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8/12/00: Miami-Dade County Commissioner Jimmy Morales has proposed an ordinance that would discourage using CDBG funds to free up other revenue to pay for ordinary government expendures. Congresswoman Carrie Meek spoke out forcefully for the proposal at a recent commission meeting. The Commission has a scheduled an Octoboer "Workshop" to discuss it.

As background, the legislation was designed to address what some saw as the utilization of the CDBG monies as a resource to narrow the gaps in individual County departmental budgets with CDBG being used to often provide what, to the outsider, seems as basic governmental services. The use of CDBG in low income areas to provide a service while an equivalent service was being funded out of "general revenue dollars" (the public library is the clearest example) illustrated how this perception, fairly or unfairly, raises our concern. The meeting was very elucidating for the Coalition to recognize the complexities and budgetary challenges the County faces.

It is at this time that the Coalition would like to continue the dialogue with County administration on how the proposed legislation might be able to be finessed to meet the budgetary concerns the county has while offering greater clarity on how the CDBG program is administered and can be improved in the overall budgetary context of county government. While being cognizant of the budgetary concerns of Miami-Dade; the Coalition would like to offer the following as possible remedies that might serve as possible policy measures that will meet the Coalition's goal of greater CDBG scrutiny while overcoming some of the administration's particular concerns with the ordinance.

If the County is going to use CDBG dollars for infrastructural upgrades and other public work-type of activities, County agencies should provide an in-kind contribution of general revenue funds. To remedy a situation where CDBG often stands alone in the funding of activities and services, the County may want to require that agencies match CDBG dollars with their own general revenue dollars. To stretch the effectiveness and multiply the investment of CDBG, the County may want to consider looking at the CDBG dollars as a leveraging too to access other funding streams in the same manner that OCED applies CDBG towards nonprofit venture development activities. This could easily be done in the OCED RFA process that scores favorably on leveraging and the creation of public/private partnerships.

Incorporate the Morales' "basic and appropriate level of governmental service" criteria with the County Manager's "Strategic Management Model/Planning Process. The Budget Office was very concerned with the prospect of the proposed ordinance's provision that asked the County Manager to "establish and maintain the basic and appropriate level of governmental service of governmental services and programs", interpreting this as mandating the Budget Office the provide services that it did not nearly have the resources to provide. In addition, according to the Budget Director, what is a "basic and appropriate level of governmental service" is opaque at best and very subjective.

However, how the Commission and concerned citizenry can decipher whether CDBG is being applied as a supplement (i.e.. investment) without having a "baseline" level of expected general services from general revenue dollars allows for too much subjectivity and relativity on how the funds are being applied. With the County Manager's Office moving forward with the development of the County Strategic Management Model; the Coalition sees this as an opportunity for collaboration in defining what will be a "basic level of service". Since this strategic plan will allow for each County Agency to "define a specific measurable departmental business plan" based on customer surveys of "expectations, experience, and customer satisfaction"; we feel that the implementation of this ambitious proposal will move towards providing greater clarity on exactly what are the general expectations from local government.

The Coalition would add as a caveat that those expectations should be evaluated in the context of the overall budgetary picture that excludes CDBG funds. In other words, the evaluation should be centered on whether or not the County can honestly meet the expectations based on the availability of general revenue dollars. The idea is to provide the citizenry an concrete idea of what governmental services and activities they can expect from their general County tax dollars at the current rate of taxation. If their expectations supersede the availability of revenue resources; then it's best that be communicated honestly to the citizens and the Board of County Commission. If existing general revenue streams are not adequate to provide services at currently desired levels, new general revenue sources should be identified. CDBG should not be used to narrow the County's budget gap annually.

Encourage collaborative budgeting and reintroduce the CDBG process into the same budgetary process as that utilized for County departments. The current budget cycle for County departments and agencies occurs prior to discussion for CDBG allocations for nonprofits. The proposed expenditure of most CDBG dollars is therefore determined prior to the commencement of the allocation process. The concept of "zero based" budgeting, as delineated in OCED's Consolidated Planning Policy paper is not seemingly reflected and it's difficult to decipher how this is applied with the separate budgeting cycles.

County Agencies should be required to undergo the same competitive, formal County RFA process for all community/economic development dollars that nonprofits undertake. The current policy of exempting County Agencies from the formal competitive RFA process strikes many in the Coalition as unfair and inefficient. Activities in which County agencies access CDBG are often important to the vitality of low income communities, but others need to be more closely examined. Efficiency would theoretically be served by direct competition between nonprofits and County agencies.

Encourage and clearly define entitlement city funding coordination. Greater coordination with other Entitlement jurisdictions within Miami-Dade would greatly benefit the community in leveraging and "stretching" CDBG monies to their fullest potential. The coordination entails that each participating entity to clearly define their community/economic development role in relation to Miami-Dade efforts. This is of particular importance to those jurisdictions that possess extraordinary needs and are "signature communities" in the County, such as the City of Miami.

Perhaps the County could achieve the stated desire of Commissioner Morales' proposed ordinance by taking the CDBG program out from under the purview of the County Budget Office and rather transfer all programmatic and allocative oversight to OCED. Should County departments feel that they need to access CDBG dollars and their general budgets are insufficient to for them to fully meet the needs of the community, then they would be afforded the opportunity to compete directly in OCED's RFA process on a level of scrutiny and accountability that is demanded from the nonprofit community.

The following are merely suggestions or "food for thought" that the County may want to give consideration to in amending or finessing the Commissioner's proposed ordinance. We in the Coalition want to be as proactive and cooperative with the County Managers Office and the County Budget Office in coming to a mutually acceptable solution to the administration of the CDBG program in the County.

The Coalition, like you and the rest of county staff, are passionately driven by the desire to improve these distressed neighborhoods of Miami-Dade. We offer these suggestions not as criticism, but in an effort to promote a constructive dialogue we hope will make Miami-Dade's community development efforts a model for the rest of the country to emulate. We look forward to cooperating, collaborating, and communicating with local government in a spirit of cooperation and trust to resolve our differences and reinvigorate these target communities.