19- 498 C.M.R. ch. 37, § 7

Current through 2024-50, December 11, 2024

Section 498-37-7 - AMENDMENTS TO THE PROGRAM STATEMENT

The State may amend the 2009 Program Statement from time to time in accordance with the same procedures required for the preparation and submission of the program statement. The State of Maine's Administrative Procedures Act will guide the amendment process.

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TO: Potential CDBG Applicants

FR: Michael D. Baran, Acting Director, Office of Community Development

DA: September 10, 2008

RE: Community Evaluation Factor

Background: In recent years, for the Housing Assistance, Public Facility and Public Infrastructure programs, a "Community Evaluation Factor" has been used in the scoring process. The 7 factors used totaled 20 points and were calculated for communities within set population ranges. During the rule making process for the Program Statement, some suggestions have been made to use more relevant information, but substantive suggestions as to what might actually be more relevant were not received. Therefore, this year the OCD contracted with Planning Decisions, Inc. to look at this portion of the scoring process.

Planning Decisions identified two major problems with the existing factors. First, the data is complicated to collect and analyze, the process is time-consuming, and unhelpful to potential applicants in predetermining a degree of competitiveness before applying. Second, the data on substandard housing, rental affordability, low and moderate income population, and poverty, are based on the 2000 Census. This is currently six years old, and becomes increasingly out of date each year.

Therefore, Planning Decisions proceeded with their analysis with the following basic assumptions:

1. Scoring factors should be closely related to the program function for which the scoring factors relate (i.e., housing and infrastructure);

2. Some balancing is needed so that there is not a bias towards small communities (with few in need, but a high percentage) and large communities (which may have many in need even with a very low percentage).

3. Data which is updated on an ongoing basis, even if less precise, is preferable to data from the 2000 Census.

4. In order for communities to know in advance where they stand, the points must be predetermined prior to applications, and not depend on application data.

Relevance and weighting of factors: Under the existing system, each of the 7 factors was given an equal weight, so the result is that financial commitment and lower income households were given a "double" weight and the issue becomes whether the factors address the right criteria for the programs in question.

Logically, different criteria might be used to deal with housing needs as opposed to an infrastructure needs. These differences are already part of the scoring system, specifically, the narrative "impact" section (30 points) of the application. The community evaluation factor is meant to come into play when all other factors are basically equal - to determine awards where two communities have similar needs and equally effective solutions.

In this light, the most important factor would appear to be tax burden. For infrastructure, all other things being equal, the State would wish to fund activities in a town that is already making a significant tax effort; while substandard housing is important for rehab programs, and affordable housing is important for all programs and the presence of low-income people is a relevant factor, they are already heavily considered in the low-income benefit aspect of the program design. Financial commitment is relevant, but it does not fit into the Community Evaluation factor, because it is application-specific, and cannot be predetermined.

Given all of this, and putting aside the question of the appropriateness of individual measurements, Planning Decisions recommends a weighting that gives tax burden 50% of the points (10), housing 40% (8 points), and low income population 10% (2 points). The recommended distribution is below.

Type of factor	2006 Measurement	2006points	Recommended2007 points	Comment
Financial commitment	Budget Page review	2	0	Doesn't fit into this factor
	leveraging	3
Substandard housing	without plumbing	3	4	relevant for rehabilitation
Affordability	Renters >25%	3	4	relevant for all housing programs
Tax burden	Tax rate	3	10	the single most important factor for infrastructure
Low income population	Community LMI	3	2	relevant to all programs
	<150% of poverty	3
TOTAL		20	20

Best measures: Given this general weighting of factors, how do we best measure them"

The current substandard housing measure uses data from the 2000 Census and is increasingly irrelevant today as hardly any year-round units in Maine lack complete plumbing and overcrowding continues to be a problem, more indicative of an affordability issue than of poor physical housing conditions. Therefore, the best external indicator for rehabilitation need is simply the age of its housing stock. While the age of housing is measured in the 2000 Census, updating is not important in this case, since the number of older units changes little from year-to-year.

Affordabilityis a problem that changes year to year, as the housing cycle changes. Therefore, the best current measure of affordability is the "affordability index" published annually by Maine Housing which tracks changes in the housing market by community, and matches it against annual changes in median income in that community.

The best measure of tax burden was designed by the Maine Municipal Association a few years ago. Unfortunately, MMA has not continued with this. Therefore, OCD's current approach of calculating the community's tax rate (state-equalized) relative to the state average is better than any of the alternatives.

The best measure of tax burden was designed by the Maine Municipal Association a few years ago. Unfortunately, MMA has not continued with this. Therefore, OCD's current approach of calculating the community's tax rate (state-equalized) relative to the state average is better than any of the alternatives.

The HUD measures of low and moderate income people and poverty are all based on 2000 Census data. Therefore, the best current estimates on a town level for low and moderate income people are from Maine Housing, with data from a private provider called Claritas. For purposes of this factor, the proportion of households under 50% of area median income would provide a good sense of how many really low-income people are residing in an individual community. The measures that will be used are in the table below:

Type of factor	Best measure	How to Score	Source	Timeliness
Substandard housing	housing built before 1939	> 35% = 4 30 to 35% = 3 20 to 30% = 2 10 to 20% = 1 <10% = 0	2000 Census	2000 Census (but doesn't change between Censuses)
Affordability	Affordability Index (state average 0.7)	under 0.7 = 4 0.7 to 0.8 = 3 0.8 to 0.9 = 2 0.9 to 1.0 = 1 1.1+ = 0	Maine Housing	Annual
Tax burden	Keep the same (state average 12.99)	>25 = 10 20 to 24 = 8 15 to 20 = 5 10 to 15 = 3 Under 10 = 0	Maine Revenue Services	Annual
Low income population	<50% of Area Median Income	20% + = 2 10 to 20% = 1 >10% = 0	Maine Housing (Claritas)	Annual

Finally, the question of adjustments for small and large municipalities: The discussion so far has not addressed whether the scoring system should take special measures to account for communities of different sizes - either by scaling all of the proposed measurements by sizes of communities, as is done now, or by including a balance of absolute number and percentage measures, in order to compensate for the effects of size on a measurement.

Planning Decisions does not recommend any special measures for the new method outlined above. There is no particular relationship between old housing and small or large municipalities; or example, Lewiston has a lot of old housing, and so does Osborne, and both would have a high score in this measure. Likewise, tax burden and affordability are unaffected either way by community size. The last measure, low income population, might favor rural communities because it is a percentage measure; but some urban service centers will get the maximum points on this, and therefore is recommended as a low point item.

2009 Community Development Block Grant Program
Community Evaluation Factor
Abbot	9	Belmont	6	Camden	13
Acton	7	Benton	7	Canaan	7
Addison	10	Berwick	10	Canton	10
Albion	8	Bethel	12	Caratunk	6
Alexander	9	Bingham	14	Caribou	13
Alfred	10	Blaine	10	Carmel	9
Allagash	6	Blue Hill	9	Carrabassett Valley	4
Alna	13	Boothbay	8	Carroll plantation	11
Alton	8	Boothbay Harbor	10	Carthage	11
Amherst	8	Bowdoin	9	Cary plantation	8
Amity	10	Bowdoinham	9	Casco	8
Andover	10	Bowerbank	4	Castine	10
Anson	16	Bradford	8	Castle Hill	9
Appleton	10	Bradley	11	Caswell	8
Arrowsic	10	Bremen	8	Chapman	7
Arundel	5	Brewer	13	Charleston	7
Ashland	12	Bridgewater	11	Charlotte	11
Athens	7	Brighton plantation	8	Chelsea	6
Atkinson	10	Bristol	8	Cherryfield	13
Augusta	13	Brooklin	10	Chester	7
Aurora	15	Brooks	9	Chesterville	8
Avon	11	Brooksville	10	China	9
Baileyville	12	Brownfield	8	Clifton	8
Baldwin	10	Brownville	14	Clinton	7
Bancroft	13	Brunswick	11	Columbia	9
Bar Harbor	9	Buckfield	8	Columbia Falls	13
Baring plantation	12	Bucksport	9	Cooper	10
Bath	12	Burlington	11	Coplin plantation	5
Beals	12	Burnham	9	Corinna	7
Beaver Cove	3	Buxton	6	Corinth	4
Beddington	5	Byron	9	Cornish	10
Belfast	15	Calais	17	Cornville	7
Belgrade	8	Cambridge	7	Cranberry Isles	10
Crawford	6	Etna	6	Harmony	7
Crystal	10	Eustis	11	Harrington	11
Cushing	7	Exeter	10	Hartford	8
Cutler	7	Fairfield	11	Hartland	7
Cyr plantation	9	Farmingdale	8	Haynesville	8
Dallas plantation	6	Farmington	12	Hebron	7
Damariscotta	11	Fayette	8	Hermon	7
Danforth	12	Fort Fairfield	14	Hersey	9
Dayton	8	Fort Kent	9	Highland plantation	5
Deblois	9	Frankfort	8	Hiram	11
Dedham	9	Franklin	5	Hodgdon	7
Deer Isle	9	Freedom	10	Holden	6
Denmark	6	Frenchboro	10	Hollis	9
Dennistown plantation	4	Frenchville	9	Hope	9
Dennysville	12	Friendship	9	Houlton	16
Detroit	7	Fryeburg	12	Howland	9
Dexter	11	Gardiner	12	Hudson	2
Dixfield	13	Garfield plantation	4	Industry	9
Dixmont	9	Garland	9	Island Falls	14
Dover-Foxcroft	13	Georgetown	7	Isle au Haut	8
Dresden	8	Gilead	11	Islesboro	8
Drew plantation	9	Glenburn	7	Jackman	11
Durham	8	Gouldsboro	7	Jackson	8
Dyer Brook	7	Grand Isle	11	Jay	9
Eagle Lake	9	Grand Lake Stream Plt	8	Jefferson	4
East Machias	15	Great Pond	6	Jonesboro	10
East Millinocket	12	Greenbush	9	Jonesport	9
Eastbrook	10	Greene	6	Kenduskeag	7
Easton	10	Greenville	11	Kennebunk	11
Eastport	14	Greenwood	9	Kennebunkport	8
Eddington	7	Guilford	10	Kingfield	13
Edgecomb	10	Hallowell	14	Kittery	11
Edinburg	8	Hamlin	8	Knox	8
Eliot	7	Hammond	12	Lagrange	9
Ellsworth	10	Hampden	9	Lake View plantation	4
Embden	3	Hancock	7	Lakeville	8
Enfield	6	Hanover	10	Lamoine	5
Lebanon	8	Maxfield	9	Orland	5
Lee	9	Mechanic Falls	13	Orono	13
Leeds	10	Meddybemps	9	Orrington	8
Levant	7	Medford	10	Osborn	13
Liberty	9	Medway	14	Otis	7
Limerick	10	Mercer	7	Otisfield	5
Limestone	10	Merrill	10	Owls Head	8
Limington	4	Mexico	16	Oxbow plantation	10
Lincoln	9	Milbridge	11	Oxford	7
Lincoln plantation	8	Milford	6	Palermo	8
Lincolnville	9	Millinocket	13	Palmyra	6
Linneus	7	Milo	15	Paris	9
Lisbon	12	Minot	7	Parkman	7
Litchfield	8	Monhegan plantation	10	Parsonsfield	12
Littleton	7	Monmouth	8	Passadumkeag	9
Livermore	8	Monroe	10	Patten	11
Livermore Falls	14	Monson	10	Pembroke	12
Lovell	10	Monticello	11	Penobscot	6
Lowell	9	Montville	12	Perham	11
Lubec	12	Moose River	9	Perry	10
Ludlow	8	Moro plantation	3	Peru	7
Lyman	5	Morrill	9	Phillips	15
Machias	14	Moscow	9	Phippsburg	7
Machiasport	8	Mount Chase	8	Pittsfield	12
Macwahoc plantation	10	Mount Desert	10	Pittston	8
Madawaska	11	Mount Vernon	9	Pleasant Ridge plantation	7
Madison	11	Nashville plantation	4	Plymouth	7
Madrid	5	New Canada	9	Poland	7
Magalloway plantation	4	Northfield	6	Portage Lake	7
Manchester	7	Northport	5	Porter	10
Mapleton	7	Norway	12	Oxbow plantation	10
Mariaville	4	Oakfield	8	Oxford	7
Mars Hill	18	Oakland	10	Palermo	8
Marshfield	9	Ogunquit	8	Palmyra	6
Masardis	11	Old Orchard Beach	10	Paris	9
Matinicus Isle plantation	9	Old Town	14	Parkman	7
Mattawamkeag	11	Orient	2	Parsonsfield	12
Passadumkeag	9	Saco	10	Stonington	10
Passamaquoddy Indianshp Res	5	Sandy River plantation	4	Stow	9
Passamaquoddy Pleasant Point	5	Sanford	11	Strong	10
Patten	11	Sangerville	10	Sullivan	10
Pembroke	12	Searsmont	8	Sumner	10
Penobscot	6	Searsport	12	Surry	8
Penobscot Indian Island Rsrvtion	6	Sebec	8	Swans Island	9
Perham	11	Seboeis plantation	8	Swanville	8
Perry	10	Sedgwick	10	Sweden	9
Peru	7	Shapleigh	6	Talmadge	14
Phillips	15	Sherman	7	Temple	9
Phippsburg	7	Shirley	8	The Forks plantation	6
Pittsfield	12	Sidney	4	Thomaston	15
Pittston	8	Skowhegan	11	Thorndike	9
Pleasant Ridge plantation	7	Smithfield	7	Topsfield	9
Plymouth	7	Smyrna	9	Topsham	8
Poland	7	Solon	8	Tremont	8
Portage Lake	7	Somerville	11	Trenton	7
Porter	10	Sorrento	8	Troy	9
Presque Isle	15	South Berwick	10	Turner	7
Princeton	12	South Bristol	10	Union	11
Prospect	10	South Thomaston	7	Unity	8
Randolph	10	Southport	10	Upton	5
Rangeley	10	Southwest Harbor	8	Van Buren	13
Rangeley plantation	5	Springfield	13	Vanceboro	14
Readfield	8	St. Agatha	10	Vassalboro	6
Reed plantation	11	St. Albans	4	Veazie	9
Richmond	13	St. Francis	8	Verona	8
Ripley	8	St. George	9	Vienna	9
Robbinston	8	St. John plantation	6	Vinalhaven	9
Rockland	15	Stacyville	10	Wade	10
Rockport	10	Starks	9	Waite	10
Rome	7	Stetson	7	Waldo	8
Roque Bluffs	7	Steuben	9	Waldoboro	10
Roxbury	10	Stockholm	11	Wales	9
Rumford	8	Stockton Springs	13	Wallagrass	7
Sabattus	10	Stoneham	7	Waltham	11
Warren	8	Woolwich	10
Washburn	13	York	7
Washington	7
Waterboro	8
Waterford	8
Waterville	18
Wayne	9
Webster plantation	10
Weld	9
Wellington	9
Wells	7
Wesley	10
West Bath	7
West Forks plantation	3
West Gardiner	4
West Paris	10
Westbrook	14
Westfield	9
Westmanland	7
Weston	6
Westport	7
Whitefield	4
Whiting	8
Whitneyville	13
Willimantic	5
Wilton	9
Windsor	8
Winn	13
Winslow	9
Winter Harbor	9
Winterport	8
Winterville plantation	3
Winthrop	9
Wiscasset	10
Woodland	7
Woodstock	6
Woodville	7

19- 498 C.M.R. ch. 37, § 7