The City of St. Louis Community Development Administration (CDA) is soliciting comments on its draft funding priorities for the 2017 Community Development Block Grant (CDBG) and Home Investment Partnerships (HOME) programs.  CDA is accepting written comments on these priorities until 5:00pm on June 17, 2016.  Rise has offered its comments to the City and we would like to share our views with others who may be interested.  Copies of the priorities may be downloaded from the City of St. Louis website here.  The 2017 Funding Priorities document details the types of activities that the City proposes to fund in 2017 with CDBG and HOME funds.

The funding priorities established for the 2017 program year will shape any Request for Proposals CDA issues for funding CDBG eligible programs and activities throughout the City of St. Louis in 2017.  This is a continuation of the revised citizen review and funding application processes initiated by the City with the development of its Five Year (2015—2019) Consolidated Plan.  Rise is proud of the role it played as a member of the consulting team that worked with the City on the Con Plan.  Through public meetings, focus groups and surveys, we were able to involve thousands of City residents in the process, compared to just a handful of people who participated in any previous years within recent memory.  And, with assistance from the US Department of Housing and Urban Development (HUD), in coordination with the preparation of the Con Plan, a group of consultants completed a Market Value Analysis (MVA) for the City, establishing a baseline of information and a way to organize our thinking about the different residential market types throughout the City.  The City commonly refers to the MVA more accurately as the Residential Market Analysis.

After years administering a funding system that allowed little room for competition; that made it very difficult for any new, perhaps better, programs to be funded; and that was by its nature very opaque, CDA and its staff are to be congratulated for negotiating their way through this difficult but important transition period.  I am now concerned, however, that the MVA may be becoming a “catch all” way to seem to designate geographic target areas for a variety of non-housing community development activities without really doing so.

The MVA makes a relative comparison of the residential market strength of different areas throughout the City and classifies them by type.  It is a useful tool for analyzing what residential development strategies might best be suited to different market types, and in some cases, with additional knowledge of the commercial areas, strategies for commercial development.  It is not designed to give us an understanding of where different types of social services or public facilities are most needed.  So it is difficult to understand why CDA proposes to prioritize funding for early childhood centers, street and sidewalk improvements, child care, crime prevention, financial literacy/financial counseling, health services, neighborhood clean-ups and beautification, resident leadership training and development, and youth services in MVA clusters D, E, F & G (Target Area 2) and MVA clusters H & I (Target Area 3).  Aside from there being no rational relationship that would suggest that the enumerated services are more needed in areas of the City that are designated as these particular market types in the MVA, this method does not necessarily result in the targeting of these activities at all.  Target Area 2 is comprised of 45% of all block groups (161 of 360) in the City and Target Area 3 is comprised of 22% of all block groups (78 of 360) in the City, leaving just 34% of the City not within one of these very general “target areas” scattered throughout the City.  With no geographic distinction being made among 239 of the City’s 360 block groups scattered throughout the City, this can hardly be considered “geographic targeting.”

The City should view the progress it has made with the development of the current Consolidated Plan and the administrative changes it has made to its processes for selecting projects and programs to be funded with CDBG and HOME funds as the first important steps in a longer term evolution toward a better place-based community development planning and funding system.  The solicitation of proposals for services and facilities to be funded with CDBG funds should be based on an objective evaluation of where the gaps are in these services and facilities through both data collection and citizen input into the process.  It is only when we take this next step, and start to develop more targeted, coordinated strategies of residential and commercial development, public facilities and the delivery of employment training, child care, youth development, and other services, that we will see the real leveraging and benefits that can be achieved through consolidated planning.

Another curious aspect of the City’s proposed 2017 CDBG and HOME funding priorities is that they completely fail to place any priority on programs and projects in the Promise Zone.  The Promise Zone is a City/County collaboration under which an area that includes practically all of North St. Louis and a large section of North St. Louis County has been designated by the federal government for certain funding preferences.  It has a total population of 200,000, distributed roughly half in the City and half in the County.  The area has high unemployment, high crime and mortality rates; significant numbers of vacant lots and abandoned buildings; and homelessness. The Promise Zone designation gives a funding priority under a variety of federal programs to competitive grant applications for projects within the designated area.  We would encourage the City to try to take full advantage of this designation by encouraging local CDBG and HOME funding proposals that seek additional funding under these direct competitive grant programs.

This kind of targeting and coordination is also what is needed in order for the City to be more successful in attracting foundation and other funding that can greatly leverage its community development efforts.  We should all encourage the City to continue to build on the important progress it has made in recent years and offer to do everything we can to help the City build a more sustainable community development planning and funding system.  Rise would like to encourage others to take advantage of these opportunities to participate in the process by letting the City know what they think of CDA’s proposed 2017 funding priorities, the proposed 2017 Annual Action Plan when it is published, and other ongoing opportunities for input into the local community development planning and funding system.

Stephen Acree, President, Rise Community Development