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Staff outlines program updates: continuing resolution, national RFI and proposed TBRA and procurement changes

3207991 · April 15, 2025
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Summary

County staff reported that HUD allocations are expected by mid‑May, summarized a national request for information to which Clark County will respond, and described proposed federal tweaks affecting TBRA reimbursements, local procurement (BABA), environmental review thresholds and public service caps.

Clark County staff provided program updates and described a recent request for information (RFI) from House committee offices seeking input on CDBG and HOME program improvements. Rebecca Royce and other county staff told the Urban County Policy Board the county expects HUD to notify entitlement awards by May 15 and that staff will incorporate any adjustments quickly into the consolidated plan action plan for HUD review.

The board was briefed on a national RFI issued by the House (ranking member and chair referenced) with an April 25 response deadline; Clark County staff are preparing a response and invited board members and cities to submit similar comments. The county’s recommended changes include: increasing the CDBG public‑service cap (currently 15%); broadening HOME‑funded TBRA eligible costs (to allow more wraparound services and higher allowable deposit amounts); allowing nonprofits to bill for pre‑housing costs so providers aren’t reimbursed only after a household is housed; reconsidering Build America Buy America (BABA) implementation timelines; and narrowing environmental review triggers that elevate small infrastructure projects to full Environmental Assessment status.

Staff explained details of the TBRA recommendations: HOME currently limits amounts for deposit assistance and restricts HOME‑funded supportive services to narrowly defined housing case‑management. Staff said that landlords and households increasingly demand larger deposits and that nonprofits are accruing application and staff time costs that they cannot invoice until a household is housed. ‘‘That means a household has to get housed before we can pay for any of the costs that it took the nonprofit to get that household into housing,’’ Rebecca Royce said.

Staff also recommended that the HUD rule implementing BABA be reviewed; Clark County staff and some city partners reported implementation and reporting complexity. Lastly, staff called attention to environmental review rules that can force small sidewalk/stormwater projects into a more stringent Environmental Assessment if infrastructure increases pass certain thresholds; staff asked HUD to consider exemptions for small neighborhood improvements.

Staff said the county letter will be filed and encouraged cities and national associations to submit parallel comments. The board did not take a formal vote on the requests but several members expressed support for the recommendations.

Ending: Staff offered to share the draft response letter and national association comment templates with cities and board members for local submission.