,037,000 $1,855,000 $2,398,000 $2,358,000 $2,316,000 -39% -21% -22% -24% $10.66 $6.51 $8.42 $8.28 $8.13 Cherry Hill, NJ $529,000 $297,000 $298,000 $200,000 $196,000 -44% -44% -62% -63% $7.52 $4.23 $4.24 $2.85 $2.79 Clifton, NJ $1,705,000 $1,167,000 $878,000 $905,000 $896,000 -32% -48% -47% -47% $21.41 $14.66 $11.03 $11.37 $11.25 Dover Twp., NJ $553,000 $486,000 $553,000 $591,000 $576,000 -12% 0% 7% 4% $5.95 $5.23 $5.96 $6.36 $6.20 East Orange, NJ $1,999,000 $2,078,000 $2,017,000 $2,484,000 $2,447,000 4% 1% 24% 22% $28.66 $29.80 $28.92 $35.62 $35.08 Edison, NJ $790,000 $743,000 $718,000 $528,000 $535,000 -6% -9% -33% -32% $7.91 $7.43 $7.19 $5.29 $5.36 Elizabeth, NJ $2,480,000 $2,973,000 $3,402,000 $4,027,000 $3,982,000 20% 37% 62% 61% $20.12 $24.11 $27.60 $32.66 $32.30 Essex County, NJ $7,217,000 $2,601,000 $3,086,000 $2,362,000 $2,327,000 -64% -57% -67% -68% $21.01 $7.57 $8.98 $6.88 $6.77 Ewing Twp., NJ $245,000 $225,000 $240,000 $281,000 $275,000 -8% -2% 15% 12% $6.78 $6.24 $6.64 $7.76 $7.62 Franklin Twp., NJ $388,000 $337,000 $358,000 $272,000 $273,000 -13% -8% -30% -30% $6.97 $6.05 $6.44 $4.89 $4.91 Gloucester County, NJ $1,783,000 $1,517,000 $1,913,000 $2,012,000 $1,966,000 -15% 7% 13% 10% $6.80 $5.79 $7.30 $7.68 $7.50 Gloucester Twp., NJ $432,000 $370,000 $431,000 $413,000 $405,000 -14% 0% -4% -6% $6.58 $5.64 $6.56 $6.28 $6.16 Hamilton Twp., NJ $674,000 $482,000 $575,000 $619,000 $610,000 -28% -15% -8% -9% $7.58 $5.42 $6.47 $6.97 $6.86

CDBG Formula Targeting to Community Development Need B-50

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Hudson County, NJ $4,402,000 $3,597,000 $3,596,000 $3,265,000 $3,230,000 -18% -18% -26% -27% $23.95 $19.57 $19.57 $17.76 $17.57 Irvington, NJ $1,261,000 $1,446,000 $1,640,000 $1,944,000 $1,920,000 15% 30% 54% 52% $20.84 $23.89 $27.10 $32.13 $31.72 Jersey City, NJ $7,932,000 $7,979,000 $7,270,000 $8,997,000 $8,873,000 1% -8% 13% 12% $33.04 $33.23 $30.28 $37.47 $36.96 Lakewood Twp., NJ $943,000 $1,163,000 $1,300,000 $1,450,000 $1,409,000 23% 38% 54% 49% $14.46 $17.83 $19.93 $22.23 $21.61 Long Branch, NJ $617,000 $650,000 $706,000 $876,000 $858,000 5% 14% 42% 39% $19.54 $20.60 $22.36 $27.76 $27.19 Middlesex County, NJ $2,370,000 $2,052,000 $2,257,000 $1,923,000 $1,919,000 -13% -5% -19% -19% $6.36 $5.50 $6.05 $5.16 $5.15 Middletown, NJ $348,000 $239,000 $274,000 $226,000 $222,000 -31% -21% -35% -36% $5.29 $3.63 $4.17 $3.44 $3.37 Millville, NJ $353,000 $447,000 $529,000 $501,000 $488,000 27% 50% 42% 38% $13.11 $16.61 $19.66 $18.62 $18.13 Monmouth County, NJ $3,780,000 $2,706,000 $3,332,000 $2,904,000 $2,841,000 -28% -12% -23% -25% $7.42 $5.31 $6.54 $5.70 $5.57 Morris County, NJ $2,732,000 $1,632,000 $1,894,000 $1,372,000 $1,350,000 -40% -31% -50% -51% $6.67 $3.98 $4.62 $3.35 $3.29 New Brunswick, NJ $971,000 $1,014,000 $1,221,000 $1,429,000 $1,417,000 4% 26% 47% 46% $19.66 $20.53 $24.72 $28.93 $28.68 Newark, NJ $10,651,000 $11,928,000 $10,333,000 $12,872,000 $12,598,000 12% -3% 21% 18% $38.45 $43.06 $37.30 $46.47 $45.48 North Bergen Twp., NJ $795,000 $846,000 $1,084,000 $1,247,000 $1,235,000 6% 36% 57% 55% $13.47 $14.33 $18.37 $21.12 $20.93 Ocean City, NJ $364,000 $145,000 $141,000 $114,000 $112,000 -60% -61% -69% -69% $23.46 $9.33 $9.06 $7.35 $7.20 Ocean County, NJ $1,713,000 $1,485,000 $1,649,000 $1,911,000 $1,857,000 -13% -4% 12% 8% $5.69 $4.93 $5.48 $6.35 $6.17 Old Bridge Twp., NJ $397,000 $360,000 $363,000 $323,000 $321,000 -9% -9% -19% -19% $6.30 $5.70 $5.76 $5.11 $5.09

CDBG Formula Targeting to Community Development Need B-51

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Parsippany-Troy Hills, NJ $350,000 $319,000 $313,000 $227,000 $229,000 -9% -10% -35% -35% $6.87 $6.25 $6.15 $4.46 $4.49 Passaic, NJ $1,405,000 $1,936,000 $2,361,000 $2,780,000 $2,748,000 38% 68% 98% 96% $20.53 $28.28 $34.50 $40.62 $40.15 Paterson, NJ $3,417,000 $4,468,000 $4,905,000 $5,921,000 $5,821,000 31% 44% 73% 70% $22.67 $29.64 $32.54 $39.27 $38.62 Perth Amboy, NJ $827,000 $980,000 $1,283,000 $1,475,000 $1,458,000 18% 55% 78% 76% $17.18 $20.35 $26.65 $30.63 $30.29 Sayreville, NJ $282,000 $259,000 $277,000 $275,000 $273,000 -8% -2% -3% -3% $6.75 $6.19 $6.63 $6.57 $6.54 Somerset County, NJ $1,502,000 $1,199,000 $1,379,000 $950,000 $944,000 -20% -8% -37% -37% $6.05 $4.83 $5.55 $3.82 $3.80 Trenton, NJ $3,686,000 $3,331,000 $2,639,000 $3,431,000 $3,362,000 -10% -28% -7% -9% $43.04 $38.89 $30.81 $40.06 $39.25 Union, NJ $782,000 $523,000 $413,000 $474,000 $468,000 -33% -47% -39% -40% $14.08 $9.42 $7.44 $8.53 $8.42 Union City, NJ $1,548,000 $2,166,000 $2,546,000 $3,024,000 $2,999,000 40% 64% 95% 94% $23.14 $32.38 $38.06 $45.20 $44.83 Union County, NJ $6,316,000 $2,446,000 $3,212,000 $2,810,000 $2,776,000 -61% -49% -56% -56% $17.95 $6.95 $9.13 $7.98 $7.89 Vineland, NJ $666,000 $694,000 $923,000 $802,000 $787,000 4% 39% 20% 18% $11.82 $12.32 $16.38 $14.24 $13.97 Wayne Twp., NJ $245,000 $180,000 $180,000 $127,000 $124,000 -26% -27% -48% -49% $4.46 $3.29 $3.27 $2.31 $2.26 Woodbridge, NJ $733,000 $627,000 $694,000 $686,000 $686,000 -14% -5% -6% -6% $7.30 $6.25 $6.91 $6.83 $6.83 New Jersey State Program $9,403,000 $6,688,000 $6,725,000 $6,725,000 $7,099,000 -29% -28% -28% -25% $9.57 $6.81 $6.84 $6.84 $7.22 TOTAL $119,119,000 $97,405,000 $102,004,000 $107,011,000 $105,822,000 -18% -14% -10% -11% $13.87 $11.34 $11.87 $12.46 $12.32

CDBG Formula Targeting to Community Development Need B-52

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4

New Mexico Albuquerque, NM $5,249,000 $5,236,000 $6,473,000 $5,604,000 $5,496,000 0% 23% 7% 5% $11.32 $11.29 $13.96 $12.08 $11.85 Farmington, NM $520,000 $586,000 $648,000 $438,000 $428,000 13% 25% -16% -18% $12.82 $14.45 $15.97 $10.79 $10.55 Las Cruces, NM $1,189,000 $1,217,000 $1,506,000 $1,238,000 $1,202,000 2% 27% 4% 1% $15.85 $16.22 $20.08 $16.50 $16.02 Rio Rancho, NM $346,000 $306,000 $316,000 $258,000 $255,000 -11% -9% -25% -26% $6.11 $5.41 $5.57 $4.56 $4.50 Santa Fe, NM $689,000 $678,000 $860,000 $734,000 $721,000 -2% 25% 6% 5% $10.58 $10.42 $13.21 $11.26 $11.07 New Mexico State Program $16,626,000 $19,297,000 $18,463,000 $18,463,000 $19,573,000 16% 11% 11% 18% $15.87 $18.42 $17.62 $17.62 $18.68 TOTAL $24,619,000 $27,321,000 $28,267,000 $26,734,000 $27,675,000 11% 15% 9% 12% $14.08 $15.62 $16.16 $15.29 $15.82

New York Albany, NY $4,531,000 $4,174,000 $2,631,000 $3,728,000 $3,649,000 -8% -42% -18% -19% $48.32 $44.50 $28.05 $39.75 $38.91 Amherst Town, NY $726,000 $572,000 $726,000 $536,000 $523,000 -21% 0% -26% -28% $6.19 $4.88 $6.20 $4.58 $4.47 Auburn, NY $1,296,000 $984,000 $641,000 $767,000 $747,000 -24% -51% -41% -42% $45.98 $34.90 $22.75 $27.21 $26.51 Babylon Town, NY $1,576,000 $1,510,000 $1,778,000 $2,039,000 $2,003,000 -4% 13% 29% 27% $7.31 $7.00 $8.24 $9.45 $9.28 Binghamton, NY $2,825,000 $2,658,000 $1,536,000 $2,011,000 $1,965,000 -6% -46% -29% -30% $60.45 $56.88 $32.87 $43.02 $42.05 Buffalo, NY $19,551,000 $19,180,000 $11,863,000 $16,872,000 $16,473,000 -2% -39% -14% -16% $67.96 $66.67 $41.23 $58.65 $57.26 Cheektowaga Town, NY $1,144,000 $1,041,000 $811,000 $882,000 $861,000 -9% -29% -23% -25% $12.31 $11.20 $8.73 $9.49 $9.26

CDBG Formula Targeting to Community Development Need B-53

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Clay Town, NY $356,000 $302,000 $393,000 $344,000 $336,000 -15% 10% -3% -6% $6.02 $5.11 $6.64 $5.82 $5.69 Colonie Town, NY $475,000 $350,000 $440,000 $384,000 $376,000 -26% -7% -19% -21% $5.94 $4.38 $5.50 $4.80 $4.70 Dunkirk, NY $688,000 $603,000 $429,000 $511,000 $497,000 -12% -38% -26% -28% $53.58 $46.92 $33.40 $39.79 $38.73 Dutchess County, NY $1,933,000 $1,279,000 $1,523,000 $1,391,000 $1,363,000 -34% -21% -28% -30% $8.13 $5.38 $6.41 $5.85 $5.73 Elmira, NY $1,657,000 $1,463,000 $929,000 $1,317,000 $1,282,000 -12% -44% -20% -23% $54.48 $48.09 $30.53 $43.31 $42.16 Erie County, NY $3,396,000 $2,232,000 $2,011,000 $1,897,000 $1,854,000 -34% -41% -44% -45% $12.65 $8.31 $7.49 $7.07 $6.91 Glens Falls, NY $678,000 $522,000 $329,000 $402,000 $393,000 -23% -52% -41% -42% $47.77 $36.74 $23.17 $28.34 $27.67 Greece, NY $522,000 $439,000 $549,000 $504,000 $492,000 -16% 5% -4% -6% $5.52 $4.64 $5.80 $5.33 $5.20 Hamburg Town, NY $529,000 $270,000 $338,000 $310,000 $303,000 -49% -36% -41% -43% $9.33 $4.76 $5.96 $5.46 $5.34 Huntington Town, NY $1,115,000 $947,000 $1,066,000 $816,000 $797,000 -15% -4% -27% -29% $5.62 $4.77 $5.37 $4.11 $4.02 Irondequoit, NY $1,174,000 $647,000 $404,000 $395,000 $385,000 -45% -66% -66% -67% $22.45 $12.38 $7.73 $7.55 $7.36 Islip Town, NY $2,509,000 $2,484,000 $2,708,000 $2,928,000 $2,885,000 -1% 8% 17% 15% $7.61 $7.54 $8.21 $8.88 $8.75 Ithaca, NY $976,000 $1,042,000 $601,000 $933,000 $918,000 7% -38% -4% -6% $32.56 $34.76 $20.05 $31.14 $30.64 Jamestown, NY $1,680,000 $1,485,000 $953,000 $1,213,000 $1,182,000 -12% -43% -28% -30% $54.14 $47.86 $30.72 $39.08 $38.10 Kingston, NY $977,000 $786,000 $536,000 $662,000 $647,000 -20% -45% -32% -34% $41.85 $33.68 $22.94 $28.35 $27.71 Middletown, NY $690,000 $652,000 $644,000 $777,000 $762,000 -6% -7% 13% 10% $26.77 $25.30 $25.00 $30.15 $29.57

CDBG Formula Targeting to Community Development Need B-54

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Monroe County, NY $1,799,000 $1,252,000 $1,524,000 $1,227,000 $1,200,000 -30% -15% -32% -33% $5.41 $3.76 $4.58 $3.69 $3.61 Mount Vernon, NY $2,192,000 $1,897,000 $1,691,000 $1,991,000 $1,966,000 -13% -23% -9% -10% $31.95 $27.65 $24.64 $29.02 $28.65 Nassau County, NY $18,477,000 $8,018,000 $9,774,000 $9,187,000 $9,063,000 -57% -47% -50% -51% $14.93 $6.48 $7.90 $7.42 $7.32 New Rochelle, NY $2,035,000 $1,591,000 $1,284,000 $993,000 $981,000 -22% -37% -51% -52% $28.08 $21.95 $17.72 $13.70 $13.54 New York City, NY $218,834,000 $264,274,000 $268,369,000 $288,735,000 $284,767,000 21% 23% 32% 30% $27.07 $32.69 $33.20 $35.72 $35.22 Newburgh, NY $1,015,000 $1,193,000 $1,124,000 $1,424,000 $1,399,000 18% 11% 40% 38% $35.76 $42.04 $39.61 $50.18 $49.29 Niagara Falls, NY $3,088,000 $2,799,000 $1,628,000 $2,276,000 $2,219,000 -9% -47% -26% -28% $56.81 $51.49 $29.95 $41.88 $40.83 Onondaga County, NY $2,526,000 $1,573,000 $1,743,000 $1,466,000 $1,429,000 -38% -31% -42% -43% $9.88 $6.15 $6.82 $5.73 $5.59 Orange County, NY $1,970,000 $1,283,000 $1,599,000 $1,484,000 $1,452,000 -35% -19% -25% -26% $7.34 $4.78 $5.96 $5.53 $5.41 Poughkeepsie, NY $1,244,000 $1,155,000 $920,000 $1,211,000 $1,186,000 -7% -26% -3% -5% $41.37 $38.41 $30.59 $40.27 $39.42 Rochester, NY $11,607,000 $11,417,000 $8,130,000 $11,236,000 $10,961,000 -2% -30% -3% -6% $53.45 $52.57 $37.44 $51.74 $50.47 Rockland County, NY $2,552,000 $2,672,000 $2,946,000 $2,245,000 $2,208,000 5% 15% -12% -13% $8.97 $9.39 $10.35 $7.89 $7.76 Rome, NY $1,456,000 $1,129,000 $668,000 $714,000 $696,000 -22% -54% -51% -52% $41.95 $32.53 $19.24 $20.58 $20.04 Saratoga Springs, NY $445,000 $283,000 $253,000 $244,000 $238,000 -36% -43% -45% -46% $16.47 $10.47 $9.37 $9.03 $8.81 Schenectady, NY $3,112,000 $2,747,000 $1,849,000 $2,610,000 $2,548,000 -12% -41% -16% -18% $50.67 $44.73 $30.10 $42.49 $41.48 Suffolk County, NY $4,474,000 $3,939,000 $4,509,000 $4,723,000 $4,625,000 -12% 1% 6% 3% $6.36 $5.60 $6.41 $6.71 $6.57

CDBG Formula Targeting to Community Development Need B-55

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Syracuse, NY $7,444,000 $7,098,000 $4,824,000 $6,693,000 $6,529,000 -5% -35% -10% -12% $51.28 $48.89 $33.23 $46.10 $44.98 Tonawanda Town, NY $2,247,000 $1,564,000 $756,000 $799,000 $780,000 -30% -66% -64% -65% $29.27 $20.37 $9.85 $10.41 $10.16 Troy, NY $2,494,000 $1,943,000 $1,226,000 $1,740,000 $1,700,000 -22% -51% -30% -32% $51.09 $39.79 $25.11 $35.65 $34.83 Union Town, NY $1,687,000 $1,416,000 $905,000 $967,000 $944,000 -16% -46% -43% -44% $30.20 $25.36 $16.20 $17.32 $16.91 Utica, NY $3,550,000 $3,597,000 $2,228,000 $3,008,000 $2,933,000 1% -37% -15% -17% $59.22 $60.01 $37.16 $50.18 $48.93 West Seneca Town, NY $353,000 $239,000 $269,000 $267,000 $261,000 -32% -24% -24% -26% $7.77 $5.27 $5.92 $5.89 $5.75 Westchester County, NY $6,887,000 $3,121,000 $3,938,000 $2,852,000 $2,815,000 -55% -43% -59% -59% $13.32 $6.03 $7.61 $5.51 $5.44 White Plains, NY $1,103,000 $725,000 $810,000 $554,000 $552,000 -34% -27% -50% -50% $19.91 $13.08 $14.62 $10.01 $9.96 Yonkers, NY $4,485,000 $4,588,000 $4,735,000 $4,942,000 $4,866,000 2% 6% 10% 9% $22.74 $23.26 $24.01 $25.06 $24.67 New York State Program $57,278,000 $46,991,000 $46,800,000 $46,800,000 $47,666,000 -18% -18% -18% -17% $15.23 $12.50 $12.44 $12.44 $12.68 TOTAL $415,358,000 $424,123,000 $408,340,000 $442,007,000 $436,676,000 2% -2% 6% 5% $21.69 $22.15 $21.32 $23.08 $22.80

North Carolina Asheville, NC $1,546,000 $1,472,000 $1,191,000 $1,281,000 $1,250,000 -5% -23% -17% -19% $22.34 $21.28 $17.22 $18.51 $18.06 Burlington, NC $518,000 $547,000 $745,000 $701,000 $686,000 6% 44% 35% 32% $11.26 $11.88 $16.18 $15.24 $14.91 Cary, NC $522,000 $402,000 $379,000 $237,000 $236,000 -23% -27% -55% -55% $5.32 $4.10 $3.87 $2.42 $2.41 Chapel Hill, NC $711,000 $581,000 $609,000 $581,000 $582,000 -18% -14% -18% -18% $13.77 $11.25 $11.79 $11.26 $11.27

CDBG Formula Targeting to Community Development Need B-56

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Charlotte, NC $5,599,000 $5,526,000 $6,699,000 $5,350,000 $5,267,000 -1% 20% -4% -6% $9.64 $9.52 $11.54 $9.21 $9.07 Concord, NC $463,000 $473,000 $632,000 $682,000 $669,000 2% 36% 47% 44% $7.92 $8.08 $10.80 $11.66 $11.43 Cumberland County, NC $1,669,000 $1,766,000 $2,105,000 $1,996,000 $1,943,000 6% 26% 20% 16% $9.32 $9.86 $11.76 $11.15 $10.85 Durham, NC $2,304,000 $2,292,000 $3,038,000 $3,166,000 $3,107,000 -1% 32% 37% 35% $11.76 $11.70 $15.50 $16.16 $15.86 Fayetteville, NC $1,395,000 $1,490,000 $1,977,000 $1,657,000 $1,614,000 7% 42% 19% 16% $11.22 $11.99 $15.91 $13.34 $12.99 Gastonia, NC $772,000 $853,000 $1,157,000 $1,377,000 $1,341,000 10% 50% 78% 74% $11.38 $12.57 $17.06 $20.30 $19.77 Goldsboro, NC $488,000 $595,000 $768,000 $775,000 $752,000 22% 57% 59% 54% $12.68 $15.46 $19.97 $20.13 $19.55 Greensboro, NC $2,296,000 $2,163,000 $2,853,000 $2,478,000 $2,430,000 -6% 24% 8% 6% $10.06 $9.48 $12.50 $10.86 $10.65 Greenville, NC $962,000 $714,000 $977,000 $916,000 $892,000 -26% 2% -5% -7% $14.69 $10.90 $14.91 $13.99 $13.62 Hickory, NC $386,000 $380,000 $483,000 $359,000 $353,000 -1% 25% -7% -9% $9.82 $9.68 $12.29 $9.14 $8.98 High Point, NC $929,000 $961,000 $1,298,000 $1,278,000 $1,247,000 3% 40% 38% 34% $10.25 $10.60 $14.32 $14.10 $13.75 Jacksonville, NC $622,000 $676,000 $778,000 $732,000 $712,000 9% 25% 18% 15% $9.30 $10.10 $11.63 $10.95 $10.64 Kannapolis, NC $491,000 $455,000 $487,000 $595,000 $581,000 -7% -1% 21% 18% $12.91 $11.97 $12.80 $15.63 $15.29 Lenoir, NC $180,000 $219,000 $281,000 $316,000 $307,000 21% 56% 75% 70% $9.96 $12.09 $15.55 $17.46 $16.97 Morganton, NC $183,000 $187,000 $233,000 $195,000 $190,000 2% 27% 7% 4% $10.57 $10.82 $13.44 $11.26 $10.99 Raleigh, NC $2,813,000 $2,438,000 $2,939,000 $2,645,000 $2,603,000 -13% 4% -6% -7% $9.16 $7.94 $9.57 $8.62 $8.48

CDBG Formula Targeting to Community Development Need B-57

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Rocky Mount, NC $804,000 $986,000 $1,331,000 $1,252,000 $1,217,000 23% 66% 56% 51% $14.35 $17.61 $23.77 $22.35 $21.72 Salisbury, NC $397,000 $406,000 $451,000 $432,000 $421,000 2% 13% 9% 6% $15.01 $15.36 $17.04 $16.32 $15.91 Wake County, NC $1,626,000 $1,460,000 $1,693,000 $1,467,000 $1,434,000 -10% 4% -10% -12% $6.28 $5.64 $6.54 $5.67 $5.54 Wilmington, NC $1,059,000 $1,453,000 $1,513,000 $1,567,000 $1,529,000 37% 43% 48% 44% $11.68 $16.03 $16.69 $17.29 $16.87 Winston Salem, NC $2,197,000 $2,292,000 $3,217,000 $3,028,000 $2,960,000 4% 46% 38% 35% $11.63 $12.13 $17.03 $16.03 $15.67 North Carolina State Program $52,454,000 $56,305,000 $63,936,000 $63,936,000 $65,960,000 7% 22% 22% 26% $9.87 $10.60 $12.04 $12.04 $12.42 TOTAL $83,386,000 $87,091,000 $101,769,000 $98,998,000 $100,283,000 4% 22% 19% 20% $10.03 $10.48 $12.24 $11.91 $12.06

North Dakota Bismarck, ND $415,000 $382,000 $484,000 $455,000 $445,000 -8% 17% 10% 7% $7.38 $6.80 $8.61 $8.09 $7.91 Fargo, ND $835,000 $744,000 $878,000 $837,000 $820,000 -11% 5% 0% -2% $9.16 $8.16 $9.63 $9.18 $8.99 Grand Forks, ND $504,000 $413,000 $540,000 $512,000 $500,000 -18% 7% 2% -1% $10.38 $8.52 $11.13 $10.55 $10.31 North Dakota State Program $5,717,000 $5,664,000 $5,633,000 $5,633,000 $5,711,000 -1% -1% -1% 0% $13.64 $13.51 $13.44 $13.44 $13.63 TOTAL $7,471,000 $7,204,000 $7,535,000 $7,438,000 $7,477,000 -4% 1% 0% 0% $12.14 $11.71 $12.25 $12.09 $12.15

Ohio Akron, OH $8,226,000 $7,406,000 $5,045,000 $6,906,000 $6,727,000 -10% -39% -16% -18% $38.38 $34.55 $23.54 $32.22 $31.38 Alliance, OH $835,000 $734,000 $507,000 $688,000 $668,000 -12% -39% -18% -20% $36.33 $31.92 $22.08 $29.92 $29.08

CDBG Formula Targeting to Community Development Need B-58

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Barberton, OH $898,000 $766,000 $533,000 $726,000 $707,000 -15% -41% -19% -21% $32.46 $27.69 $19.26 $26.26 $25.57 Bowling Green, OH $369,000 $229,000 $230,000 $308,000 $301,000 -38% -38% -17% -18% $12.52 $7.76 $7.80 $10.43 $10.21 Butler County, OH $1,389,000 $910,000 $1,085,000 $959,000 $938,000 -35% -22% -31% -32% $6.05 $3.96 $4.72 $4.18 $4.09 Canton, OH $3,512,000 $3,179,000 $2,116,000 $2,930,000 $2,853,000 -9% -40% -17% -19% $44.03 $39.85 $26.52 $36.73 $35.77 Cincinnati, OH $16,103,000 $14,688,000 $9,750,000 $12,302,000 $12,014,000 -9% -39% -24% -25% $49.72 $45.35 $30.10 $37.98 $37.09 Cleveland, OH $29,026,000 $28,790,000 $18,443,000 $25,642,000 $24,978,000 -1% -36% -12% -14% $62.04 $61.54 $39.42 $54.81 $53.39 Cleveland Heights, OH $2,072,000 $1,258,000 $749,000 $742,000 $724,000 -39% -64% -64% -65% $41.66 $25.30 $15.06 $14.91 $14.57 Columbus, OH $7,820,000 $9,791,000 $11,438,000 $13,068,000 $12,762,000 25% 46% 67% 63% $10.78 $13.50 $15.77 $18.02 $17.60 Cuyahoga County, OH $3,841,000 $2,806,000 $3,603,000 $2,960,000 $2,895,000 -27% -6% -23% -25% $6.45 $4.71 $6.05 $4.97 $4.86 Cuyahoga Falls, OH $1,150,000 $450,000 $351,000 $350,000 $342,000 -61% -69% -70% -70% $22.88 $8.96 $6.99 $6.96 $6.80 Dayton, OH $7,675,000 $7,148,000 $4,682,000 $6,394,000 $6,227,000 -7% -39% -17% -19% $47.18 $43.94 $28.78 $39.31 $38.28 East Cleveland, OH $1,339,000 $1,697,000 $1,248,000 $1,749,000 $1,702,000 27% -7% 31% 27% $50.24 $63.69 $46.83 $65.64 $63.84 Elyria, OH $772,000 $706,000 $796,000 $947,000 $920,000 -9% 3% 23% 19% $13.72 $12.53 $14.14 $16.83 $16.34 Euclid, OH $1,221,000 $915,000 $646,000 $760,000 $742,000 -25% -47% -38% -39% $23.52 $17.62 $12.45 $14.64 $14.29 Fairborn, OH $322,000 $257,000 $357,000 $408,000 $397,000 -20% 11% 27% 23% $9.92 $7.92 $10.98 $12.58 $12.23 Franklin County, OH $2,222,000 $1,838,000 $2,330,000 $1,792,000 $1,750,000 -17% 5% -19% -21% $5.72 $4.73 $6.00 $4.62 $4.51

CDBG Formula Targeting to Community Development Need B-59

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Hamilton City, OH $1,831,000 $1,609,000 $1,137,000 $1,534,000 $1,495,000 -12% -38% -16% -18% $30.47 $26.77 $18.91 $25.52 $24.89 Hamilton County, OH $3,294,000 $2,680,000 $3,425,000 $3,306,000 $3,233,000 -19% 4% 0% -2% $8.22 $6.68 $8.54 $8.25 $8.06 Kent, OH $366,000 $348,000 $399,000 $516,000 $503,000 -5% 9% 41% 37% $13.19 $12.53 $14.40 $18.61 $18.14 Kettering, OH $616,000 $231,000 $314,000 $248,000 $243,000 -63% -49% -60% -61% $10.87 $4.07 $5.53 $4.37 $4.29 Lake County, OH $1,664,000 $1,186,000 $1,248,000 $1,240,000 $1,209,000 -29% -25% -25% -27% $9.33 $6.65 $7.00 $6.95 $6.78 Lakewood, OH $2,609,000 $1,418,000 $835,000 $897,000 $880,000 -46% -68% -66% -66% $47.19 $25.64 $15.10 $16.23 $15.92 Lancaster, OH $670,000 $588,000 $528,000 $711,000 $693,000 -12% -21% 6% 3% $18.57 $16.31 $14.63 $19.70 $19.20 Lima, OH $1,454,000 $1,604,000 $1,211,000 $1,654,000 $1,609,000 10% -17% 14% 11% $35.62 $39.29 $29.67 $40.53 $39.42 Lorain, OH $1,523,000 $1,495,000 $1,459,000 $1,839,000 $1,788,000 -2% -4% 21% 17% $22.49 $22.09 $21.55 $27.17 $26.42 Mansfield, OH $1,152,000 $1,211,000 $1,008,000 $1,151,000 $1,120,000 5% -12% 0% -3% $22.70 $23.86 $19.87 $22.68 $22.07 Marietta, OH $534,000 $412,000 $294,000 $322,000 $312,000 -23% -45% -40% -42% $37.82 $29.21 $20.85 $22.78 $22.12 Massillon, OH $889,000 $597,000 $447,000 $552,000 $537,000 -33% -50% -38% -40% $28.17 $18.92 $14.16 $17.50 $17.03 Mentor, OH $216,000 $157,000 $177,000 $155,000 $151,000 -27% -18% -28% -30% $4.30 $3.14 $3.52 $3.09 $3.02 Middletown, OH $799,000 $752,000 $781,000 $931,000 $905,000 -6% -2% 17% 13% $15.61 $14.70 $15.25 $18.20 $17.69 Montgomery County, OH $2,278,000 $2,054,000 $2,800,000 $2,508,000 $2,444,000 -10% 23% 10% 7% $6.68 $6.03 $8.22 $7.36 $7.17 Newark, OH $1,020,000 $934,000 $794,000 $1,074,000 $1,045,000 -8% -22% 5% 2% $21.96 $20.10 $17.09 $23.12 $22.49

CDBG Formula Targeting to Community Development Need B-60

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Parma, OH $1,098,000 $725,000 $527,000 $548,000 $536,000 -34% -52% -50% -51% $12.99 $8.57 $6.24 $6.48 $6.34 Sandusky, OH $967,000 $785,000 $589,000 $759,000 $739,000 -19% -39% -22% -24% $35.35 $28.68 $21.54 $27.74 $27.00 Springfield, OH $2,400,000 $2,132,000 $1,478,000 $1,898,000 $1,848,000 -11% -38% -21% -23% $37.42 $33.24 $23.04 $29.60 $28.82 Stark County, OH $1,729,000 $1,192,000 $1,479,000 $1,329,000 $1,293,000 -31% -14% -23% -25% $7.04 $4.85 $6.02 $5.41 $5.26 Steubenville, OH $908,000 $924,000 $527,000 $574,000 $559,000 2% -42% -37% -38% $46.12 $46.95 $26.75 $29.16 $28.37 Summit County, OH $1,252,000 $959,000 $1,109,000 $862,000 $841,000 -23% -11% -31% -33% $4.90 $3.75 $4.34 $3.38 $3.30 Toledo, OH $9,459,000 $9,450,000 $7,374,000 $9,510,000 $9,262,000 0% -22% 1% -2% $30.60 $30.57 $23.86 $30.77 $29.96 Warren, OH $1,572,000 $1,529,000 $1,183,000 $1,405,000 $1,365,000 -3% -25% -11% -13% $33.29 $32.37 $25.05 $29.74 $28.90 Youngstown, OH $4,897,000 $4,596,000 $2,687,000 $3,723,000 $3,620,000 -6% -45% -24% -26% $61.19 $57.43 $33.58 $46.52 $45.23 Ohio State Program $57,071,000 $50,441,000 $52,330,000 $52,330,000 $53,158,000 -12% -8% -8% -7% $10.88 $9.62 $9.98 $9.98 $10.14 TOTAL $191,060,000 $173,576,000 $150,048,000 $171,209,000 $169,037,000 -9% -21% -10% -12% $16.73 $15.20 $13.14 $14.99 $14.80

Oklahoma Broken Arrow, OK $468,000 $406,000 $432,000 $344,000 $339,000 -13% -8% -26% -28% $5.63 $4.88 $5.20 $4.15 $4.08 Edmond, OK $479,000 $379,000 $454,000 $316,000 $309,000 -21% -5% -34% -36% $6.79 $5.37 $6.44 $4.48 $4.38 Enid, OK $678,000 $906,000 $854,000 $894,000 $870,000 34% 26% 32% 28% $14.57 $19.48 $18.34 $19.22 $18.70 Lawton, OK $1,056,000 $1,165,000 $1,523,000 $1,472,000 $1,431,000 10% 44% 39% 36% $11.56 $12.75 $16.67 $16.12 $15.67

CDBG Formula Targeting to Community Development Need

CDBG Formula Targeting to Community Development Need B-61

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Midwest City, OK $586,000 $637,000 $843,000 $886,000 $861,000 9% 44% 51% 47% $10.75 $11.69 $15.46 $16.26 $15.80 Norman, OK $1,026,000 $733,000 $958,000 $877,000 $858,000 -29% -7% -15% -16% $10.49 $7.49 $9.79 $8.96 $8.77 Oklahoma City, OK $6,355,000 $7,117,000 $9,347,000 $9,174,000 $8,956,000 12% 47% 44% 41% $12.24 $13.71 $18.01 $17.67 $17.26 Shawnee, OK $482,000 $555,000 $562,000 $591,000 $574,000 15% 17% 23% 19% $16.44 $18.93 $19.18 $20.17 $19.59 Tulsa, OK $4,512,000 $4,648,000 $6,297,000 $5,506,000 $5,384,000 3% 40% 22% 19% $11.51 $11.86 $16.07 $14.05 $13.74 Oklahoma State Program $20,040,000 $23,419,000 $25,557,000 $25,557,000 $26,328,000 17% 28% 28% 31% $10.89 $12.72 $13.88 $13.88 $14.30 TOTAL $35,682,000 $39,965,000 $46,826,000 $45,617,000 $45,910,000 12% 31% 28% 29% $11.06 $12.39 $14.52 $14.14 $14.24

Oregon Ashland, OR $250,000 $242,000 $302,000 $278,000 $271,000 -3% 21% 11% 8% $12.37 $11.95 $14.95 $13.74 $13.39 Beaverton, OR $711,000 $668,000 $700,000 $514,000 $513,000 -6% -2% -28% -28% $8.91 $8.38 $8.78 $6.44 $6.43 Bend, OR $491,000 $446,000 $556,000 $520,000 $509,000 -9% 13% 6% 4% $8.61 $7.83 $9.75 $9.13 $8.93 Clackamas County, OR $2,562,000 $2,366,000 $2,680,000 $2,145,000 $2,112,000 -8% 5% -16% -18% $7.18 $6.63 $7.51 $6.01 $5.92 Corvallis, OR $659,000 $574,000 $640,000 $730,000 $716,000 -13% -3% 11% 9% $13.24 $11.53 $12.85 $14.67 $14.39 Eugene, OR $1,666,000 $1,538,000 $1,796,000 $1,672,000 $1,637,000 -8% 8% 0% -2% $11.87 $10.96 $12.79 $11.91 $11.66 Gresham, OR $1,067,000 $1,132,000 $1,220,000 $1,217,000 $1,196,000 6% 14% 14% 12% $11.27 $11.95 $12.88 $12.85 $12.63 Hillsboro, OR $767,000 $778,000 $786,000 $675,000 $673,000 1% 2% -12% -12% $10.10 $10.25 $10.35 $8.89 $8.86

CDBG Formula Targeting to Community Development Need B-62

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Medford, OR $739,000 $775,000 $1,055,000 $977,000 $956,000 5% 43% 32% 29% $11.43 $11.99 $16.31 $15.12 $14.79 Multnomah County, OR $360,000 $328,000 $387,000 $288,000 $283,000 -9% 8% -20% -21% $7.88 $7.17 $8.48 $6.30 $6.21 Portland, OR $12,105,000 $9,239,000 $8,736,000 $9,118,000 $8,979,000 -24% -28% -25% -26% $22.44 $17.13 $16.19 $16.90 $16.65 Salem, OR $1,741,000 $1,832,000 $2,221,000 $1,945,000 $1,910,000 5% 28% 12% 10% $12.35 $12.99 $15.75 $13.80 $13.55 Springfield, OR $739,000 $805,000 $1,027,000 $1,190,000 $1,161,000 9% 39% 61% 57% $13.68 $14.89 $19.01 $22.03 $21.49 Washington County, OR $2,415,000 $2,238,000 $2,366,000 $1,826,000 $1,806,000 -7% -2% -24% -25% $7.64 $7.08 $7.49 $5.78 $5.71 Oregon State Program $16,683,000 $17,378,000 $17,392,000 $17,392,000 $18,637,000 4% 4% 4% 12% $11.27 $11.74 $11.75 $11.75 $12.59 TOTAL $42,955,000 $40,339,000 $41,862,000 $40,489,000 $41,360,000 -6% -3% -6% -4% $12.22 $11.47 $11.91 $11.51 $11.76

Pennsylvania Abington, PA $987,000 $253,000 $281,000 $228,000 $225,000 -74% -71% -77% -77% $17.59 $4.51 $5.02 $4.07 $4.00 Allegheny County, PA $19,327,000 $14,677,000 $9,585,000 $9,084,000 $8,851,000 -24% -50% -53% -54% $22.26 $16.90 $11.04 $10.46 $10.19 Allentown, PA $3,331,000 $3,313,000 $2,751,000 $3,673,000 $3,586,000 -1% -17% 10% 8% $31.39 $31.23 $25.92 $34.62 $33.79 Altoona, PA $2,411,000 $2,019,000 $1,218,000 $1,537,000 $1,497,000 -16% -49% -36% -38% $49.72 $41.63 $25.11 $31.69 $30.88 Beaver County, PA $4,672,000 $3,629,000 $2,345,000 $2,899,000 $2,823,000 -22% -50% -38% -40% $26.15 $20.31 $13.13 $16.23 $15.80 Bensalem Twp., PA $465,000 $428,000 $495,000 $471,000 $464,000 -8% 6% 1% 0% $7.93 $7.29 $8.43 $8.02 $7.90 Berks County, PA $3,257,000 $1,638,000 $1,695,000 $1,620,000 $1,584,000 -50% -48% -50% -51% $10.80 $5.43 $5.62 $5.37 $5.25

CDBG Formula Targeting to Community Development Need B-63

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Bethlehem, PA $2,036,000 $1,778,000 $1,335,000 $1,666,000 $1,626,000 -13% -34% -18% -20% $28.38 $24.78 $18.61 $23.22 $22.66 Bristol Twp., PA $787,000 $607,000 $506,000 $584,000 $572,000 -23% -36% -26% -27% $14.17 $10.93 $9.11 $10.52 $10.30 Bucks County, PA $2,864,000 $1,920,000 $2,305,000 $1,871,000 $1,830,000 -33% -20% -35% -36% $5.77 $3.87 $4.64 $3.77 $3.69 Carlisle, PA $511,000 $406,000 $304,000 $358,000 $349,000 -21% -41% -30% -32% $28.33 $22.52 $16.85 $19.83 $19.37 Chester, PA $1,760,000 $1,795,000 $1,305,000 $1,711,000 $1,668,000 2% -26% -3% -5% $47.49 $48.44 $35.21 $46.17 $45.02 Chester County, PA $3,319,000 $2,190,000 $2,633,000 $2,001,000 $1,962,000 -34% -21% -40% -41% $7.37 $4.87 $5.85 $4.45 $4.36 Dauphin County, PA $1,840,000 $1,266,000 $1,574,000 $1,506,000 $1,473,000 -31% -14% -18% -20% $9.00 $6.20 $7.70 $7.37 $7.21 Delaware County, PA $4,937,000 $3,633,000 $3,217,000 $3,030,000 $2,960,000 -26% -35% -39% -40% $12.75 $9.38 $8.31 $7.82 $7.65 Easton, PA $1,164,000 $885,000 $580,000 $818,000 $799,000 -24% -50% -30% -31% $44.53 $33.85 $22.19 $31.30 $30.58 Erie, PA $4,334,000 $3,998,000 $2,659,000 $3,552,000 $3,463,000 -8% -39% -18% -20% $42.44 $39.15 $26.04 $34.78 $33.91 Harrisburg, PA $2,537,000 $2,414,000 $1,719,000 $2,307,000 $2,251,000 -5% -32% -9% -11% $52.27 $49.74 $35.41 $47.52 $46.37 Haverford, PA $1,200,000 $277,000 $243,000 $219,000 $214,000 -77% -80% -82% -82% $24.86 $5.75 $5.03 $4.53 $4.43 Hazleton, PA $1,147,000 $895,000 $528,000 $646,000 $630,000 -22% -54% -44% -45% $50.41 $39.35 $23.22 $28.41 $27.70 Johnstown, PA $1,926,000 $1,608,000 $843,000 $1,181,000 $1,149,000 -17% -56% -39% -40% $82.91 $69.21 $36.28 $50.84 $49.48 Lancaster, PA $2,157,000 $2,071,000 $1,669,000 $2,246,000 $2,196,000 -4% -23% 4% 2% $38.78 $37.23 $30.00 $40.38 $39.48 Lancaster County, PA $4,057,000 $2,685,000 $3,149,000 $3,055,000 $2,978,000 -34% -22% -25% -27% $9.59 $6.35 $7.45 $7.22 $7.04

CDBG Formula Targeting to Community Development Need B-64

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Lebanon, PA $1,023,000 $762,000 $553,000 $745,000 $727,000 -26% -46% -27% -29% $42.60 $31.73 $23.02 $31.04 $30.25 Lower Merion, PA $1,388,000 $363,000 $325,000 $272,000 $267,000 -74% -77% -80% -81% $23.14 $6.05 $5.42 $4.54 $4.44 Luzerne County, PA $6,025,000 $4,267,000 $2,982,000 $3,211,000 $3,124,000 -29% -51% -47% -48% $26.05 $18.45 $12.89 $13.88 $13.51 McKeesport, PA $1,486,000 $1,295,000 $770,000 $1,071,000 $1,043,000 -13% -48% -28% -30% $63.01 $54.90 $32.63 $45.40 $44.21 Millcreek Twp., PA $302,000 $245,000 $301,000 $223,000 $216,000 -19% 0% -26% -29% $5.74 $4.66 $5.73 $4.23 $4.10 Montgomery County, PA $4,445,000 $2,400,000 $3,024,000 $2,461,000 $2,417,000 -46% -32% -45% -46% $7.46 $4.03 $5.07 $4.13 $4.06 Norristown, PA $1,231,000 $1,096,000 $814,000 $1,090,000 $1,067,000 -11% -34% -11% -13% $39.32 $34.99 $26.00 $34.81 $34.08 Penn Hills, PA $861,000 $673,000 $453,000 $488,000 $475,000 -22% -47% -43% -45% $18.42 $14.39 $9.70 $10.45 $10.17 Philadelphia, PA $63,066,000 $70,630,000 $51,401,000 $70,234,000 $68,629,000 12% -18% 11% 9% $42.26 $47.33 $34.45 $47.07 $45.99 Pittsburgh, PA $20,289,000 $16,728,000 $9,028,000 $11,460,000 $11,191,000 -18% -56% -44% -45% $61.88 $51.02 $27.53 $34.95 $34.13 Reading, PA $3,756,000 $3,961,000 $3,158,000 $4,250,000 $4,150,000 5% -16% 13% 10% $46.66 $49.21 $39.23 $52.80 $51.55 Scranton, PA $4,140,000 $2,940,000 $1,610,000 $2,135,000 $2,081,000 -29% -61% -48% -50% $55.41 $39.36 $21.54 $28.57 $27.86 Sharon, PA $834,000 $673,000 $404,000 $535,000 $521,000 -19% -52% -36% -38% $52.58 $42.44 $25.46 $33.75 $32.84 State College, PA $862,000 $397,000 $416,000 $498,000 $502,000 -54% -52% -42% -42% $22.63 $10.42 $10.92 $13.06 $13.19 Upper Darby, PA $2,329,000 $1,745,000 $1,201,000 $1,468,000 $1,441,000 -25% -48% -37% -38% $28.77 $21.56 $14.84 $18.14 $17.80 Washington County, PA $5,228,000 $4,129,000 $2,730,000 $3,166,000 $3,082,000 -21% -48% -39% -41% $25.56 $20.19 $13.35 $15.48 $15.07

CDBG Formula Targeting to Community Development Need B-65

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Westmoreland County, PA $5,282,000 $3,997,000 $3,242,000 $3,621,000 $3,517,000 -24% -39% -31% -33% $16.26 $12.30 $9.98 $11.14 $10.82 Wilkes-Barre, PA $2,352,000 $1,766,000 $1,012,000 $1,421,000 $1,386,000 -25% -57% -40% -41% $55.97 $42.03 $24.08 $33.83 $32.98 Williamsport, PA $1,536,000 $1,310,000 $790,000 $1,075,000 $1,049,000 -15% -49% -30% -32% $51.06 $43.54 $26.25 $35.72 $34.87 York, PA $2,060,000 $2,023,000 $1,453,000 $2,015,000 $1,967,000 -2% -29% -2% -4% $51.12 $50.20 $36.07 $50.01 $48.82 York County, PA $3,154,000 $1,747,000 $2,026,000 $2,009,000 $1,961,000 -45% -36% -36% -38% $9.04 $5.01 $5.81 $5.76 $5.62 Pennsylvania State Program $59,971,000 $54,554,000 $52,545,000 $52,545,000 $53,112,000 -9% -12% -12% -11% $14.70 $13.37 $12.88 $12.88 $13.02 TOTAL $262,646,000 $232,087,000 $183,175,000 $212,257,000 $209,075,000 -12% -30% -19% -20% $21.29 $18.82 $14.85 $17.21 $16.95

Rhode Island Cranston, RI $1,266,000 $896,000 $778,000 $806,000 $788,000 -29% -39% -36% -38% $15.61 $11.05 $9.59 $9.94 $9.72 East Providence, RI $941,000 $661,000 $591,000 $685,000 $669,000 -30% -37% -27% -29% $18.95 $13.31 $11.90 $13.79 $13.47 Pawtucket, RI $2,472,000 $2,457,000 $1,908,000 $2,586,000 $2,528,000 -1% -23% 5% 2% $33.39 $33.19 $25.77 $34.94 $34.14 Providence, RI $6,792,000 $7,715,000 $6,408,000 $8,469,000 $8,280,000 14% -6% 25% 22% $38.61 $43.86 $36.43 $48.15 $47.07 Warwick, RI $1,034,000 $747,000 $697,000 $667,000 $652,000 -28% -33% -35% -37% $11.88 $8.58 $8.01 $7.66 $7.49 Woonsocket, RI $1,605,000 $1,548,000 $1,221,000 $1,670,000 $1,628,000 -4% -24% 4% 1% $36.58 $35.29 $27.83 $38.06 $37.10 Rhode Island State Program $6,156,000 $5,355,000 $5,279,000 $5,279,000 $5,440,000 -13% -14% -14% -12% $11.03 $9.59 $9.46 $9.46 $9.75 TOTAL $20,266,000 $19,379,000 $16,882,000 $20,163,000 $19,984,000 -4% -17% -1% -1% $18.95 $18.12 $15.78 $18.85 $18.68

CDBG Formula Targeting to Community Development Need B-66

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4

South Carolina Aiken, SC $256,000 $296,000 $373,000 $300,000 $291,000 16% 46% 17% 14% $9.83 $11.36 $14.34 $11.52 $11.16 Anderson, SC $920,000 $860,000 $582,000 $594,000 $577,000 -7% -37% -35% -37% $35.81 $33.46 $22.65 $23.13 $22.44 Charleston, SC $1,288,000 $1,937,000 $1,877,000 $1,786,000 $1,742,000 50% 46% 39% 35% $13.04 $19.61 $19.00 $18.07 $17.63 Charleston County, SC $2,438,000 $2,602,000 $3,372,000 $3,057,000 $2,969,000 7% 38% 25% 22% $11.16 $11.91 $15.43 $13.99 $13.59 Columbia, SC $1,543,000 $1,846,000 $2,080,000 $2,220,000 $2,162,000 20% 35% 44% 40% $13.14 $15.73 $17.72 $18.91 $18.41 Conway, SC $154,000 $179,000 $250,000 $291,000 $282,000 16% 62% 89% 83% $12.81 $14.90 $20.79 $24.24 $23.48 Florence, SC $407,000 $485,000 $623,000 $512,000 $496,000 19% 53% 26% 22% $13.56 $16.14 $20.76 $17.05 $16.54 Greenville, SC $1,329,000 $1,324,000 $1,017,000 $931,000 $906,000 0% -23% -30% -32% $23.66 $23.56 $18.11 $16.56 $16.13 Greenville County, SC $2,860,000 $2,813,000 $3,539,000 $2,883,000 $2,809,000 -2% 24% 1% -2% $8.33 $8.19 $10.31 $8.40 $8.18 Lexington County, SC $1,185,000 $1,098,000 $1,278,000 $1,092,000 $1,062,000 -7% 8% -8% -10% $7.10 $6.58 $7.66 $6.54 $6.36 Myrtle Beach, SC $241,000 $211,000 $240,000 $180,000 $177,000 -13% 0% -25% -27% $9.83 $8.59 $9.78 $7.35 $7.22 Richland County, SC $1,647,000 $1,593,000 $1,934,000 $1,639,000 $1,600,000 -3% 17% 0% -3% $8.54 $8.26 $10.03 $8.50 $8.30 Rock Hill, SC $553,000 $524,000 $718,000 $857,000 $838,000 -5% 30% 55% 52% $10.13 $9.59 $13.15 $15.70 $15.35 Spartanburg, SC $921,000 $1,055,000 $1,016,000 $1,053,000 $1,022,000 15% 10% 14% 11% $23.57 $27.02 $26.00 $26.95 $26.17 Spartanburg County, SC $1,558,000 $1,535,000 $1,944,000 $1,801,000 $1,755,000 -1% 25% 16% 13% $8.20 $8.08 $10.24 $9.48 $9.24

CDBG Formula Targeting to Community Development Need B-67

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Sumter, SC $460,000 $516,000 $710,000 $638,000 $618,000 12% 54% 39% 34% $11.68 $13.10 $18.03 $16.20 $15.69 South Carolina State Program $27,822,000 $30,831,000 $33,880,000 $33,880,000 $34,753,000 11% 22% 22% 25% $11.26 $12.47 $13.71 $13.71 $14.06 TOTAL $45,582,000 $49,704,000 $55,435,000 $53,714,000 $54,058,000 9% 22% 18% 19% $11.10 $12.10 $13.50 $13.08 $13.16

South Dakota Rapid City, SD $596,000 $577,000 $775,000 $712,000 $694,000 -3% 30% 20% 16% $9.89 $9.58 $12.86 $11.82 $11.52 Sioux Falls, SD $980,000 $859,000 $1,154,000 $1,075,000 $1,053,000 -12% 18% 10% 7% $7.51 $6.59 $8.84 $8.24 $8.07 South Dakota State Program $7,774,000 $7,119,000 $7,019,000 $7,019,000 $7,173,000 -8% -10% -10% -8% $14.73 $13.49 $13.30 $13.30 $13.59 TOTAL $9,350,000 $8,555,000 $8,947,000 $8,806,000 $8,920,000 -9% -4% -6% -5% $13.01 $11.91 $12.45 $12.25 $12.41

Tennessee Bristol, TN $278,000 $418,000 $431,000 $443,000 $430,000 50% 55% 59% 55% $11.17 $16.79 $17.31 $17.81 $17.29 Chattanooga, TN $2,265,000 $3,200,000 $3,241,000 $3,379,000 $3,287,000 41% 43% 49% 45% $14.57 $20.59 $20.85 $21.74 $21.15 Clarksville, TN $958,000 $969,000 $1,212,000 $1,091,000 $1,066,000 1% 27% 14% 11% $9.05 $9.15 $11.45 $10.30 $10.07 Cleveland, TN $405,000 $472,000 $567,000 $558,000 $542,000 16% 40% 38% 34% $10.83 $12.61 $15.18 $14.94 $14.50 Jackson, TN $709,000 $955,000 $1,165,000 $1,204,000 $1,172,000 35% 64% 70% 65% $11.69 $15.75 $19.21 $19.85 $19.33 Johnson City, TN $589,000 $811,000 $855,000 $800,000 $777,000 38% 45% 36% 32% $10.38 $14.28 $15.07 $14.09 $13.68 Kingsport, TN $496,000 $980,000 $941,000 $900,000 $873,000 98% 90% 81% 76% $11.18 $22.09 $21.22 $20.29 $19.68

CDBG Formula Targeting to Community Development Need B-68

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Knox County, TN $1,203,000 $1,027,000 $1,259,000 $1,067,000 $1,036,000 -15% 5% -11% -14% $6.10 $5.20 $6.38 $5.41 $5.25 Knoxville, TN $2,262,000 $3,095,000 $3,272,000 $3,949,000 $3,841,000 37% 45% 75% 70% $13.03 $17.82 $18.84 $22.74 $22.12 Memphis, TN $9,742,000 $11,834,000 $15,938,000 $17,215,000 $16,785,000 21% 64% 77% 72% $15.01 $18.24 $24.56 $26.53 $25.87 Morristown, TN $349,000 $434,000 $511,000 $526,000 $512,000 24% 46% 51% 47% $13.88 $17.27 $20.32 $20.93 $20.36 Murfreesboro, TN $722,000 $550,000 $671,000 $685,000 $669,000 -24% -7% -5% -7% $9.64 $7.34 $8.96 $9.15 $8.94 Nashville-Davidson, TN $5,954,000 $5,960,000 $8,048,000 $7,451,000 $7,280,000 0% 35% 25% 22% $10.43 $10.44 $14.10 $13.05 $12.75 Oak Ridge, TN $313,000 $599,000 $450,000 $414,000 $405,000 91% 44% 32% 29% $11.50 $21.99 $16.54 $15.21 $14.86 Shelby County, TN $1,366,000 $1,162,000 $1,261,000 $853,000 $834,000 -15% -8% -38% -39% $5.32 $4.53 $4.91 $3.32 $3.25 Tennessee State Program $31,244,000 $34,182,000 $40,455,000 $40,455,000 $40,969,000 9% 29% 29% 31% $9.36 $10.24 $12.12 $12.12 $12.28 TOTAL $58,855,000 $66,646,000 $80,279,000 $80,993,000 $80,478,000 13% 36% 38% 37% $10.15 $11.50 $13.85 $13.97 $13.88

Texas Abilene, TX $1,329,000 $1,483,000 $1,792,000 $1,731,000 $1,692,000 12% 35% 30% 27% $11.53 $12.87 $15.55 $15.03 $14.68 Allen, TX $263,000 $205,000 $179,000 $126,000 $125,000 -22% -32% -52% -53% $4.60 $3.59 $3.13 $2.20 $2.18 Amarillo, TX $2,168,000 $2,503,000 $3,152,000 $2,945,000 $2,885,000 15% 45% 36% 33% $12.25 $14.14 $17.81 $16.64 $16.30 Arlington, TX $3,825,000 $3,950,000 $4,121,000 $3,204,000 $3,198,000 3% 8% -16% -16% $10.93 $11.29 $11.78 $9.16 $9.14 Austin, TX $8,967,000 $8,400,000 $9,175,000 $7,697,000 $7,660,000 -6% 2% -14% -15% $13.35 $12.50 $13.66 $11.46 $11.40

CDBG Formula Targeting to Community Development Need B-69

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Baytown City, TX $1,003,000 $1,178,000 $1,359,000 $1,442,000 $1,422,000 17% 36% 44% 42% $14.89 $17.49 $20.18 $21.41 $21.10 Beaumont, TX $2,126,000 $2,502,000 $2,608,000 $2,387,000 $2,326,000 18% 23% 12% 9% $18.84 $22.16 $23.11 $21.15 $20.61 Bexar County, TX $2,067,000 $2,243,000 $2,422,000 $1,998,000 $1,958,000 9% 17% -3% -5% $9.54 $10.35 $11.18 $9.22 $9.04 Brazoria County, TX $2,329,000 $2,482,000 $2,653,000 $2,380,000 $2,347,000 7% 14% 2% 1% $9.75 $10.39 $11.11 $9.97 $9.83 Brownsville, TX $3,916,000 $5,190,000 $5,729,000 $5,563,000 $5,421,000 33% 46% 42% 38% $26.03 $34.50 $38.09 $36.98 $36.03 Bryan, TX $1,129,000 $1,141,000 $1,325,000 $1,186,000 $1,163,000 1% 17% 5% 3% $16.93 $17.11 $19.87 $17.78 $17.44 Carrollton, TX $950,000 $949,000 $933,000 $648,000 $653,000 0% -2% -32% -31% $8.25 $8.24 $8.10 $5.63 $5.67 College Station, TX $1,345,000 $628,000 $667,000 $619,000 $607,000 -53% -50% -54% -55% $19.06 $8.90 $9.46 $8.77 $8.60 Conroe, TX $656,000 $766,000 $832,000 $865,000 $853,000 17% 27% 32% 30% $16.79 $19.60 $21.30 $22.14 $21.84 Corpus Christi, TX $4,105,000 $4,737,000 $5,975,000 $5,337,000 $5,228,000 15% 46% 30% 27% $14.74 $17.01 $21.45 $19.16 $18.77 Dallas, TX $21,184,000 $24,598,000 $27,798,000 $25,786,000 $25,578,000 16% 31% 22% 21% $17.49 $20.30 $22.95 $21.28 $21.11 Dallas County, TX $2,252,000 $2,272,000 $2,480,000 $1,987,000 $1,974,000 1% 10% -12% -12% $8.27 $8.34 $9.10 $7.29 $7.25 Denison, TX $450,000 $508,000 $451,000 $496,000 $483,000 13% 0% 10% 7% $19.42 $21.91 $19.46 $21.39 $20.86 Denton, TX $1,005,000 $763,000 $902,000 $1,013,000 $1,000,000 -24% -10% 1% 0% $11.12 $8.44 $9.98 $11.22 $11.07 Edinburg, TX $1,091,000 $1,368,000 $1,507,000 $1,086,000 $1,058,000 25% 38% 0% -3% $20.68 $25.94 $28.57 $20.58 $20.05 El Paso, TX $10,236,000 $12,705,000 $15,000,000 $12,500,000 $12,207,000 24% 47% 22% 19% $17.73 $22.00 $25.98 $21.65 $21.14

CDBG Formula Targeting to Community Development Need B-70

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Flower Mound, TX $246,000 $184,000 $159,000 $104,000 $101,000 -25% -36% -58% -59% $4.19 $3.14 $2.70 $1.77 $1.73 Fort Bend County, TX $2,148,000 $2,253,000 $2,277,000 $1,708,000 $1,694,000 5% 6% -20% -21% $8.94 $9.38 $9.48 $7.11 $7.05 Fort Worth, TX $7,900,000 $8,857,000 $11,018,000 $11,608,000 $11,437,000 12% 39% 47% 45% $13.92 $15.61 $19.41 $20.45 $20.15 Galveston, TX $1,748,000 $1,891,000 $1,637,000 $1,974,000 $1,933,000 8% -6% 13% 11% $30.84 $33.35 $28.88 $34.83 $34.09 Garland, TX $2,552,000 $2,818,000 $2,876,000 $2,707,000 $2,717,000 10% 13% 6% 6% $11.62 $12.83 $13.09 $12.32 $12.37 Grand Prairie, TX $1,639,000 $1,838,000 $1,996,000 $1,893,000 $1,883,000 12% 22% 16% 15% $12.11 $13.58 $14.75 $13.99 $13.92 Harlingen, TX $1,149,000 $1,431,000 $1,703,000 $1,209,000 $1,181,000 25% 48% 5% 3% $19.35 $24.10 $28.67 $20.35 $19.89 Harris County, TX $12,729,000 $13,528,000 $14,003,000 $10,614,000 $10,545,000 6% 10% -17% -17% $9.62 $10.22 $10.58 $8.02 $7.97 Hidalgo County, TX $10,116,000 $13,693,000 $14,521,000 $15,476,000 $15,020,000 35% 44% 53% 48% $29.31 $39.68 $42.07 $44.84 $43.52 Houston, TX $36,209,000 $42,271,000 $47,690,000 $43,443,000 $42,994,000 17% 32% 20% 19% $18.02 $21.03 $23.73 $21.62 $21.39 Irving, TX $2,755,000 $2,998,000 $3,040,000 $2,384,000 $2,413,000 9% 10% -13% -12% $14.05 $15.29 $15.50 $12.16 $12.31 Killeen, TX $1,126,000 $1,249,000 $1,372,000 $1,225,000 $1,210,000 11% 22% 9% 7% $12.15 $13.47 $14.79 $13.22 $13.05 Laredo, TX $4,336,000 $5,630,000 $6,225,000 $5,213,000 $5,098,000 30% 44% 20% 18% $22.64 $29.39 $32.50 $27.22 $26.61 League City, TX $316,000 $288,000 $279,000 $183,000 $181,000 -9% -12% -42% -43% $6.15 $5.61 $5.42 $3.55 $3.52 Lewisville, TX $662,000 $615,000 $617,000 $475,000 $477,000 -7% -7% -28% -28% $7.88 $7.33 $7.35 $5.66 $5.68 Longview, TX $928,000 $1,029,000 $1,301,000 $1,131,000 $1,103,000 11% 40% 22% 19% $12.48 $13.85 $17.51 $15.21 $14.84

CDBG Formula Targeting to Community Development Need B-71

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Lubbock, TX $2,782,000 $2,657,000 $3,248,000 $2,915,000 $2,852,000 -4% 17% 5% 3% $13.66 $13.04 $15.95 $14.31 $14.00 Marshall, TX $499,000 $702,000 $672,000 $738,000 $718,000 41% 35% 48% 44% $20.81 $29.28 $28.03 $30.77 $29.94 McAllen, TX $2,134,000 $2,681,000 $2,920,000 $1,869,000 $1,827,000 26% 37% -12% -14% $18.74 $23.54 $25.65 $16.41 $16.04 McKinney, TX $539,000 $493,000 $514,000 $381,000 $376,000 -9% -5% -29% -30% $7.38 $6.74 $7.03 $5.22 $5.15 Mesquite, TX $1,097,000 $1,099,000 $1,174,000 $1,104,000 $1,101,000 0% 7% 1% 0% $8.52 $8.53 $9.12 $8.57 $8.55 Midland, TX $1,092,000 $1,197,000 $1,411,000 $1,229,000 $1,203,000 10% 29% 13% 10% $11.40 $12.49 $14.73 $12.82 $12.55 Mission, TX $985,000 $1,267,000 $1,363,000 $903,000 $878,000 29% 38% -8% -11% $19.15 $24.63 $26.50 $17.56 $17.08 Missouri City, TX $333,000 $290,000 $284,000 $178,000 $178,000 -13% -15% -47% -46% $5.63 $4.89 $4.79 $3.00 $3.01 Montgomery County, TX $2,065,000 $2,036,000 $2,056,000 $1,440,000 $1,413,000 -1% 0% -30% -32% $7.70 $7.60 $7.67 $5.37 $5.27 New Braunfels, TX $396,000 $417,000 $493,000 $440,000 $432,000 5% 24% 11% 9% $9.60 $10.12 $11.94 $10.66 $10.46 North Richland Hills, TX $392,000 $360,000 $381,000 $269,000 $269,000 -8% -3% -31% -31% $6.62 $6.09 $6.44 $4.55 $4.54 Odessa, TX $1,363,000 $1,597,000 $1,902,000 $1,592,000 $1,554,000 17% 40% 17% 14% $14.98 $17.56 $20.91 $17.50 $17.09 Orange, TX $543,000 $604,000 $520,000 $549,000 $534,000 11% -4% 1% -2% $29.84 $33.17 $28.56 $30.17 $29.35 Pasadena, TX $2,337,000 $2,766,000 $2,956,000 $3,026,000 $2,998,000 18% 26% 30% 28% $16.11 $19.07 $20.38 $20.87 $20.67 Pharr, TX $1,321,000 $1,762,000 $1,853,000 $1,635,000 $1,592,000 33% 40% 24% 21% $25.76 $34.37 $36.14 $31.88 $31.04 Plano, TX $1,477,000 $1,328,000 $1,273,000 $765,000 $762,000 -10% -14% -48% -48% $6.20 $5.58 $5.34 $3.21 $3.20

CDBG Formula Targeting to Community Development Need B-72

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Port Arthur, TX $1,666,000 $1,937,000 $1,845,000 $2,211,000 $2,158,000 16% 11% 33% 30% $29.29 $34.06 $32.44 $38.88 $37.93 Richardson, TX $777,000 $688,000 $659,000 $418,000 $421,000 -11% -15% -46% -46% $8.01 $7.10 $6.80 $4.32 $4.34 Round Rock, TX $447,000 $394,000 $393,000 $302,000 $304,000 -12% -12% -32% -32% $6.05 $5.34 $5.32 $4.09 $4.12 San Angelo, TX $1,084,000 $1,170,000 $1,527,000 $1,451,000 $1,416,000 8% 41% 34% 31% $12.40 $13.39 $17.46 $16.60 $16.20 San Antonio, TX $17,379,000 $20,078,000 $24,497,000 $23,218,000 $22,789,000 16% 41% 34% 31% $14.55 $16.81 $20.51 $19.44 $19.08 San Benito, TX $609,000 $803,000 $941,000 $890,000 $868,000 32% 54% 46% 43% $25.30 $33.38 $39.08 $36.98 $36.08 San Marcos, TX $618,000 $405,000 $450,000 $490,000 $485,000 -34% -27% -21% -22% $14.86 $9.74 $10.81 $11.78 $11.65 Sherman, TX $391,000 $453,000 $558,000 $550,000 $540,000 16% 43% 41% 38% $10.93 $12.67 $15.58 $15.38 $15.09 Sugar Land, TX $388,000 $343,000 $340,000 $211,000 $209,000 -12% -12% -46% -46% $5.66 $4.99 $4.96 $3.07 $3.05 Tarrant County, TX $3,800,000 $3,695,000 $3,923,000 $2,866,000 $2,842,000 -3% 3% -25% -25% $7.68 $7.46 $7.93 $5.79 $5.74 Temple, TX $618,000 $662,000 $903,000 $742,000 $725,000 7% 46% 20% 17% $11.35 $12.17 $16.58 $13.62 $13.31 Texarkana, TX $555,000 $755,000 $903,000 $844,000 $820,000 36% 63% 52% 48% $15.76 $21.44 $25.64 $23.99 $23.30 Texas City, TX $521,000 $581,000 $752,000 $880,000 $861,000 12% 44% 69% 65% $12.10 $13.50 $17.46 $20.44 $19.99 Tyler, TX $1,132,000 $1,242,000 $1,601,000 $1,419,000 $1,386,000 10% 41% 25% 22% $13.01 $14.28 $18.40 $16.30 $15.93 Victoria, TX $762,000 $862,000 $1,063,000 $919,000 $900,000 13% 40% 21% 18% $12.49 $14.12 $17.42 $15.06 $14.74 Waco, TX $2,006,000 $2,232,000 $2,672,000 $3,022,000 $2,950,000 11% 33% 51% 47% $17.33 $19.28 $23.09 $26.11 $25.49

CDBG Formula Targeting to Community Development Need B-73

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Wichita Falls, TX $1,641,000 $1,593,000 $1,501,000 $1,500,000 $1,463,000 -3% -9% -9% -11% $15.94 $15.47 $14.58 $14.57 $14.22 Williamson County, TX $1,215,000 $1,089,000 $1,157,000 $1,004,000 $994,000 -10% -5% -17% -18% $6.03 $5.40 $5.74 $4.98 $4.93 Texas State Program $86,718,000 $98,206,000 $89,187,000 $89,187,000 $95,771,000 13% 3% 3% 10% $13.18 $14.92 $13.55 $13.55 $14.55 TOTAL $300,637,000 $339,587,000 $359,667,000 $333,502,000 $336,410,000 13% 20% 11% 12% $13.80 $15.59 $16.51 $15.31 $15.45

Utah Clearfield, UT $279,000 $254,000 $297,000 $324,000 $319,000 -9% 6% 16% 14% $10.60 $9.66 $11.28 $12.31 $12.11 Layton, UT $409,000 $386,000 $406,000 $333,000 $328,000 -6% -1% -19% -20% $6.81 $6.42 $6.75 $5.54 $5.46 Logan, UT $705,000 $553,000 $704,000 $719,000 $708,000 -22% 0% 2% 0% $16.43 $12.88 $16.41 $16.75 $16.50 Ogden, UT $1,367,000 $1,653,000 $1,698,000 $1,896,000 $1,863,000 21% 24% 39% 36% $17.38 $21.02 $21.59 $24.11 $23.69 Orem, UT $727,000 $713,000 $741,000 $591,000 $580,000 -2% 2% -19% -20% $8.69 $8.52 $8.85 $7.07 $6.94 Provo, UT $2,039,000 $1,487,000 $1,596,000 $1,585,000 $1,573,000 -27% -22% -22% -23% $19.39 $14.14 $15.18 $15.07 $14.96 Salt Lake City, UT $4,891,000 $3,897,000 $3,509,000 $3,373,000 $3,325,000 -20% -28% -31% -32% $26.98 $21.50 $19.36 $18.61 $18.34 Salt Lake County, UT $2,969,000 $2,803,000 $3,006,000 $2,446,000 $2,417,000 -6% 1% -18% -19% $7.33 $6.92 $7.42 $6.04 $5.97 Sandy City, UT $475,000 $406,000 $403,000 $313,000 $307,000 -15% -15% -34% -35% $5.32 $4.55 $4.52 $3.51 $3.44 St. George, UT $548,000 $555,000 $577,000 $454,000 $445,000 1% 5% -17% -19% $10.14 $10.27 $10.67 $8.40 $8.24 Taylorsville, UT $457,000 $445,000 $456,000 $420,000 $418,000 -3% 0% -8% -8% $7.73 $7.53 $7.71 $7.11 $7.08

CDBG Formula Targeting to Community Development Need B-74

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 West Jordan, UT $486,000 $459,000 $443,000 $428,000 $424,000 -6% -9% -12% -13% $6.63 $6.25 $6.04 $5.84 $5.77 West Valley, UT $1,112,000 $1,202,000 $1,260,000 $1,283,000 $1,273,000 8% 13% 15% 14% $10.00 $10.81 $11.33 $11.53 $11.44 Utah State Program $7,525,000 $7,517,000 $6,431,000 $6,431,000 $7,001,000 0% -15% -15% -7% $8.04 $8.03 $6.87 $6.87 $7.48 TOTAL $23,989,000 $22,329,000 $21,526,000 $20,596,000 $20,982,000 -7% -10% -14% -13% $10.40 $9.68 $9.33 $8.93 $9.10

Vermont Burlington, VT $1,044,000 $1,036,000 $711,000 $965,000 $945,000 -1% -32% -8% -9% $26.45 $26.25 $18.01 $24.44 $23.95 Vermont State Program $8,692,000 $6,962,000 $6,787,000 $6,787,000 $6,927,000 -20% -22% -22% -20% $15.06 $12.06 $11.76 $11.76 $12.00 TOTAL $9,736,000 $7,998,000 $7,498,000 $7,752,000 $7,872,000 -18% -23% -20% -19% $15.79 $12.97 $12.16 $12.57 $12.77

Virginia Alexandria, VA $1,499,000 $1,527,000 $1,700,000 $1,108,000 $1,114,000 2% 13% -26% -26% $11.46 $11.67 $13.00 $8.47 $8.51 Arlington County, VA $2,248,000 $2,027,000 $2,240,000 $1,465,000 $1,479,000 -10% 0% -35% -34% $11.21 $10.10 $11.17 $7.30 $7.37 Blacksburg, VA $774,000 $280,000 $347,000 $425,000 $413,000 -64% -55% -45% -47% $19.30 $6.98 $8.65 $10.60 $10.29 Bristol, VA $348,000 $377,000 $314,000 $350,000 $339,000 8% -10% 1% -3% $20.33 $22.01 $18.37 $20.47 $19.81 Charlottesville, VA $643,000 $585,000 $617,000 $810,000 $793,000 -9% -4% 26% 23% $14.67 $13.34 $14.08 $18.47 $18.09 Chesapeake, VA $1,476,000 $1,450,000 $1,790,000 $1,593,000 $1,557,000 -2% 21% 8% 5% $7.14 $7.02 $8.66 $7.71 $7.53 Chesterfield County, VA $1,475,000 $1,226,000 $1,388,000 $1,145,000 $1,121,000 -17% -6% -22% -24% $5.44 $4.52 $5.12 $4.22 $4.13

CDBG Formula Targeting to Community Development Need B-75

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Christiansburg, VA $124,000 $111,000 $154,000 $135,000 $131,000 -11% 24% 9% 5% $7.07 $6.32 $8.78 $7.68 $7.46 Colonial Heights, VA $106,000 $104,000 $137,000 $134,000 $132,000 -2% 29% 26% 24% $6.21 $6.10 $8.02 $7.84 $7.71 Danville, VA $1,258,000 $1,521,000 $1,259,000 $1,339,000 $1,301,000 21% 0% 6% 3% $26.43 $31.95 $26.46 $28.13 $27.33 Fairfax County, VA $7,310,000 $6,812,000 $6,558,000 $4,113,000 $4,139,000 -7% -10% -44% -43% $7.17 $6.68 $6.43 $4.03 $4.06 Fredericksburg, VA $279,000 $209,000 $255,000 $322,000 $313,000 -25% -9% 15% 12% $13.90 $10.40 $12.68 $16.03 $15.61 Hampton, VA $1,330,000 $1,326,000 $1,824,000 $1,782,000 $1,741,000 0% 37% 34% 31% $9.11 $9.09 $12.50 $12.21 $11.93 Harrisonburg, VA $648,000 $346,000 $440,000 $490,000 $479,000 -47% -32% -24% -26% $15.84 $8.46 $10.76 $11.98 $11.71 Henrico County, VA $1,760,000 $1,516,000 $1,907,000 $1,526,000 $1,499,000 -14% 8% -13% -15% $6.56 $5.65 $7.11 $5.69 $5.59 Hopewell, VA $253,000 $308,000 $410,000 $497,000 $484,000 22% 62% 96% 91% $11.23 $13.66 $18.19 $22.05 $21.47 Loudoun County, VA $949,000 $718,000 $697,000 $533,000 $530,000 -24% -27% -44% -44% $4.65 $3.52 $3.41 $2.61 $2.60 Lynchburg, VA $1,100,000 $1,286,000 $1,209,000 $1,322,000 $1,288,000 17% 10% 20% 17% $17.02 $19.91 $18.72 $20.46 $19.93 Newport News, VA $1,961,000 $2,081,000 $2,913,000 $3,170,000 $3,094,000 6% 49% 62% 58% $10.88 $11.54 $16.16 $17.58 $17.16 Norfolk, VA $6,249,000 $5,665,000 $4,856,000 $5,536,000 $5,406,000 -9% -22% -11% -13% $26.14 $23.70 $20.32 $23.16 $22.61 Petersburg, VA $819,000 $876,000 $835,000 $1,053,000 $1,026,000 7% 2% 29% 25% $24.73 $26.45 $25.21 $31.79 $30.97 Portsmouth, VA $2,174,000 $2,364,000 $2,058,000 $2,562,000 $2,497,000 9% -5% 18% 15% $21.79 $23.69 $20.63 $25.68 $25.03 Prince William County, VA $2,238,000 $2,031,000 $2,122,000 $2,058,000 $2,045,000 -9% -5% -8% -9% $6.22 $5.64 $5.89 $5.72 $5.68

CDBG Formula Targeting to Community Development Need B-76

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Radford, VA $248,000 $174,000 $152,000 $204,000 $200,000 -30% -39% -18% -19% $15.83 $11.09 $9.68 $13.04 $12.79 Richmond, VA $5,945,000 $5,855,000 $4,968,000 $5,933,000 $5,787,000 -2% -16% 0% -3% $30.11 $29.65 $25.16 $30.05 $29.31 Roanoke, VA $2,207,000 $2,277,000 $1,918,000 $2,306,000 $2,246,000 3% -13% 4% 2% $23.51 $24.26 $20.43 $24.57 $23.93 Suffolk, VA $652,000 $761,000 $994,000 $1,067,000 $1,036,000 17% 52% 64% 59% $9.32 $10.88 $14.21 $15.25 $14.80 Virginia Beach, VA $3,012,000 $2,790,000 $3,199,000 $2,543,000 $2,496,000 -7% 6% -16% -17% $6.94 $6.43 $7.37 $5.86 $5.75 Winchester, VA $306,000 $307,000 $339,000 $334,000 $327,000 0% 11% 9% 7% $12.63 $12.69 $14.00 $13.79 $13.50 Virginia State Program $22,735,000 $25,911,000 $28,900,000 $28,900,000 $29,354,000 14% 27% 27% 29% $8.21 $9.36 $10.44 $10.44 $10.61 TOTAL $72,126,000 $72,820,000 $76,500,000 $74,755,000 $74,364,000 1% 6% 4% 3% $9.89 $9.98 $10.49 $10.25 $10.20

Washington Anacortes, WA $128,000 $113,000 $142,000 $136,000 $132,000 -12% 11% 6% 4% $8.42 $7.41 $9.36 $8.92 $8.72 Auburn, WA $482,000 $498,000 $627,000 $604,000 $594,000 3% 30% 25% 23% $10.92 $11.28 $14.21 $13.69 $13.45 Bellevue, WA $859,000 $771,000 $732,000 $430,000 $431,000 -10% -15% -50% -50% $7.61 $6.83 $6.48 $3.81 $3.82 Bellingham, WA $1,022,000 $973,000 $976,000 $1,052,000 $1,032,000 -5% -5% 3% 1% $14.50 $13.80 $13.85 $14.93 $14.64 Bremerton, WA $631,000 $1,009,000 $955,000 $1,259,000 $1,233,000 60% 51% 99% 95% $17.38 $27.79 $26.29 $34.67 $33.96 Clark County, WA $1,576,000 $1,507,000 $1,684,000 $1,581,000 $1,548,000 -4% 7% 0% -2% $7.03 $6.72 $7.51 $7.05 $6.90 Everett, WA $1,127,000 $1,178,000 $1,511,000 $1,734,000 $1,710,000 4% 34% 54% 52% $11.61 $12.13 $15.56 $17.86 $17.61

CDBG Formula Targeting to Community Development Need B-77

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Federal Way, WA $867,000 $902,000 $984,000 $994,000 $988,000 4% 14% 15% 14% $10.55 $10.98 $11.98 $12.10 $12.02 Kennewick, WA $679,000 $753,000 $837,000 $697,000 $685,000 11% 23% 3% 1% $11.72 $13.00 $14.45 $12.02 $11.82 Kent City, WA $953,000 $1,001,000 $1,104,000 $1,138,000 $1,127,000 5% 16% 19% 18% $11.66 $12.25 $13.51 $13.93 $13.80 King County, WA $5,325,000 $4,911,000 $5,416,000 $3,489,000 $3,461,000 -8% 2% -34% -35% $7.28 $6.71 $7.40 $4.77 $4.73 Kitsap County, WA $1,402,000 $1,295,000 $1,507,000 $1,300,000 $1,274,000 -8% 8% -7% -9% $7.06 $6.52 $7.59 $6.54 $6.41 Lakewood, WA $785,000 $838,000 $1,041,000 $948,000 $931,000 7% 33% 21% 19% $13.36 $14.26 $17.71 $16.12 $15.84 Longview, WA $443,000 $542,000 $684,000 $675,000 $658,000 22% 54% 52% 49% $12.49 $15.27 $19.29 $19.04 $18.57 Mount Vernon, WA $385,000 $421,000 $484,000 $524,000 $517,000 9% 26% 36% 34% $14.15 $15.48 $17.80 $19.26 $18.99 Olympia, WA $472,000 $496,000 $528,000 $545,000 $536,000 5% 12% 15% 13% $10.85 $11.39 $12.13 $12.52 $12.31 Pasco, WA $698,000 $854,000 $958,000 $1,020,000 $1,006,000 22% 37% 46% 44% $19.71 $24.11 $27.04 $28.79 $28.40 Pierce County, WA $3,555,000 $3,390,000 $3,877,000 $3,277,000 $3,223,000 -5% 9% -8% -9% $7.49 $7.14 $8.17 $6.91 $6.79 Renton City, WA $545,000 $537,000 $635,000 $635,000 $632,000 -2% 17% 17% 16% $10.25 $10.09 $11.95 $11.95 $11.88 Richland, WA $323,000 $306,000 $405,000 $302,000 $296,000 -5% 26% -6% -8% $7.78 $7.38 $9.77 $7.28 $7.14 Seattle, WA $14,803,000 $7,755,000 $7,645,000 $7,102,000 $7,028,000 -48% -48% -52% -53% $25.95 $13.60 $13.40 $12.45 $12.32 Shoreline, WA $427,000 $386,000 $452,000 $452,000 $448,000 -10% 6% 6% 5% $8.09 $7.32 $8.56 $8.56 $8.48 Snohomish County, WA $3,677,000 $3,379,000 $3,591,000 $3,533,000 $3,502,000 -8% -2% -4% -5% $7.07 $6.50 $6.90 $6.79 $6.73

CDBG Formula Targeting to Community Development Need B-78

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Spokane, WA $4,583,000 $4,841,000 $4,022,000 $4,511,000 $4,411,000 6% -12% -2% -4% $23.35 $24.66 $20.49 $22.98 $22.47 Spokane County, WA $1,831,000 $1,642,000 $2,019,000 $1,826,000 $1,784,000 -10% 10% 0% -3% $7.92 $7.10 $8.73 $7.90 $7.72 Tacoma, WA $3,354,000 $3,489,000 $3,937,000 $4,306,000 $4,222,000 4% 17% 28% 26% $16.98 $17.66 $19.93 $21.80 $21.37 Vancouver, WA $1,606,000 $1,668,000 $2,018,000 $2,084,000 $2,046,000 4% 26% 30% 27% $10.72 $11.13 $13.47 $13.91 $13.65 Yakima, WA $1,389,000 $1,647,000 $2,146,000 $1,939,000 $1,908,000 19% 55% 40% 37% $18.95 $22.47 $29.28 $26.46 $26.03 Washington State Program $18,647,000 $19,471,000 $18,653,000 $18,653,000 $20,195,000 4% 0% 0% 8% $12.22 $12.76 $12.23 $12.23 $13.24 TOTAL $72,574,000 $66,571,000 $69,572,000 $66,744,000 $67,556,000 -8% -4% -8% -7% $12.02 $11.02 $11.52 $11.05 $11.19

West Virginia Charleston, WV $2,271,000 $1,932,000 $1,088,000 $907,000 $882,000 -15% -52% -60% -61% $43.92 $37.37 $21.05 $17.53 $17.06 Huntington, WV $2,546,000 $2,574,000 $1,455,000 $1,685,000 $1,640,000 1% -43% -34% -36% $51.01 $51.58 $29.16 $33.75 $32.86 Martinsburg, WV $495,000 $492,000 $386,000 $502,000 $488,000 -1% -22% 1% -1% $32.74 $32.57 $25.53 $33.20 $32.29 Morgantown, WV $675,000 $1,058,000 $669,000 $917,000 $899,000 57% -1% 36% 33% $24.69 $38.70 $24.46 $33.54 $32.90 Parkersburg, WV $1,276,000 $1,250,000 $838,000 $1,032,000 $1,001,000 -2% -34% -19% -22% $39.51 $38.70 $25.93 $31.95 $30.98 Weirton, WV $592,000 $467,000 $251,000 $243,000 $235,000 -21% -58% -59% -60% $29.56 $23.30 $12.55 $12.12 $11.75 Wheeling, WV $1,799,000 $1,490,000 $796,000 $863,000 $841,000 -17% -56% -52% -53% $59.24 $49.06 $26.21 $28.42 $27.70

CDBG Formula Targeting to Community Development Need B-79

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 West Virginia State Program $19,912,000 $27,709,000 $30,106,000 $30,106,000 $29,988,000 39% 51% 51% 51% $12.64 $17.59 $19.11 $19.11 $19.04 TOTAL $29,566,000 $36,973,000 $35,589,000 $36,254,000 $35,975,000 25% 20% 23% 22% $16.41 $20.52 $19.75 $20.12 $19.97

Wisconsin Appleton, WI $723,000 $440,000 $541,000 $520,000 $512,000 -39% -25% -28% -29% $10.24 $6.22 $7.65 $7.37 $7.25 Beloit, WI $813,000 $736,000 $660,000 $850,000 $833,000 -9% -19% 5% 2% $22.79 $20.64 $18.49 $23.81 $23.34 Dane County, WI $1,317,000 $946,000 $1,160,000 $999,000 $987,000 -28% -12% -24% -25% $6.29 $4.52 $5.54 $4.77 $4.71 Eau Claire, WI $771,000 $793,000 $714,000 $813,000 $798,000 3% -7% 6% 3% $12.36 $12.72 $11.44 $13.04 $12.80 Fond du Lac, WI $670,000 $395,000 $395,000 $433,000 $424,000 -41% -41% -35% -37% $15.84 $9.35 $9.35 $10.25 $10.03 Green Bay, WI $1,128,000 $1,136,000 $1,366,000 $1,478,000 $1,453,000 1% 21% 31% 29% $11.11 $11.19 $13.46 $14.56 $14.32 Janesville, WI $651,000 $451,000 $521,000 $507,000 $497,000 -31% -20% -22% -24% $10.69 $7.40 $8.55 $8.32 $8.16 Kenosha, WI $1,287,000 $1,076,000 $1,214,000 $1,539,000 $1,510,000 -16% -6% 20% 17% $13.91 $11.63 $13.12 $16.64 $16.32 La Crosse, WI $1,204,000 $924,000 $695,000 $842,000 $825,000 -23% -42% -30% -31% $23.51 $18.05 $13.57 $16.45 $16.11 Madison, WI $2,398,000 $2,355,000 $2,330,000 $2,519,000 $2,489,000 -2% -3% 5% 4% $11.14 $10.94 $10.83 $11.71 $11.56 Milwaukee, WI $20,715,000 $21,157,000 $17,382,000 $22,612,000 $22,098,000 2% -16% 9% 7% $35.06 $35.80 $29.42 $38.27 $37.40 Milwaukee County, WI $1,956,000 $1,054,000 $1,338,000 $1,099,000 $1,079,000 -46% -32% -44% -45% $8.18 $4.41 $5.60 $4.60 $4.52 Neenah, WI $253,000 $158,000 $191,000 $171,000 $168,000 -38% -24% -32% -34% $10.34 $6.45 $7.81 $6.99 $6.87

CDBG Formula Targeting to Community Development Need B-80

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Oshkosh, WI $979,000 $735,000 $660,000 $831,000 $815,000 -25% -33% -15% -17% $15.43 $11.59 $10.40 $13.10 $12.85 Racine, WI $2,388,000 $2,028,000 $1,696,000 $2,152,000 $2,107,000 -15% -29% -10% -12% $29.59 $25.13 $21.01 $26.66 $26.10 Sheboygan, WI $1,251,000 $737,000 $637,000 $728,000 $714,000 -41% -49% -42% -43% $25.30 $14.90 $12.88 $14.72 $14.45 Superior, WI $1,042,000 $750,000 $470,000 $573,000 $559,000 -28% -55% -45% -46% $38.29 $27.56 $17.28 $21.05 $20.53 Waukesha, WI $516,000 $358,000 $437,000 $394,000 $392,000 -31% -15% -24% -24% $7.80 $5.42 $6.60 $5.95 $5.92 Waukesha County, WI $1,257,000 $878,000 $885,000 $635,000 $624,000 -30% -30% -50% -50% $4.15 $2.89 $2.92 $2.09 $2.06 Wausau, WI $843,000 $736,000 $624,000 $673,000 $658,000 -13% -26% -20% -22% $22.34 $19.52 $16.54 $17.82 $17.44 Wauwatosa, WI $1,431,000 $267,000 $270,000 $234,000 $229,000 -81% -81% -84% -84% $30.63 $5.72 $5.79 $5.01 $4.90 West Allis, WI $1,661,000 $928,000 $578,000 $680,000 $667,000 -44% -65% -59% -60% $27.39 $15.31 $9.53 $11.22 $11.00 Wisconsin State Program $33,072,000 $22,965,000 $22,709,000 $22,709,000 $23,534,000 -31% -31% -31% -29% $11.43 $7.94 $7.85 $7.85 $8.13 TOTAL $78,326,000 $62,006,000 $57,473,000 $63,993,000 $63,973,000 -21% -27% -18% -18% $14.44 $11.43 $10.59 $11.80 $11.79

Wyoming Casper, WY $551,000 $573,000 $631,000 $623,000 $605,000 4% 15% 13% 10% $11.01 $11.45 $12.62 $12.45 $12.10 Cheyenne, WY $663,000 $609,000 $574,000 $593,000 $579,000 -8% -13% -11% -13% $12.36 $11.35 $10.69 $11.04 $10.79 Wyoming State Program $3,754,000 $3,811,000 $4,195,000 $4,195,000 $4,369,000 2% 12% 12% 16% $9.67 $9.82 $10.81 $10.81 $11.26 TOTAL $4,968,000 $4,993,000 $5,400,000 $5,411,000 $5,553,000 0% 9% 9% 12% $10.10 $10.15 $10.98 $11.00 $11.29

CDBG Formula Targeting to Community Development Need B-81

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4

Puerto Rico Aguadilla Municipio, PR $2,249,000 $2,988,000 $3,529,000 $2,862,000 $2,760,000 33% 57% 27% 23% $34.28 $45.54 $53.78 $43.62 $42.07 Arecibo Municipio, PR $3,313,000 $4,438,000 $5,149,000 $5,765,000 $5,565,000 34% 55% 74% 68% $32.71 $43.82 $50.84 $56.92 $54.94 Bayamon Municipio, PR $5,539,000 $7,250,000 $8,038,000 $6,821,000 $6,608,000 31% 45% 23% 19% $24.65 $32.27 $35.78 $30.36 $29.41 Cabo Rojo Municipio, PR $1,491,000 $1,969,000 $2,196,000 $1,838,000 $1,775,000 32% 47% 23% 19% $30.77 $40.63 $45.32 $37.92 $36.62 Caguas Municipio, PR $4,097,000 $5,425,000 $6,100,000 $5,602,000 $5,424,000 32% 49% 37% 32% $28.91 $38.29 $43.05 $39.54 $38.28 Canovanas Municipio, PR $1,609,000 $2,181,000 $2,393,000 $2,614,000 $2,527,000 36% 49% 62% 57% $36.15 $49.01 $53.76 $58.74 $56.78 Carolina Municipio, PR $4,708,000 $6,101,000 $6,760,000 $4,995,000 $4,855,000 30% 44% 6% 3% $25.11 $32.54 $36.06 $26.64 $25.90 Cayey Municipio, PR $1,581,000 $2,138,000 $2,439,000 $2,739,000 $2,644,000 35% 54% 73% 67% $33.28 $45.01 $51.35 $57.65 $55.67 Cidra Municipio, PR $1,427,000 $1,930,000 $2,081,000 $2,048,000 $1,983,000 35% 46% 44% 39% $32.39 $43.80 $47.24 $46.48 $45.02 Fajardo Municipio, PR $1,169,000 $1,540,000 $1,798,000 $1,676,000 $1,622,000 32% 54% 43% 39% $28.25 $37.23 $43.46 $40.51 $39.20 Guayama Municipio, PR $1,490,000 $2,017,000 $2,349,000 $1,934,000 $1,867,000 35% 58% 30% 25% $33.29 $45.06 $52.47 $43.21 $41.71 Guaynabo Municipio, PR $2,317,000 $2,997,000 $3,381,000 $2,221,000 $2,160,000 29% 46% -4% -7% $22.88 $29.59 $33.38 $21.93 $21.33 Humacao Municipio, PR $1,893,000 $2,517,000 $2,838,000 $2,943,000 $2,845,000 33% 50% 55% 50% $31.71 $42.17 $47.55 $49.30 $47.67 Isabela Municipio, PR $1,579,000 $2,151,000 $2,426,000 $1,983,000 $1,908,000 36% 54% 26% 21% $34.80 $47.40 $53.46 $43.69 $42.05 Juana Diaz Municipio, PR $1,916,000 $2,603,000 $2,889,000 $3,053,000 $2,948,000 36% 51% 59% 54% $37.23 $50.57 $56.13 $59.32 $57.28

CDBG Formula Targeting to Community Development Need B-82

Total Grant Amount/ Per Capita Grant Amount Alternative Change in Funding Relative to FY 2004 Jurisdiction Name FY 2004 Grant Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alt. 1 Alt. 2 Alt. 3 Alt. 4 Manati Municipio, PR $1,591,000 $2,155,000 $2,461,000 $2,638,000 $2,550,000 35% 55% 66% 60% $34.13 $46.23 $52.78 $56.58 $54.70 Mayaguez Municipio, PR $3,451,000 $4,258,000 $5,125,000 $4,791,000 $4,651,000 23% 49% 39% 35% $35.26 $43.50 $52.36 $48.95 $47.51 Ponce Municipio, PR $6,256,000 $8,416,000 $9,992,000 $8,489,000 $8,201,000 35% 60% 36% 31% $33.61 $45.22 $53.69 $45.61 $44.06 Rio Grande Municipio, PR $1,725,000 $2,303,000 $2,525,000 $2,683,000 $2,600,000 33% 46% 56% 51% $32.21 $43.00 $47.14 $50.10 $48.55 San German Municipio, PR $1,263,000 $1,685,000 $1,957,000 $1,690,000 $1,638,000 33% 55% 34% 30% $33.71 $44.97 $52.22 $45.11 $43.72 San Juan Municipio, PR $12,558,000 $16,263,000 $20,449,000 $14,290,000 $13,920,000 30% 63% 14% 11% $28.97 $37.52 $47.18 $32.97 $32.12 San Sebastian Municipio, PR $1,668,000 $2,279,000 $2,514,000 $2,428,000 $2,340,000 37% 51% 46% 40% $36.94 $50.46 $55.66 $53.77 $51.82 Toa Alta Municipio, PR $1,847,000 $2,452,000 $2,654,000 $2,389,000 $2,318,000 33% 44% 29% 26% $27.18 $36.08 $39.06 $35.16 $34.12 Toa Baja Municipio, PR $2,569,000 $3,411,000 $3,789,000 $3,453,000 $3,336,000 33% 48% 34% 30% $27.08 $35.96 $39.94 $36.40 $35.17 Trujillo Alto Municipio, PR $1,884,000 $2,444,000 $2,700,000 $1,927,000 $1,869,000 30% 43% 2% -1% $24.02 $31.15 $34.42 $24.56 $23.83 Vega Baja Municipio, PR $2,077,000 $2,817,000 $3,200,000 $3,544,000 $3,419,000 36% 54% 71% 65% $32.99 $44.75 $50.82 $56.28 $54.30 Yauco Municipio, PR $1,769,000 $2,412,000 $2,717,000 $2,185,000 $2,112,000 36% 54% 24% 19% $37.53 $51.18 $57.65 $46.36 $44.80 Puerto Rico State Program $55,714,000 $74,172,000 $61,831,000 $61,831,000 $65,100,000 33% 11% 11% 17% $41.03 $54.62 $45.53 $45.53 $47.94 TOTAL $130,750,000 $173,312,000 $176,279,000 $161,431,000 $161,547,000 33% 35% 23% 24% $33.88 $44.91 $45.68 $41.83 $41.86

CDBG Formula Targeting to Community Development Need References - 1 References

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CDBG Formula Targeting to Community Development Need

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