Amendments

During the course of the Consolidated Plan's five-year cycle, Entitlement Communities like the Town of Normal may need to make changes to already approved Annual Action Plans or the Consolidated Plan.  Such amendments to plans are subject to regulations enforced by the U.S. Department of Housing & Urban Development (HUD) and guidelines put forth in each Entitlement Community's Citizen Participation Plan.  Amendments can be classified as "minor" or "substantial" based on the types of changes proposed. 

The Town's Citizen Participation Plan states that a Substantial Amendment is required if any one of the following criteria applies:
  1.  A change in the use of CDBG money from one activity to another, in excess of $100,000.00
  2.  Activities proposed to be added or deleted from the plan (Consolidated Plan or an Annual Action Plan)
  3.  A change in the purpose, scope, location, or type of beneficiaries of an activity
  4.  A change in priorities for allocating funds
Substantial Amendments are required to go through a public process for review and comment.  A public hearing as well as a 30-day comment period must be publicized and take place before the proposed amendment is submitted to the Town Council and subsequent submission to HUD.  Amendments may be submitted to HUD individually as they are approved or together at the end of the program year.

In preparing a Substantial Amendment for submission to HUD, careful consideration will be given to all comments or views expressed by the public, whether given as verbal testimony at the public hearing or submitted in writing during the 30-day comment period.  The final version of the Substantial Amendment will have a section that presents all comments, plus explanations why any comments were not accepted.

Amendments #1 & #2 to the 2015-2019 Consolidated Plan


The Town submitted two amendments to the 2015-2019 Consolidated Plan to HUD in March of 2019.  This Consolidated Plan and its associated Community Needs Assessment (CNA) were drafted in 2014 and submitted to HUD in early 2015.  Based on consultation with the representatives from HUD, review of the Consolidated Plan and CNA, and the guidelines set forth in the Citizen Participation Plan, Town Staff identified two amendments that should be made to the Consolidated Plan before its expiration.  The Town will enter the fifth and final year of the Consolidated Plan on April 1, 2019. 

The following amendments were proposed by the Town and approved in May 2019:

Removal of "Rehabilitation" (Goal 8) from the Goals Summary (SP-45) table of the Consolidated Plan
Goal 8 states that the Town will provide funding for "at least one restoration project during the five-year period covered by [the] Consolidated Plan."  "Rehabilitation" was    defined as any work done to a home, group home, business facade, or "building subject to historic preservation."  No such project was funded or carried out with CDBG money.  Instead, the Town used General Funds dollars through the Emergency Repair Program to fund rehabilitation projects for residences.  The $61,152 budgeted for this goal was distributed to other eligible, approved activities.  Residential and/or commercial property rehabilitation is not called out as a priority need in the 2014 Community Needs Assessment.  

Corrections to the Goals Summary (SP-45) table's "Year Start/End," "Funding," and "Goal Outcome Indicator" columns
The information placed in these columns of the Goal Summary table were entered incorrectly back in 2015.  This table is supposed to forecast the funding levels and goal outcome indicators over a period of five years, but the numbers put forth and previously approved were for both one- and five-year goals.  HUD representatives have requested that this clerical error be corrected to show five-year figures before the expiration of the Consolidated Plan. 

The materials submitted to HUD related to these two amendments can be seen here.