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The Honorable Joseph E. Flescher December 20, 2013 Page 4 of 5 Neighborhood Revitalization/National Objective During the application review period, the Department determined that each service area met the national objective of benefiting primarily low-and moderate-income (LMI)persons. Construction plans were previously reviewed for consistency with the application. During monitoring,any addendums issued after the construction plans were approved and any change order(s) executed after contract award were reviewed for eligibility. The grant manager drove through each service area to observe the work that had been done. The primary activity was sewer line installation and hook up. Based on document review and the service area visit, it appears that the funded activities remained consistent with the application and that at least 51 percent of the persons served by the activities were low-or moderate-income. The project includes new sewer hookups funded by the subgrant. The grant manager reviewed hookup files to ensure that the homes connected were LMI households.Additionally, since sewer hookups were funded,he reviewed compliance with the hookup notice requirements in Section 381.00655(1), Florida Statutes. Finding: It appears the County has charged impact fees, connection fees and closing costs to LMI households. The letters of December 27,2012, from the County to the residents of the service area describe the costs to the homeowners for the sewer hookups. One letter states that the SHIP program will pay the costs for those who apply and qualify. Not all LMIs, however,qualify for SHIP,so it is not clear whether LMIs were charged connection and impact fees for the CDBG work. Required Action: The County is required to either refund the fees or return all subgrant funds. If the County decides to refund the fees,the following documentation must be submitted to the Department to resolve the finding. Identify all LMI households within the service area and their status as to whether they were charged connection fees,impact fees or both. Identify those households that received SHIP funding and what the funding paid. Identify the amounts of fees already paid by any LMI households and the amount of refund due. Provide documentation that the refunds were paid to the LME households. Submit copies of letters sent to the LMI households stating that they are not responsible for the fees for being hooked up now nor will they be charged in the future for this work. Provide documentation of the receipt of those letters by the LMI households. Procurement CDBG-funded activities must comply with applicable federal procurement regulations and state laws. The principal federal procurement regulation is contained in 24 CFR 85.36. Procurement of some professional services is also subject to Section 287.055,Florida Statutes, (also known as the Consultants Competitive Negotiation Act or CCNA). Construction procurement must comply with Section 255.0525, Florida Statutes. There were no findings or concerns related to Procurement. 161