The intent of the program is to carry out the purposes of HB22-1304, which seeks to enable local governments to invest in infill development projects that support affordable housing. For the purpose of this program, “infill” refers to projects that are within or adjacent to a downtown area, a core business district, job center, transit-oriented development.
No. DOLA has not set a hard cap on the maximum (or minimum) award amount for this program in order to allow for flexibility. The suggested maximum award amount is $4 million; however, DOLA expects most awards to fall within the $1,000,000 to $3,000,000 range. The award amount should be proportional to the impact on local housing needs, community benefits added, and/or inequities addressed. Competitive strategy can be discussed in the required pre-application meeting with DOLA.
No. Other groups, such as housing authorities or councils of government, cannot apply for program funds. However, a municipality or county can partner with other organizations and funds can be shared with partner agencies to cover eligible costs.
A Letter of Intent (LOI) will be due in August of 2023. LOIs will be submitted via a simple Google form (to be created) that will be similar to the one listed on the Strong Communities webpage. After receipt, DOLA will work with each submitting community to set up a pre-application meeting (required). Potential applicants will meet with DOLA Division of Local Government (DLG) and Division of Housing (DOH) staff to first ensure the municipality or county qualifies for the Infrastructure Grants and, second, to discuss project details, such as local match, project readiness, how the project meets the scoring criteria, and how to leverage other potential funding sources. Once DOLA has met with all communities that submitted an LOI by the cut-off date, notices will be sent to potential applicants as to whether they are invited to apply for funds.
While it is not a requirement to have adopted one or more of the strategies on the list of land use best practices, the most competitive communities will have adopted one or more of these. Some strategies simply aren’t appropriate for—or wouldn’t be effective—in every community. The most effective strategies have broad community support, respond to housing need and equity assessment data, will consistently be enforced or implemented (and not on a temporary or one-off basis), won’t ultimately shift costs in other ways to the individual (e.g., via increased transportation costs), and will impact long term affordability for the community.
Yes. Having strategies from the list of best practices is not a requirement for receiving an infrastructure grant. However, communities that have not adopted any of these strategies will not be as competitive as communities that have adopted one or more of them. A local government may
apply by proposing novel, innovative strategies not currently on the menu of best practices. DOLA will determine whether the strategy will be considered. In this case, and in the case of any innovative strategies, DOLA recommends meeting with DOLA staff as soon as possible to give the local government its best chance at competing for the funds.
A minimum of 20% local cash match of the total project cost is required. An applicant experiencing financial hardship may request a reduced level of matching funds and must consult with their DOLA Regional Manager before submitting their application with a reduced match. Local match is defined with flexibility and can include leveraged funds or financial commitment from partners (e.g., COGs, housing authorities). Land purchased or donated after August 1, 2022 also counts toward the requirement. In-kind match (e.g., staff time) does not count toward the 20% requirement but does demonstrate capacity and support for the project, which is a selection criterion. More matching funds does not necessarily make the project more competitive, especially in the case of smaller communities that may be challenged to raise additional matching funds.
Communities may reduce their match to 15% by including additional elements into their project scope, such as age-friendly and accessible design, including onsite early childhood education centers, equity standards, etc. (See list in Program Guidelines.)ds.
Yes, as long as the project’s federal funding sources allow federal-fund matching. You can match these funds with other state funds as well.
Note: Recipients should check U.S. Treasury guidance on the Colorado State Controller website and consult their own legal counsel. Guidance to date seems to show that ARPA funds may leverage other federal funds but not all federal funds will allow leveraging ARP funds. Please contact DOLA staff with any questions about matching funds.
As part of the 20% match requirement, some portion must come from local funds. State and other grant funds can count toward a portion of that match with a few exceptions. Grant funding from the Department of Housing’s Transformational Affordable Housing Grant (TAHG) program is not eligible as a matching fund source for the Strong Communities program. Funding received from other Division of Local Government (DLG) grant programs is also not eligible (such as 1271 incentive or planning grants).
It depends. Funds, available under the “revenue loss” eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. However, note that SLFRF funds may not be used as the non-federal share for purposes of a state’s Medicaid and CHIP programs.
Funds beyond those that are available under the revenue loss eligible use category may not be used to meet the non-federal match or cost-share requirements of other federal programs, other than as specifically provided for by statute.
Yes. The dollar value of fee waivers provided by the local government to the project counts toward the local match requirement. However, due to HB22-1304’s focus on permanent solutions and fiscally sustainable development patterns, more competitive projects will utilize adopted policies that support fee waivers for affordable housing projects (and that have a sustainable revenue source to replace those waivers) rather than one-time fee waivers or exceptions.
Yes. Up to 15% of the total award may be spent on administrative costs. Allowable costs include those related to project management by the applicant or the public/nonprofit agency partner but cannot include administrative costs of private, for-profit developers.
No. Predevelopment costs such as site development, planning activities, etc. are not eligible in the Strong Communities program.
Yes, as long as match funds are also spent by the deadline. A Certificate of Occupancy (CO) does not need to be issued for the project by this deadline.
Yes. Communities can apply for funds to support multiple projects at once (in one application) but will have to demonstrate that the projects will be able to complete work on time and that the award amount is proportionate to the impact of the project(s) on local housing need and community benefit.
Yes. Communities can submit projects that are located on more than one site, sometimes referred to as scattered site development.
Collaborative multi-jurisdictional affordable housing projects are encouraged where appropriate. An eligible local government may apply for a project outside of its jurisdiction but within a collaborative partnership with the appropriate neighboring jurisdiction(s).
“Rural flexibility” can be applied to communities in rural and rural resort counties that have geographic constraints (e.g., mountain towns that are limited due to terrain); projects that are in a previously identified growth area; or projects that include early childhood education centers.
The statutory language focuses on planning strategies (for the Planning Grant Program) and housing projects that have permanent or long-lasting affordability terms. The most competitive applications will be ones where communities have adopted one or more qualifying strategies and have continued efforts to promote affordable housing development. However, if tools aren’t tested or haven’t been successful, the expectation is that a community would refine existing tools or try something new. An early pre-application meeting with DOLA staff is strongly encouraged to review eligibility and competitiveness for these funds.
A Use Covenant, Regulatory Agreement, or other deed restriction must be recorded to ensure long-term affordability of projects and units assisted with Strong Communities Grant Program funds. Typically affordability is protected for thirty years, but more competitive projects will extend the period of protection.
In the most competitive projects, the applicant will show they have developed (or implemented) an inclusive and equitable stakeholder engagement strategy and robustly considered and addressed the potential impacts on marginalized and vulnerable populations. More thorough EDI guidance is available on the EDI webpage.
No. This program is dedicated to supporting local governments around the state that have affordable housing challenges and are willing to take local government land use actions to make affordable housing development easier. In fact, statutory language requires flexibility for rural communities. Projects will be considered competitive by reviewing whether they are proportionate to the local affordable housing need. For example, a small town project where the city, county, and school district partner to provide a 4-plex for teachers and health professionals will be considered just as impactful in that community as a project with a larger number of units in a big city.
We continue to review federal guidance. However, we can confirm that NEPA review and Davis Bacon wage rates will not apply, so long as any leveraged funding does not carry that requirement. However, please be aware that projects may trigger a federal single audit.
No. The Strong Communities program uses only federal funds. However, if state funds are being used as a match or to fund other portions of the project, the High Performance Certification requirements may be triggered.
This funding program allows for some off-site expenditures. This means that a portion of the funds can be spent in the neighborhood in which the project is located. Refer to the program guidelines for examples of potentially qualifying off-site improvements.
The bill language describes affordability as a function of household income. Therefore, income qualification steps will be required. However, the bill language does allow for mixed-income projects, so restrictions will not be required on any units considered “market rate.”
Yes, a project can include a mix of affordable housing units and market-rate units. However, the amount of the project that can be covered by the Strong Communities Infrastructure Grant is proportional to the number of affordable units. For example, if a project has 100 units and 25 are affordable, the grant would cover 25% of the project’s total infrastructure costs.
The statute requires units up to 140% of the area median income (AMI) for ownership and rental units in most areas, and up to 160% AMI for ownership units in rural resort communities. However, with pre-approval from DOLA, it is possible to provide a range of units that, when averaged, meet the income requirements (e.g., a mixture of 80% AMI and 200% AMI to meet the 140% average target for rental units). The local approach to protect this averaged range over time will be an important topic of discussion during the pre-application meeting.
Limited appreciation projects refer to local governments, housing authorities, or owners restricting the amount of appreciation associated with affordable for-sale homes so that the homes remain affordable after they are sold. "Appreciation cap" is another common term used to describe this.