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Draft Policies and Procedures for the Business Assistance Facade Program

Orange City Council
June 23, 2026

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Draft Policies and Procedures for the Business Assistance Facade Program
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June 23, 2026
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Orange City Council
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Text extracted from the city's file for reading and search. Open the original on cityoforange.legistar1.com. That file is the official record.

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SLICE POLICIES AND PROCEDURES

PROGRAM BACKGROUND
The Supporting Local Investment in Commercial Exteriors (SLICE) Program is administered by the City’s Community Development Department and funded through the Community Development Block Grant (CDBG) Program in accordance with 24 CFR Part 570.

The SLICE Program supports the revitalization of commercial areas through targeted façade improvements to eligible properties located within areas that meet the Low- and Moderate-Income Area (LMA) National Objective pursuant to 24 CFR 570.208(a)(1).

The program provides financial assistance to commercial property owners and tenants operating for-profit businesses to improve the exterior appearance, functionality, and accessibility of commercial structures. These improvements are intended to enhance the overall condition of commercial areas and support revitalization efforts within surrounding low- and moderate-income neighborhoods.

The SLICE Program is aligned with priorities identified in the City’s 2025–2029 Consolidated Plan, which recognizes economic development and neighborhood revitalization as key community needs. Program activities are designed to advance these priorities while ensuring compliance with all applicable CDBG eligibility and National Objective requirements.

All activities funded under the SLICE Program must demonstrate and document a clear public benefit to residents within the defined LMA service area.

PROGRAM MISSION AND GOALS
MISSION: To revitalize commercial corridors by supporting local businesses in enhancing the appearance, accessibility, and character of their storefronts to foster economic growth, promote community pride, and contribute to the long-term vitality and prosperity of the City.

GOAL: To strengthen the resilience of businesses located in low- and moderate- income areas by providing targeted support for façade improvements that enhance curb appeal, and promote community investment.

DEFINITIONS
LMI (Low- and Moderate-Income): HUD defines an LMI person as a member of a household having an income equal to or less than 80% of the Area Median Family Income (AMI) for the county or metropolitan area, or, for non-metropolitan areas, the statewide non-metro median family income.

LMA (Low- and Moderate-Income Area Benefit): An LMA activity is a CDBG-funded project that benefits all residents in a specific, primarily residential area, where at least Draft
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51% of the residents are LMI persons.
 Service Area Requirement: The project must serve a defined geographic area, not just specific individuals.
 51% Threshold: The area must generally have a population that is at least 51% LMI, according to HUD-provided data (such as the ACS 5-Year Estimates) or a local income survey.

FUNDING LIMITS
The SLICE Program allocates a portion of the City’s annual Community Development Block Grant (CDBG) entitlement funds to support eligible local for-profit businesses through façade improvement grants of up to $50,000 per project. Grant awards are subject to the availability of funds and are intended to assist in the revitalization of commercial properties located within designated low- and moderate-income areas.

FAÇADE ELIGIBILITY
Only exterior improvements that are visible from the public right-of-way or street are eligible for funding under the SLICE Program. Eligible façades include building faces that face public streets, sidewalks, alleys, or other areas accessible to the general public. Improvements on portions of the building not visible from the public right-of-way are not eligible for funding. Interior improvements are not eligible except for limited accessibility improvements directly necessary to complete approved exterior accessibility improvements.

The SLICE program is designed to meet the CDBG Low- and Moderate-Income Area Benefit (LMA) National Objective by targeting façade improvements within eligible census tracts and block groups where at least 51% of residents are considered low and moderate income. Improvements funded through the program are limited to publicly visible exterior enhancements that contribute to the overall appearance, accessibility, safety, and economic success of commercial corridors serving LMI neighborhoods. By improving commercial façade in eligible areas, the program supports neighborhood stabilization, economic activity and growth, and enhances the quality of the public environment and overall neighborhood conditions consistent with HUD CDBG regulations.

USE OF FUNDS
The SLICE program is funded by Community Development Block Grant (CDBG) and must comply with all applicable federal and local requirements. Funds may only be used for eligible activities that support façade improvements and corridor revitalization.

ELIGIBLE IMPROVEMENTS
Façade and Exterior Improvements
The SLICE Program is intended solely for eligible exterior façade improvements and is not designed to function as a general rehabilitation or code correction program.

Eligible activities include, but are not limited to:

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 Façade rehabilitation, including historic restoration elements  Exterior painting (including murals, subject to City approval)  Siding, trim, soffit, and fascia
 Roofing (when part of a façade improvement project)
 Gutters and downspouts
 Doors and windows
Storefront & Architectural Features
 Awnings, canopies, and shade structures
 Storefront window improvements and display areas
 Exterior lighting attached to the building
 Signage integrated into the building architecture
Accessibility Improvements (ADA)
 Removal of barriers to access
 Accessible entrances and path-of-travel improvements
 ADA-compliant hardware and features
*ADA-related improvements must be limited to those that are exterior-facing or directly connected to the primary public entrance and necessary to support the approved façade improvements. Interior accessibility upgrades (e.g., restrooms or non-public areas) are not eligible unless directly necessary to complete the approved exterior accessibility improvements.

Professional Services & Construction Costs
 Architectural, engineering, and design services
 Labor, materials, and fixtures directly related to eligible improvements

INELIGIBLE ACTIVITIES
Interior Improvements
 Interior improvements are not eligible, except for limited accessibility improvements directly associated with the primary public entrance and necessary to complete approved exterior improvements.

Site Work & Non-Façade Improvements
 Parking lots, paving, or resurfacing
 Landscaping or irrigation
 Public sidewalks or work within the public right-of-way Building Expansion and Structural Changes
 New construction
 Expansion of building area
 Structural alterations not directly related to façade improvements Draft
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Property and Business Operations
 Property acquisition
 Equipment and furnishings not permanently affixed to the building Signage Restrictions
 Freestanding signage
 Signage not affixed or integrated into the building
Materials and Design Restrictions
 Painting of unpainted brick or masonry
 Fencing exceeding three (3) feet in height, unless otherwise approved General Prohibitions
 Routine maintenance that does not result in a visible exterior improvement  Work initiated prior to environmental clearance and funding agreement execution  Activities prohibited under CDBG regulations

APPLICATION & GRANT TIMELINE
The open and competitive application period for the SLICE Program will open annually on the first Monday in June and close on the last day in June. Late or incomplete applications will not be considered.

All eligible applications will undergo a formal evaluation and scoring process in July. Notification of award or denial will be issued to all applicants on the first Monday in August.

Grant agreements will be executed following award notifications. The grant contract period will commence upon full execution of the agreement and the awardee will have one year from agreement execution to complete awarded project.

The Community Development Director reserves the authority to grant special consideration and approval for applications submitted outside the designated application period, at their sole discretion, and based on demonstrated need or extenuating circumstances.

MARKETING AND OUTREACH
The City will implement a comprehensive outreach strategy to ensure broad awareness of the SLICE Program and equitable access to funding opportunities for eligible businesses in eligible areas.
 Outreach efforts may include, but are not limited to:
 Posting program information on the City’s website and social media platforms  Distribution of printed materials such as flyers and program guides  Direct outreach to businesses through in-person visits  Email notifications
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 Coordination with local partners,
 Hosting informational workshops and technical assistance sessions to support applicants
 Inclusion of program information in business license communications or other City mailings
The City will make reasonable efforts to ensure that outreach materials are accessible to a diverse community, including providing translated materials and engaging with community-based organizations to reach underserved populations. The City may also promote completed projects through before-and-after documentation, testimonials, and other communication tools to increase program visibility and encourage participation.

Outreach efforts will be conducted in a manner that affirmatively furthers fair housing and promotes equitable access to program resources.

APPLICATION EVALUATION CRITERIA
Applications will be evaluated and scored by the SLICE Selection Committee based on the following criteria:

1. Location and LMA Impact (0-30 points):
i. Strength of LMA service area justification (walkability, proximity, residential nexus within an approximately one-mile service area demonstrating that the area is primarily residential and that at least 51% of residents qualify as low- and moderate-income
ii. Weak or unclear LMA justification; limited explanation of service area: 0-3 points
iii. Meets LMA threshold; basic justification provided: 4-6 points iv. Strong LMA justification with clear explanation of service area and surrounding residential context: 7-8 points
v. Very strong justification supported by narrative, proximity to LMI neighborhoods, and clear evidence the business serves local residents: 9-10 points
b. Proximity and Accessibility to LMA Residents (0-8 points):
i. Limited proximity to residential areas; primarily auto-oriented or isolated: 0-2 points
ii. Moderate proximity; accessible but not strongly connected to neighborhood: 3-5 points
iii. Close proximity to LMA residential areas; easily accessible: 6-8 points
iv. Directly integrated into neighborhood (walkable, central location, strong residential adjacency): 8 points
c. Visibility from Public Right-of-Way (0-6 points):
i. Minimal visibility; not easily seen from street: 0-1 points ii. Moderate visibility; partially visible: 2-3 points
iii. Highly visible from public street or sidewalk: 4- 5 points iv. Prominent visibility (corner lot, high-traffic frontage, multiple street exposures): 6 points
d. Neighborhood serving nature of business (0-6 points):

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i. Business does not clearly serve local residents: 0-1 points ii. General service with some neighborhood relevance: 2-3 points iii. Provides commonly used goods/services to local residents: 4-5 points
iv. Clearly neighborhood-serving (e.g., food, retail, services used frequently by LMA residents): 6 points

2. Match Contribution (minimum 25% of total project cost): (0-25 points):
a. Minimum 25% match: 10 points (baseline)
b. 26%-35% match: 15 points
c. 36%-50% match: 20 points
d. 51% or more match: 25 points

3. Multi-Tenant/Area Impact – 0-15 points*
a. Single-tenant project: 0-5 points
b. Multi-tenant (2-3 eligible businesses): 6-10 points
c. Multi-tenant (4 or more eligible businesses): 11-15 points

4. Visual Impact (0–10 points)
a. Transformational façade improvement: 8-10 points
b. Moderate improvement: 4–7 points
c. Minimal improvement: 0–3 points

5. Business & Economic Impact (0–10 points)
a. Limited or unclear economic impact; business type does not clearly serve surrounding LMA residents: 0-2 points
b. Moderate impact; business provides general goods/services but limited neighborhood-serving role: 3-5 points
c. Strong impact; business provides essential or frequently used goods/services to the surrounding LMA area and demonstrates stability:
6-8 points
d. High impact; business is clearly neighborhood-serving (e.g., food, retail, services), demonstrates long-term stability, supports job retention and/or modest job creation, and/or is a small or locally owned business with demonstrated community reliance: 9-10 points

6. Project Readiness (0–5 points)
a. Incomplete application; missing key documents; unclear scope or budget: 0-1 points
b. Basic application complete; preliminary cost estimates provided; some details pending: 2-3 points
c. Complete application with contractor estimates, clear scope, and owner authorization; minor items pending: 4 points
d. Fully developed project; detailed cost estimates, design plans (if applicable), site readiness confirmed, no known environmental or permitting barriers: 5 points

7. ADA Compliance (0–5 points)
a. No ADA improvements included: 0 points
b. Minor improvements that enhance accessibility or address low-level issues: 1-2 points
c. Meaningful ADA improvements that increase accessibility or address Draft
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documented deficiencies: 3-4 points
d. Significant ADA improvements that substantially improve accessibility to the primary public entrance and enhance access for persons with disabilities: 5 points
Conditions to qualify for these points
Projects must meet the following conditions to be fully considered in the scoring:
 Tenants must be individually eligible and properly documented  Improvements must be visible from the public right-of-way  For multi-tenant properties, cost allocation must be clearly defined  Cost allocation methodology must be defined
 All proposed improvements must align with SLICE activities Tie Breaker Priorities
In the event that two or more applications receive the same final score and insufficient funding is available to award all projects, preference will be given based on the following factors, in the order listed below:
 Provide a higher private match contribution
 Serve a greater number of LMI tenants
 Support small businesses with five (5) or fewer employees  Locally owned and operated businesses
 Demonstrate strong neighborhood serving characteristics If a tie remains after application of the above criteria, the City reserves the right to make funding determinations based on overall program objectives, readiness to proceed, and the extent of demonstrated public benefit. Tie-breaker determinations will be documented in the project file.

ADDITIONAL CONSIDERATIONS
The City may give additional consideration to projects that:
 Benefit multiple eligible businesses within a single property  Create a concentrated and visible impact within commercial areas serving LMI neighborhoods
 Enhance the overall appearance and accessibility of multiple storefronts For multi-tenant properties, scoring preference will be based on the number of eligible tenant businesses directly benefiting from the improvements, rather than the overall size or cost of the project. Scoring for qualitative criteria will be based on the extent to which the application demonstrates clear, documented, and measurable outcomes aligned with program objectives. The City may require supporting documentation to justify scoring determinations.

TARGET AREA PRIORITIZATION
The SLICE Program is designed to support façade improvements within areas that meet Draft
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the Low- and Moderate-Income Area (LMA) National Objective, as defined by the most recent U.S. Census data.

While all eligible projects located within LMA-qualified areas may be considered for funding, the City will prioritize projects that demonstrate a high level of public benefit, including but not limited to:
 Strong visibility from the public right-of-way
 Concentration of improvements that contribute to corridor-wide revitalization  Location within areas exhibiting signs of physical deterioration or disinvestment  Projects that enhance pedestrian accessibility and neighborhood-serving commercial activity
The City may identify areas of strategic investment based on community development needs; however, all projects will be evaluated based on established program criteria.

Funding decisions will be made in a manner that is fair, transparent, and consistent with CDBG requirements, with the goal of maximizing the overall impact of available funds. All projects must document compliance with the LMA National Objective and prioritization will be based on the extent to which the proposed improvements advance program goals and community development outcomes.

TARGET AREA REQUIREMENTS
Census tract data is used to identify neighborhoods in the City where there are at least 51% or more residents that have been identified as Low- or Moderate-Income (LMI) households. These identified neighborhoods make up the “target area” of the program.

BUILDING/BUSINESS TYPE REQUIREMENTS
To qualify for the SLICE Program, applicants must own or lease a for-profit commercial property with a façade visible from the public right-of-way located within an area that meets the CDBG LMA National Objective or otherwise demonstrates eligibility under CDBG requirements. Properties must be accessible to the public and have a façade visible from the public right-of-way.

For leased properties, the applicant must provide written notarized authorization from the property owner confirming that the proposed façade improvements are permitted.

Applicant must also provide an executed lease for a minimum of one year.

For properties that are currently vacant, the applicant must secure a commercial tenant within six months of grant approval to remain eligible.

Mixed-use buildings that include both commercial and residential components may qualify; however, grant-funded improvements must be limited exclusively to the commercial portion of the property.

Improvements funded through the SLICE program must be maintained in good condition and consistent with the approved project scope for a minimum period of five years following project completion. The property owner and/or tenant shall not remove or Draft
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materially alter funded improvements during this period without prior written approval from the City.

If the property is sold, leased to a new tenant, or undergoes a change in use during compliance period, the improvements must continue to meet program requirements.

Failure to maintain the improvements or comply with program requirements may result in repayment of grant funds, in accordance with the City’s recapture provisions.

MATCH CONTRIBUTION REQUIREMENT
A minimum match contribution of 25% of total project costs is required for all SLICE- funded projects. Match contributions must be from non-federal sources and must be documented and verified prior to reimbursement.

For larger projects, the City may require an increased match contribution to ensure appropriate private investment and to mitigate potential undue benefit. All assistance will be limited to the minimum amount necessary to complete the project and achieve program objectives.

A match contribution is the applicant’s required financial investment towards the total project cost. Match funds may include private funds, loans, or other eligible non- federal sources used to complete approved façade improvements.

Match Contribution Example:

Funding Source Amount
SLICE Grant Funds (75%) $50,000.00
Applicant Match Contribution (25%) $16,667
Total Project Cost $66,667
The City may prioritize and award additional points to applications that demonstrate a higher-than-required match contribution. The City reserves the right to establish tiered match requirements based on total project cost.

MULTI-TENANT COMMERCIAL PROPERTIES SELECTION (STRIP MALLS AND

SHOPPING CENTERS)
Commercial properties containing multiple tenant spaces, such as strip malls or shopping centers are eligible for assistance under the SLICE Program, provided that all improvements meet program requirements and are limited to eligible façade and exterior elements that are visible from the public right-of-way. Common area improvements must be clearly attributable to the benefiting tenant spaces and proportionally allocated.

Improvements that primarily benefit the property owner or do not have a direct and documentable benefit to eligible tenant businesses may be deemed ineligible.

For multi-tenant properties, each tenant space benefiting from the improvements will be treated as an individual assisted business for the purposes of eligibility determination, Draft
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National Objective compliance, and reporting. The City will maintain separate documentation for each tenant to demonstrate compliance with CDBG requirements, including Low- and Moderate-Income Area (LMA) benefit.

Program funds will be allocated to each tenant based on a reasonable and documented cost allocation methodology, such as linear frontage, square footage, or proportional share of the façade improvements. The selected methodology must be clearly documented and maintained in the project file. The City will perform a cost reasonableness analysis for all projects, including review of independent cost estimates, contractor bids, or other pricing documentation, to ensure that all costs are necessary and reasonable in accordance with 2 CFR 200.404.

A property owner may apply on behalf of multiple tenants; however, all benefiting tenants must meet program eligibility requirements and may be required to provide supporting documentation as determined by the City.

The maximum total grant award for any single multi-tenant commercial property shall not exceed $150,000, regardless of the number of businesses assisted. Individual tenant awards remain subject to program funding limits. All improvements must demonstrate a clear public benefit, enhance the visual appearance of the commercial corridor, and be consistent with the program’s National Objective. The City reserves the right to determine eligibility, funding levels, and cost allocations on a case-by-case basis to ensure compliance with all applicable CDBG regulations and to prevent undue private benefit.

The City will ensure that the level of assistance provided does not result in an undue financial benefit to property owners or businesses. Assistance will be limited to the minimum amount necessary to complete the project, and all costs will be evaluated for reasonableness and necessity in accordance with CDBG requirements.

OWNERSHIP REQUIREMENTS
Both business owners and commercial property owners are eligible to apply for SLICE Program funding. In cases where the applicant is a tenant, written consent from the property owner is required as part of the application process. If the application is selected for funding, the property owner will be required to provide a notarized letter of authorization and will be included as a party to the grant agreement.

It is required that tenant applicants have a minimum of 12 months remaining on their lease at the time of application or possess a renewal option to ensure project continuity and compliance throughout the grant term.

FEDERAL REQUIREMENTS
SLICE extends assistance to eligible commercial rehabilitation projects under 24 CFR 570.202(a)(3), limited to eligible exterior façade improvements and associated accessibility improvements directly related to the approved façade project. Because the program is funded with federal CDBG funding, all projects must comply with the CDBG program’s National Objective of Low- to moderate-income benefit. The City will maintain Draft
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documentation supporting the determination that each assisted business serves the defined service area, including narrative justification and, where applicable, mapping or supporting data.

The City will define and document the service area for each assisted business using reasonable and supportable methods, such as proximity, accessibility, and customer base characteristics. The City will maintain records demonstrating that the service area is primarily residential and that at least 51% of residents are low- and moderate-income, consistent with HUD guidance. Supporting documentation may include narrative justification, mapping, census data, or other relevant documentation, as appropriate.

Projects will be evaluated on a case-by-case basis to ensure eligibility with CDBG National Objective. Once a project is approved, applicants and contractors must agree to provide supporting documentation and comply with reporting requirements for a minimum of five years.

FLOOD INSURANCE
In accordance with federal regulations, applicants whose project sites are located within a designated 100-Year Flood Zone are required to maintain active flood insurance coverage in order to be eligible to receive Community Development Block Grant (CDBG) funds. Prior to submitting an application, applicants are advised to verify the flood zone status of their project location by visiting the Federal Emergency Management Agency (FEMA) Flood Map Service Center.

If the project site is determined to be within a flood zone and the application is selected for funding, the applicant will be required to provide proof of current flood insurance coverage as a condition of grant award. Proof of current flood insurance coverage must be provided as a condition of grant award.

OTHER PROGRAM REQUIREMENTS

1. Applications will not be accepted for improvements already underway.

2. All work must follow applicable permitting and code requirements, zoning ordinances, and standard engineering practices.

3. Architectural drawings may be required and will be the grantee’s responsibility to obtain. (Costs can be included in 25% Contribution).

4. Davis-Bacon and Related Acts may apply depending on project type, funding structure, and federal requirements. The City will make the final determination regarding the applicability of federal labor standards. Where federal labor standards apply, contractors must comply before work begins, including wage decisions, payroll reporting, and required labor standard clauses.

5. Projects are required to comply with the Copeland Act, the Contract Work Hours and Safety Standards Act, and lead-based paint regulations. Lead-based paint requirements will apply where triggered by the scope, building use, age of structure, or impact to residential portion of mixed-used properties.

6. Projects will be submitted for an Environmental Review.  The City will determine the appropriate level of environmental review and maintain the Environmental Review Record prior to commitment of funds.

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 No funds will be committed and no choice-limiting actions may be undertaken prior to completion of the environmental review and receipt of environmental clearance. The City will assume responsibility for completion of the environmental review and receipt of Release of Funds in accordance with 24 CFR Part 58.
 If the building resides within a Historic District, we will be required to receive a certificate of appropriateness from the State Historic Preservation Office (SHPO). This can take up to 30 days.

7. Construction cannot begin until an executed contract is in place and the City’s bid process is complete.

8. All work and purchase of materials must go through a licensed general contractor.

9. Any property that receives CDBG funds over $25,000 for improvements would be subject to a five-year property use restriction recorded with the County and the City. The City reserves the right to recapture funds on a prorated basis if program requirements are not met. This is to ensure that the funded improvements benefit the business or a similar business at the property during that time.

DESIGN REQUIREMENTS

1. Façade improvements should make a noticeable contribution to neighborhood revitalization efforts.

2. The proposed design should be consistent with the character of the neighborhood.

3. Façade improvements should support and enhance pedestrian accessibility.

Signs, windows, doors, and lighting should be pedestrian oriented.

4. The improvements are to conform to local and national historic district guidelines, if applicable.

5. Significant architectural features should be repaired and preserved rather than replaced. If replacement is required, the design and materials should be consistent with the original historic character of the building.

APPLICATION SUBMISSION
Applications will be deemed complete upon submission of the following (incomplete applications will not be reviewed):
 Project details and supporting documents including:
o Identified areas of the building to be improved (both in photo and description, such as, area east of the main entrance, from front east corner to west end of the building, around the doors or windows, etc.)
o Existing types of surface and materials of areas to be refinished, altered, painted, etc., such as window or door frame material types. o Proposed type of new surface, materials, etc.
o Signage must be attached to the building and have a reasonable description including size to determine if signage is considered a mural, non-religious, non- political, and allowed according to the zoning ordinance. o Confirmation that lighting is either attached to the building’s exterior, or an interior front window display
 Photographs of the building’s current condition, including:
o Every side which is visible from the street that you are proposing to make Draft
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improvements on.
o Specific areas where improvements will be made.
 Estimated budget:
o Cite a source from a professional who has expertise in construction cost estimates. These are price quotes (not bids). Applicants cannot obligate funds to any professional, contractor, architect, etc. until they have an executed contract and have followed the City’s bid process.
 If the applicant is a tenant, a letter of support from the property owner must be included.
 All documentation or clarifications requested by City staff.  All applications must be submitted through the City’s portal by the deadline. City staff will provide technical assistance if needed.

APPLICATION REVIEW
All submitted applications will undergo an initial eligibility screening conducted by the Housing Manager to ensure compliance with program requirements. Applications deemed eligible will be forwarded to the SLICE Selection Committee for further evaluation and scoring.

The Scoring Committee (Committee) will consist of three members from various divisions including Economic Development, Planning, Building, and Code Enforcement. The Committee will review applications for completeness and consistency with program requirement guidelines and may request additional information or clarification as needed.

Final funding decisions will be made by the Community Development Director based on Committee recommendations. Approvals must be documented and justified consistent with program objectives and CDBG requirements.

BID AND PRE-CONSTRUCTION
The applicant will work with the City to ensure that all procurement and labor requirements are met in compliance with federal regulations. Procurement will be conducted in accordance with federal procurement standards (2 CFR 200) and the City’s procurement policies. The method of procurement used will depend on the nature and size of the project and may include sealed bids, competitive proposals, or other approved methods.

Invitations for bids, proposals, or solicitations will be publicly advertised through the City’s Public Procurement website. Attendance at pre-bid meetings is required for General Contractors to be eligible to submit a response. Contractors will have a defined period to submit their bids or proposals, which will be publicly opened and reviewed by City staff.

Contractors cannot be promised work prior to completion of the procurement process.

Contractor selection will be based on the applicable procurement method and will consider responsiveness, responsibility, and compliance with project requirements. The City reserves the right to reject any or all bids or proposals if there is a sound, documented reason.

All program activities will comply with CDBG conflict of interest requirements under 24 CFR 570.611. The City will make the final determination regarding the applicability of federal labor standards, including Davis-Bacon requirements, for each project.

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Procurement documentation, including solicitation materials, bids/proposals received, cost reasonableness review, contractor eligibility, and award justification, will be maintained in the project file.

GRANT AGREEMENT
After a General Contractor is awarded the bid, the applicant will be required to enter and execute a three-party grant agreement with the City and awarded General Contractor to establish terms, conditions, and requirements for program participation. The property owner may also be required to acknowledge and agree to the terms of the compliance period as part of the Grant Agreement. Any work initiated or completed prior to the execution of the Grant Agreement will not be eligible for reimbursement. Funding must be spent by the end of the contract period; contract extensions will only be awarded on a case-by-case basis.

All projects funded through the SLICE program must be maintained in good condition and consistent with the approved project scope for a minimum period of five years following project completion. The property must remain in active commercial use during this period and continue to meet applicable CDBG National Objective requirements. Significant alteration, without prior written approval from the City may be considered noncompliance.

As part of the Agreement, the awardee may elect to be contacted by the Chamber of Commerce regarding ribbon-cutting opportunities and other services it offers. Choosing to be contacted is entirely optional and does not affect eligibility for the award or confer any preferential consideration.

CONSTRUCTION
Construction work shall commence once all approvals and permits have been received.

All work must be completed within the contract period.

GRANT DISBURSEMENT
The City will pay General Contractors directly through progress payments as work and required documents are submitted and approved by the grantee. Payment requests must be submitted through the City’s portal. Payments can take up to thirty days to process.

FINANCIAL MANAGEMENT
All SLICE Program funds will be administered in accordance with applicable federal financial management standards.
 Funds will be disbursed on a reimbursement basis only. No advance payments will be made.
 Payment requests must be supported by itemized invoices, proof of payment, and verification of completed work.
 The City reserves the right to withhold payment until all required documentation is submitted and approved.
 The City will pay contractors directly, as outlined in the grant agreement, based on approved progress payments.
 All costs must be necessary, reasonable, and directly related to eligible program Draft
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activities.
 The City will maintain adequate internal controls to ensure compliance with 2 CFR 200, including separation of duties, review and approval of payment requests, and verification of costs prior to disbursement.

REPORTING
After the construction is completed, the applicant may be required to submit a post- program report. Applicants may also be asked to give a testimonial of the project. City employees will go on-site to take before, during, and after photos to document the project.

RECORD KEEPING
The City will maintain complete and accurate records for each project funded under the SLICE Program in accordance with Community Development Block Grant (CDBG) requirements. Records will be retained for a minimum period consistent with federal record retention requirements and will include, but are not limited to:

Documentation of applicant eligibility:
 National Objective compliance with Low- and Moderate-Income Area Benefit.

The City will maintain documentation in each project file demonstrating how the service area was determined and how the Low- and Moderate-Income (LMI) benefit was calculated.
 Environmental review and clearance documentation
 Procurement and contracting records
 Project budgets, invoices, and proof of payment
 Before, during, and after photographs of the project
 Inspection reports and project completion documentation  Grant agreements and any amendments
 Documentation of compliance with applicable federal requirements All records shall be made available for review upon request by authorized representatives of the City or HUD.

DUPLICATION OF BENEFITS
SLICE Program funds may not be used to pay for costs that have been or will be reimbursed by another source. Applicants are required to disclose all sources of funding related to the proposed project, including but not limited to:
 Insurance proceeds
 Other federal, state, or local grants
 Private funding or incentives
The City will review all funding sources to ensure that CDBG funds do not duplicate other financial assistance. If a duplication of benefits is identified, the City will reduce the SLICE award accordingly or require repayment of duplicated funds. Applicants may not receive reimbursement for costs funded through another federal assistance source for the same eligible activity.

MONITORING AND COMPLIANCE
The City will monitor all SLICE-funded projects to ensure compliance with program requirements, 24 CFR Part 570 and all other applicable federal regulations.

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Page | 16 SLICE PROGRAM GUIDELINES
Monitoring activities will ensure that each project:
 Meets and maintains compliance with applicable CDBG National Objective, including LMA requirements, where applicable
 Comply with the approved project scope and grant agreement  Comply with all applicable federal requirements, including but not limited to procurement, ERR, and labor standards (as applicable)
Monitoring may include but is not limited to:
 Pre-construction review to confirm required approvals, and procurement compliance
 Site visits during and after construction to verify progress and completion of work.  Recipients are required to cooperate with all monitoring activities and provide requested documentation in a timely manner.
 The City may conduct follow-up monitoring during the affordability/use restriction period to ensure continued compliance with program requirements.

The City may require corrective actions to address any findings identified during monitoring.

The City may conduct desk reviews and on-site monitoring in accordance with its risk- based monitoring procedures. If monitoring identifies noncompliance with program requirements or federal regulations, the City may require corrective actions. The City reserves the right to enforce all provisions of the grant agreement and applicable federal regulations to ensure proper use of CDBG funds.

RECAPTURE OF FUNDS
The City reserves the right to recapture all or a portion of the awarded funds on a prorated basis if the recipient fails to comply with program requirements, including but not limited to failure to complete the project, maintain required use, or comply with applicable federal regulations. Recapture provisions will be enforced in accordance with the terms outlined in the grant agreement and any recorded use restrictions.

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