Proposed EDA Regulations December 2011

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• I agree

  46 votes

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  EDA investments should be consistent with EDA-approved CEDS

  We are concerned that the proposed rules eliminate the specific reference that EDA “projects be part of an overarching long-term Comprehensive Economic Development Strategy…” and “demonstrates a high degree of local commitment.” While EDA states that the PWEDA Act (EDA’s primary authorization legislation) already mandates that all EDA implementation investments under public works and economic adjustment assistance must ...more »

  We are concerned that the proposed rules eliminate the specific reference that EDA “projects be part of an overarching long-term Comprehensive Economic Development Strategy…” and “demonstrates a high degree of local commitment.” While EDA states that the PWEDA Act (EDA’s primary authorization legislation) already mandates that all EDA implementation investments under public works and economic adjustment assistance must be consistent with an EDA-approved CEDS, it is important that EDA restate this requirement in its regulations, especially for areas covered by an EDD CEDS. Since EDA allocates considerable resources each year for EDD-coordinated CEDS, the agency should place a greater emphasis on implementing the priorities outlined in EDD CEDS.

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  6 comments

  Submitted by Community Member 3 months ago

• I agree

  34 votes

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  Policy Board Requirements

  We are opposed to the proposed regulations eliminating the current requirement that policy boards of Economic Development Districts be governed by at least a simple majority of local elected officials or their designated appointees. While we are very supportive of the overall intent of the proposed change to provide EDDs with greater flexibility, especially with respect to private sector and community representation, ...more »

  We are opposed to the proposed regulations eliminating the current requirement that policy boards of Economic Development Districts be governed by at least a simple majority of local elected officials or their designated appointees. While we are very supportive of the overall intent of the proposed change to provide EDDs with greater flexibility, especially with respect to private sector and community representation, it is important that local government officials remain a key part of the EDD governance structure. Local governments provide the local matching funds for EDDs (including the CEDS process), are typically required by the private sector to make considerable investments in public infrastructure and facilities to support private industry, and are accountable to the general public.

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  1 comment

  Submitted by Community Member 3 months ago

• I agree

  30 votes

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  Alignment of Statewide CEDS

  We agree with alignment of statewide CEDS for the purpose of information sharing and collaboration. Whether or not the mutual plans "are consistent" does not serve well the regional efforts and strategies. We do not recommend a requirement to mandate "consistency" or alignment.

  1 comment

  Submitted by Community Member 3 months ago

• I agree

  27 votes

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  EDA CEDS should be coordinated and leveraged...

  Under the new CEDS requirements, language under the third element should be clarified that EDA CEDS should be coordinated and leveraged with state and local economic development and/or workforce development strategies. The proposed language that CEDS “should not be inconsistent with” these other strategies may be misleading or imply that CEDS are developed after these other plans. In many cases, EDA-funded CEDS are ...more »

  Under the new CEDS requirements, language under the third element should be clarified that EDA CEDS should be coordinated and leveraged with state and local economic development and/or workforce development strategies. The proposed language that CEDS “should not be inconsistent with” these other strategies may be misleading or imply that CEDS are developed after these other plans. In many cases, EDA-funded CEDS are a region’s primary strategy, often used to inform the development of other state, regional and local economic development and workforce plans.

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  3 comments

  Submitted by Community Member 3 months ago

• I agree

  25 votes

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  EDD Governing Board

  We encourge EDA to reconsider changes to the policy boards overall composition. At the very least we should maintain a majority of the membership to be elected officials or appointed. The EDD connection to local government is crucial in our region.

  1 comment

  Submitted by dlawrence 3 months ago

• I agree

  24 votes

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  Flexibility

  Thank you for the flexability at the local level that allows Economic Development Districts to be different and that allow us to assign strategies that make sense for our areas.

  3 comments

  Submitted by Community Member 3 months ago

• I agree

  23 votes

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  Do not eliminate requirement that projects be part of CEDS

  EDA SHOULD NOT eliminate, as part of the application evaluation criteria, the need for a project to be part of “an overarching, long-term Comprehensive Economic Development Strategy that enhances a Region’s success in achieving a rising standard of living…” AND that a project must demonstrate "a high degree of local commitment.”

  1 comment

  Submitted by Community Member 3 months ago

• I agree

  21 votes

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  80/20 Split

  I am glad to see EDA reconsidering the 80% federal, 20% local match option. Now that EDA grants for essentially requires applicants to spend money on engineering and environmental work ahead of time, it would be nice if applicants could get more than half of the project covered by EDA. The 80/20 split would incentivize applicants to put the necessary effort into an EDA construction application.

  1 comment

  Submitted by mhunt 4 months ago

• I agree

  16 votes

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  Certification of managment of RLF funds

  EDA is proposing to require that the certification of the management of RLF funds be made by “a qualified independent accountant who preferably has audited the RLF Recipient in accordance with OMB Circular A-133 requirements.” While the provision seems to have sound intentions, we are concerned that an independent auditor will not be willing to certify the management of the RLF due to liability issues.

  2 comments

  Submitted by Community Member 3 months ago

• I agree

  15 votes

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  Using ACS data to determine income

  The use of American Community Survey (ACS) data to determine per capita income will be difficult since rural areas often will only have 5 year estimates available for a specific geography. The problem this presents is if there was a significant economic change such as a plant closure that led to a significant decrease in per capita income it would take several years for this change to be captured by the ACS 5 year estimate. ...more »

  The use of American Community Survey (ACS) data to determine per capita income will be difficult since rural areas often will only have 5 year estimates available for a specific geography.

  The problem this presents is if there was a significant economic change such as a plant closure that led to a significant decrease in per capita income it would take several years for this change to be captured by the ACS 5 year estimate.

  My suggestion is to utilize local state data for determining the per capita income for rural areas as opposed to 5 year ACS data.

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  Submitted by jonathan 4 months ago

• I agree

  14 votes

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  Coordinate CEDS with Local Economic Development Strategie

  303.7 Requirements for Comprehensive Economic Development Strategies.

  Language under the third CEDS requirement should be clarified to restate that CEDS strategies and implementation plans should be coordinated and developed in cooperation with state and local economic development and/or workforce development strategies.

  2 comments

  Submitted by gvaday 3 months ago

• I agree

  12 votes

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  Local elected officials are important to EDD boards

  I am concerned with the proposal to eliminate the requirement that EDD policy boards have a majority of elected officials. While I applaud the effort to provide flexibility, this is one area that I believe should be sacrosanct. Without that direct tie to the voters I fear that you lose the legitimacy of the organization to speak for all the people of the region, not just a subset like a Chamber of Commerce that represents ...more »

  I am concerned with the proposal to eliminate the requirement that EDD policy boards have a majority of elected officials. While I applaud the effort to provide flexibility, this is one area that I believe should be sacrosanct. Without that direct tie to the voters I fear that you lose the legitimacy of the organization to speak for all the people of the region, not just a subset like a Chamber of Commerce that represents business.

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  1 comment

  Submitted by fred.rader 3 months ago

• I agree

  11 votes

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  Planning Partnership regulations

  I am very happy to see less restrictive requirements on EDD's board composition and CEDS Strategy Committee composition. I am surprised to see so many specifics cut out of the CEDS content requirements. I think our EDD is stronger because it went through all the analysis.

  3 comments

  Submitted by Susan Chavarria 5 months ago

• I agree

  11 votes

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  CEDS Project List

  We disagree with eliminating the project list from the CEDS. Listing projects is an important and unique outcome of the CEDS process. To be eligible for EDA funding a project should be included in the CEDS. This ensures the project is critical to the region.

  1 comment

  Submitted by dlawrence 3 months ago

• I agree

  11 votes

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  CEDS Strategy Committee

  We fully agree with removing the requirement requiring private sector majority control of the CEDS Strategy Committee. This Committee needs flexibilty to change and deal with local needs. A committee is critical, but leave it to the EDD to determine the makeup.

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  Submitted by dlawrence 3 months ago

• I agree

  11 votes

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  Removal of RLF Federal Identify

  I favor the removal of the federal identity of Revolving Loan Funds after the funds are revolved a maximum of 3 times.

  2 comments

  Submitted by Thomas Solomon 3 months ago

• I agree

  9 votes

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  CEDS Advisory Committee

  We agree with, and support the additional flexibility on CEDS Advisory Committee membership. While private sector involvement is most definitely needed, the required percentage accomplished little. We prefer that majority membership be of local elected officials, and let each board determine the private sector composition.

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  Submitted by Bonnie 3 months ago

• I agree

  7 votes

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  RLF Flexibility

  Entrepreneurs and businesses are facing a serious credit crunch, especially in rural and distressed areas where we've lost many local and independent banks. How is EDA using its Revolving Loan Fund or RLF program to help alleviate the credit crunch for local businesses and entrepreneurs? Why has the agency scaled back its investments in this program? What would be the downside of transferring full control and ownership ...more »

  Entrepreneurs and businesses are facing a serious credit crunch, especially in rural and distressed areas where we've lost many local and independent banks. How is EDA using its Revolving Loan Fund or RLF program to help alleviate the credit crunch for local businesses and entrepreneurs? Why has the agency scaled back its investments in this program?

  What would be the downside of transferring full control and ownership of the RLFs to the local intermediaries after the initial amount has been lent out and fully recovered by the RLF? Isn't the EDA portion of the RLF a grant, rather than a loan to an intermediary? The RLF Administrator would like to see regulations that indicate after the funds have revolved for so long, that they lose their federal identification this would offer the RLF program additional flexibility.

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  Submitted by Community Member 3 months ago

• I agree

  6 votes

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  CEDS Comment Period

  The need for a 30 day public comment period is common for many planning efforts. This would not create a problem for our process, but we would not anticipate any additional input as a result.

  1 comment

  Submitted by dlawrence 3 months ago

• I agree

  5 votes

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  EDD Organization and Governance Regulations

  The Roanoke Valley-Alleghany Regional Commission (RVARC) agrees with the proposed changes to Chapter III, Part 304, Section 304.2c of EDA’s proposed regulations changes. The current Economic Development District (EDD) organization and governance regulations require that 35% of the District Organization governing body be comprised of private sector representatives, Executive Directors of Chamber of Commerce, representatives ...more »

  The Roanoke Valley-Alleghany Regional Commission (RVARC) agrees with the proposed changes to Chapter III, Part 304, Section 304.2c of EDA’s proposed regulations changes. The current Economic Development District (EDD) organization and governance regulations require that 35% of the District Organization governing body be comprised of private sector representatives, Executive Directors of Chamber of Commerce, representatives of institutions of post-secondary education, workforce development groups, and/or labor groups. Existing Commonwealth of Virginia requirements regarding the composition of District Organizations makes it difficult to accommodate the required percentages under the current EDA regulations.

  The RVARC believes it is very important to have a diverse governing body, one comprised of private sector representatives, Executive Directors of Chamber of Commerce, representatives of institutions of post-secondary education, workforce development groups, and labor groups. However, the 35% District Organization requirement referenced above has presented problems to our organization as we have pursued EDD designation. EDA’s proposed modifications to Section 304.2c will simplify the EDD application requirements while still ensuring that each District Organization has a broadly representative board.

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  1 comment

  Submitted by sburton 5 months ago

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  5 votes

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  Funded projects need to be a part of the CEDS

  Section 305.3: The regulation omits the reference that calls for project to be part of an “overarching long-term Comprehensive Economic Development Strategy” and “demonstrate a high degree of local commitment.” Allowing projects that are not part of the CEDS, or are part of other, less structured strategies, may result in projects that do not meet the mission of EDA or the local governments.

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  Submitted by Bonnie 3 months ago

• I agree

  5 votes

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  Quarterly Funding Cycle

  The removal of rolling grant submissions is detrimental to our local communities. When recruiting new industries, the local governments need to request infrastructure funding as soon as possible. If the need arises early in the quarter, a prospect may be lost before the grant is even submitted. It appears that this process favors large, glamorous projects and ignores the smaller rural projects.

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  Submitted by Stephanie Quattlebaum 3 months ago

• I agree

  4 votes

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  Define end of revolving phase

  The definition of revolving phase is important because the utilization rate applies during the revolving phase. Currently, revolving phase is currently defined only by its beginning. The end of the revolving phase should be defined as well - for example - after the funds are loaned out 1X or 2X. At the end of the revolving phase, the applicant should have the option to wind down or terminate the load fund or apply to ...more »

  The definition of revolving phase is important because the utilization rate applies during the revolving phase. Currently, revolving phase is currently defined only by its beginning. The end of the revolving phase should be defined as well - for example - after the funds are loaned out 1X or 2X. At the end of the revolving phase, the applicant should have the option to wind down or terminate the load fund or apply to the EDA to apply the funds for another economic development purpose.

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  1 comment

  Submitted by Community Member 4 months ago

• I agree

  4 votes

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  Improve Post Award Processing

  I am happy with the new grant processing format and timeline. I would like EDA to continue to build efficiencies into its post award processing, which has been very slow in our region. Several years after an award, we are still waiting to drawdown EDA funds. This is a disincentive for potential applicants that observe the delay and thus perceive EDA and being too slow for economic development projects.

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  Submitted by mhunt 4 months ago

• I agree

  4 votes

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  Structures and Process

  EDA works because of the structures and processes that are currently in place. The need to continue reginal CEDS requirement continues the regional efforts that strengthen EDA's overall goals.

  1 comment

  Submitted by Community Member 3 months ago

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