These priorities seem old, tired and recycled to me, and they don’t seem to be working so well for us. Hearing on Thursday, but, as always actual public appearances are limited to 3 minutes and it seems, frowned upon. I’d suggest written comments which is what I will likely do. Please give your written input too!

PUBLIC HEARING ON 2015 – 2016 Goals and Objectives
5:00 p.m. March 20, 2014
Water Utility Building
119 E Olin Ave., Madison WI 53713

The CDBG Committee welcomes verbal or written statements from Madison residents or groups concerning emerging community needs and opportunities, and suggested funding priorities and terms for 2015-2016. These specific goals, objectives and terms of funding being developed will be within the overall context of the Five Year Community Development Consolidated Plan.

The Committee particularly invites comments that address these concerns:
1. As the City revises its 2015-2016 Program Funding Goals and Objectives, where should the CDBG Committee place its priorities for new funding? Which population groups? Which geographical areas? Which priorities and strategies? What types of activities?
2. How can the CDBG Committee and the Community Development Division best improve their effectiveness in working with community groups to achieve the adopted goals proposed in the 2015-2016 Goals and Objectives Statement? Are there specific opportunities or concerns emerging in the next several years that you feel the City should be addressing through its community and neighborhood development program?

Time at a public hearing is usually short, and the Committee requests that you keep within a three minute presentation limit. If you have multiple presenters representing the same agency, please try to limit presenters to three people per agency, with each having 3 minutes to speak.

If you find the time is too brief, or are unable to attend the public hearing, please submit your comments by one of the following methods by noon, on March 19, 2014:
• Send written comments to the Community Development Division at P.O. Box 2627, Madison, Wisconsin 53701-2627;
• Fax the office at (608) 261-9661;
• Send the Committee an e-mail at cdbg@cityofmadison.com , or through the website at www.cityofmadison.com/cdbg ; or
• Phone in your comments to (608) 266-6520.

Your comments will be incorporated into the Committee’s discussions of the 2015-2016 priorities on March 20 and at their regular monthly meeting on April 3 . A copy of the draft 2015-2016 Program Funding Goals and Objectives is available on the City’s website at http://www.cityofmadison.com/cdbg/whatsnew.htm

Provide decent, safe, sanitary and affordable housing opportunities for low- and moderate-income households in order to enhance household, neighborhood and community stability.

Preserve, improve and expand the supply of affordable housing for homeowners and renters.
Priorities and Strategies
1. Target assistance geographically to:
a. Maximize access to jobs, transit, and other key amenities,
b. Implement neighborhood revitalization plans, and/or
c. Stabilize or improve areas of priority to the City, including NRTs.
d. Promote dispersion of assisted housing units.
2. Increase the supply of rental units, especially:
a. For larger families needing affordable 3+ bedroom units,
b. For individuals needing affordable single room occupancy (SRO) or efficiency units,
c. With supportive services for special populations.
3. Expand homeownership opportunities.
4. Maintain affordability of housing stock through energy efficiency and/or accessibility improvements.
5. Improve safety through lead paint and asbestos mitigation.
6. Assist low- and moderate-income homeowners to continue to live in housing.

Owner-Occupied Housing Rehab Conditions
1. Subsidies provided to homeowners through a minor home repair program shall not exceed $3,600 in any 10-year period.
2. Loan assistance to homeowners for substantial rehab projects shall not exceed $19,000. In addition to this amount, projects may also receive up to $8,000 for energy efficiency improvements and up to $12,000 for lead paint reduction or asbestos mitigation to reflect the additional rehab expenses for these activities. Any one project may not receive more than $32,000.
3. Funds may not be used to repair or rehab a home in which the owner has previously received assistance through CDD-funded ownership assistance programs (excluding the Green Madison / REEIP programs). CDD staff may allow for individual exceptions to this one-time use restriction in circumstances where the repair is for accessibility improvements or for unforeseen repair needs, if deferral would result in further damage to the property and/or noncompliance with City housing codes, or would cause undue hardship. In instances where rehab or repair funds are provided to previously assisted homeowners, the total amount of the combined assistance shall not exceed $54,000 (up to $60,000 for cases involving lead paint, asbestos mitigation and energy efficiency).
4. The CDD shall secure amounts of assistance greater than $3,600 with a mortgage and a promissory note. Subsides of $3,600 or less provided to existing homeowners are considered a grant and do not require a mortgage or promissory note.
5. All projects must comply with the relevant funding source requirements. The CDD will require that HOME-funded projects comply with the regulations in 24 CFR part 92, HOME Investment Partnerships Program, as amended, and that CDBG-funded projects comply with the regulations in 24 CFR 570 Community Development Block Grant, as amended. These federal regulations include, but are not limited to, the following:
a. Funds may be used only for housing units which do not exceed the HOME assessment limit designated by the Federal Department of Housing and Urban Development (HUD).

Owner-Occupied Housing Development Conditions
1. The CDD will evaluate each proposal based on the project’s contribution to increase the affordable housing stock, project’s financial need, leverage of other resources, developer capacity, project readiness, type of project (acquisition, rehab or new construction), and availability of resources to determine the appropriate level of funding up to a maximum investment of $54,000 per unit.
2. Projects that incorporate accessibility or energy efficiency into the design or involve lead paint reduction or asbestos mitigation shall be considered for an amount greater than $54,000 per unit based on increased costs to provide these features, up to a maximum total of $60,000 per unit. This maximum of $60,000 per unit will include the total of all federal, state and local funds provided by the CDD. The CDD may also offer a higher amount per unit as temporary financing to reduce holding costs.
3. Projects may not exceed a total secured funds-to-value ratio greater than 115% from all sources. Projects where a community land trust serves as owner of the underlying land will be permitted to meet a higher ratio of 125% secured funds-to-value ratio for the entire project of land and property, or 150% of secured funds-to-value ratio for the land alone if the ground lease meets the conditions of affordability and 100% of the full value of the land is secured by a mortgage to the City.
4. A minimum of 85% of all funds received shall be applied to capital costs as defined by the CDD including acquisition and closing costs, rehabilitation, labor and materials, design and engineering costs. A maximum of 15% of the total CDD funds received may be applied to developer fees and other soft costs.
5. The CDD shall secure funding for capital costs with a promissory note and mortgage in the form of a non-recourse loan and a Land Use Restriction Agreement (LURA) if required by funding source. Funds will be provided in the form of a long-term deferred loan payable upon sale of the property, transfer or change of use of the property. The loan terms in the promissory note may be transferred to home owner.
6. All projects must comply with the relevant funding source requirements. The CDD will require that HOME-funded projects comply with the regulations in 24 CFR part 92, HOME Investment Partnerships Program, as amended and that CDBG-funded projects comply with the regulations in 24 CFR 570 Community Development Block Grant, as amended. These federal regulations include, but are not limited to, the following:
a. An agency designated as a developer cannot provide direct down payment assistance to individual homeowners purchasing the property unless it is a certified Community Housing Development Organization (CHDO) with the CDD or has both Developer and Sub-recipient contracts for each housing project as applicable.
b. All new homebuyers receiving a CDD loan will be required to attend a CDD- approved homebuyer education class. Homebuyers will be required to submit a homebuyer education certificate of completion to the CDD prior to closing.
c. Development of owner-occupied housing cannot exceed the HOME purchase price or value limit designated by the Federal Department of Housing and Urban Development (HUD).
d. Home ownership dwellings must be transferred to owner-occupied status within nine (9) months of construction completion.
e. Developers must comply with CD Division Underwriting Guidelines for all loans provided to owner-occupied dwellings.
f. All rehabilitation work must meet the CDD Rehabilitation Standards and prior to closing the housing units must meet all applicable City of Madison minimum housing standards and building codes.
g. COMMUNITY HOUSING DEVELOPMENT ORGANIZATION (CHDO) HOUSING: 15% of the aggregate HOME funds available to the City are reserved for projects administered by agencies which meet the HUD definition of a Community Housing Development Organization (CHDO), as defined in 24 CFR Part 92. The City may consider appropriate CHDO-sponsored, -managed or -owned projects for predevelopment or technical assistance loans.

Rental Housing Development Conditions
1. The CDD will evaluate each proposal based on the project’s contribution to increase the affordable housing stock, project’s financial need, leverage of other resources, developer capacity, project readiness, type of project (acquisition, rehab or new construction) and availability of resources to determine the appropriate level of funding up to a maximum investment of $54,000 per unit.
2. Projects that incorporate accessibility or energy efficiency improvements into the design, involve lead paint reduction or asbestos mitigation shall be considered for an amount greater than $54,000 per unit based on increased costs to provide these features, up to a maximum investment of $60,000 per unit. The maximum of $60,000 per unit will include the total of all federal, state and local funds provided by the CDD. The CDD may also offer a higher amount per unit as temporary financing to reduce holding costs. Projects involving construction of new affordable rental units shall be considered for an additional investment of up to $10,000 per unit, up to a maximum investment of $70,000 per unit.
3. Projects may not exceed total secured loan-to-value ratio greater than 115% from all sources. Projects in areas of priority to the City, including Neighborhood Resource Team (NRT) areas, may be allowed up to 125% secured loan-to-value ratio.
4. A minimum of 85% of all funds received shall be applied to capital costs as defined by the CDD including acquisition and closing costs, labor and materials, design and engineering costs. A maximum of 15% of the total CDD funds received may be applied to developer fees and other soft costs.
5. The CDD shall secure funding for capital costs with a promissory note and a mortgage in the form of a non-recourse loan and a Land Use Restriction Agreement (LURA) if required by a funding source. Funds will be provided in the form of a long-term deferred loan payable upon sale of the property, transfer, or change in the use of the property. The promissory note will require one of the following loan terms, to be requested at the time of project application:
Option 1: Long-term deferred loan payable upon sale, transfer or change in the use of the property. The promissory note will require repayment of either a percent of the appraised value after-rehab or construction based on the amount of the CDD funds invested in the property or a percentage of the net proceeds, whichever is less.
Option 2: Long-term deferred loan, plus 2% accrued simple interest, payable upon sale, transfer or change in the use of the property. Repayment will be equal to the amount of the CDD funds invested plus 2% simple interest accrued over the life of the loan.
6. A developer’s proposal should include a minimum of 5% of the total development costs in equity or a first mortgage.
7. Existing not-for-profit housing is eligible only for funds available through the Housing Development Reserve Fund (see Section 4 of this document).
8. The CDD will not consider investments in projects that convert owner-occupied units to rental units.
9. All projects must comply with the relevant funding source requirements. The CDD will require that HOME-funded projects comply with the regulations in 24 CFR part 92, HOME Investment Partnership Program, as amended, and that CDBG-funded projects comply with the regulations in 24 CFR 570 Community Development Block Grant, as amended. These federal regulations include, but are not limited to, the following:
a. Funds will be applied to the acquisition, construction and/or rehab of permanent or transitional rental housing with rents at or below the HOME rent levels.
b. At least 90% of the HOME-assisted units in a project must assist households at or below 60% Area Median Income (AMI) at the time of initial occupancy or investment. The remaining 10% of funds must assist households at or below 80% AMI.
c. Housing (after rehab) must meet the Community Development Division Rehabilitation Standards and all applicable City minimum housing standards and building codes.
d. Newly constructed housing projects will be:
i. located in areas of the city which do not have a high concentration of lower-income housing unless the project is necessary to meet overriding housing needs that cannot be met elsewhere in the city, or
ii. part of a larger neighborhood revitalization effort.
e. COMMUNITY HOUSING DEVELOPMENT ORGANIZATION (CHDO) HOUSING: 15% of the aggregate HOME funds available to the City are reserved for projects administered by agencies which meet the HUD definition of a Community Housing Development Organization (CHDO), as defined in 24 CFR Part 92. The City may consider appropriate CHDO-sponsored, -managed or -owned projects for predevelopment or technical assistance loans.

Improve housing stability for homebuyers, renters, homeless and special needs populations.
Priorities and Strategies
1. Target assistance geographically to:
a. Maximize access to jobs, transit, and other key amenities,
b. Implement neighborhood revitalization plans, and/or
c. Stabilize or improve areas of priority to the City, including NRTs.
2. Expand homeownership opportunities.
3. Stabilize renter households.
4. Reduce the number of homeless individuals and families.
5. Prevent at-risk households from becoming homeless.
6. Equip individuals with the information and/or skills necessary to obtain and maintain stable housing.
7. Reduce barriers to fair housing choice.

Homebuyer Assistance Conditions
1. Sub-recipient agencies will be limited to a maximum amount of $36,000 per unit of down payment assistance. Of this amount, up to 10% of the awarded may be used toward service delivery costs.
2. The CDD shall secure funding with a mortgage in the form of a non-recourse loan. Funds will be provided in the form of a long-term deferred loan payable upon sale of the property, transfer or change in use of the property. The promissory note will require a repayment of a percent of the appraised value based on the amount of the CDD funds invested in the property or net proceeds, whichever is less.
3. All projects must comply with the relevant funding source requirements. The CDD will require that HOME-funded projects comply with the regulations in 24 CFR part 92, HOME Investment Partnerships Program, as amended, and that CDBG-funded projects comply with the regulations in 24 CFR 570 Community Development Block Grant, as amended. These federal regulations include, but are not limited to, the following:
a. Funds may be used only for housing units which do not exceed the HOME purchase price or value limit designated by the Federal Department of Housing and Urban Development (HUD).
b. Loans must comply with CD Division Underwriting Guidelines for all loans provided to owner-occupied dwellings.
c. All new homebuyers receiving a CDD loan will be required to attend a CDD-approved homebuyer education class. Homebuyers will be required to submit a homebuyer education certificate of completion prior to closing.
d. Prior to closing, the housing must meet all applicable City minimum housing standards and building codes.

Homeless and Special Needs Populations Conditions
1. Projects must strengthen the area’s Continuum of Care (CoC) for homeless people, including outreach to homeless persons on the street; support services to homeless persons in emergency shelter, transitional housing, and permanent supportive housing; provide assistance to prevent homelessness or households at-risk; and/or provide financial assistance to help people obtain and maintain housing.
2. All projects must comply with the relevant funding source requirements. The CDD will require that ESG-funded projects comply with 24 CFR 576 Emergency Solutions Grant, as amended, and that Continuum of Care funded projects comply with 24 CFR 578. These regulations include, but are not limited to, the following: eligible recipients, program design, documentation standards and match requirements.
Preferences
1. The Committee will give preference to proposals designed to develop long-term solutions that assist homeless individuals in gaining the skills necessary to obtain and maintain stable housing.
2. The Committee will give preference to proposals that incorporate HUD’s Rapid Re-Housing model to move homeless persons into stable housing as quickly as possible, while providing a full complement of support services and financial assistance.
3. The Committee will give preference to proposals that incorporate the Housing First Model to prioritize moving homeless persons into stable housing without conditions of sobriety, income or service participation.
4. The Committee will give preference to proposals that provide services to homeless persons with multiple barriers to housing, and that prioritize serving homeless persons who have been homeless the longest.

Housing Resources Conditions
1. Funds will be targeted to the operating costs of projects which provide information or other non-monetary resources to low- and moderate-income persons, such as housing counseling, training, legal advocacy or mediation.
2. The Committee will consider projects that equip individuals with the skills needed to improve housing tenure.
3. The Committee will consider projects which either address broader housing opportunities for people of all races, non-English speakers and other protected classes, fair housing goals, or activities which support the access to affordable housing opportunities throughout the community.

Expand employment opportunities and enhance neighborhood vitality by supporting new and existing businesses.

Create jobs, particularly for underrepresented individuals, by supporting new or expanding businesses.
Priorities and Strategies
1. Target assistance geographically to:
a. Maximize access to jobs, transit, and other key amenities,
b. Implement neighborhood revitalization plans, and/or
c. Stabilize or improve areas of priority to the City, including NRTs
d. Contribute to the viability of neighborhoods.
e. Provide employment opportunities to neighborhood residents.
2. Create living wage jobs.

Conditions
1. Projects will target the development of jobs, 70% of which pay at least the City’s living wage and provide training and advancement opportunities.
2. The CDD will require the recipients of loans or equity investments agree to create, at a minimum, one full-time job for every $35,000 of CDBG funds received (Table 1). At least 51% of the jobs created must be filled by low- and moderate-income persons. Positions need to be created and filled within 2 years and will be tracked for the length of the loan.

Amount of Assistance Number of Jobs Created
1 job $1 – $35,000
2 jobs $35,000 – $70,000
3 jobs $70,001 – $105,000
3. Projects funded must have a well developed business plan that considers, among other things: focus of the business and intended customer base, expected costs and revenues, a particular sector of the economy (“green” jobs, etc.), a particular stage of development (start-up business, second stage business, etc.) and size of business (number of employees).

Assist entrepreneurs, particularly those from populations that are under-represented, seeking to start or grow small businesses and micro-enterprises (as defined by HUD) that create jobs.
Priorities and Strategies
1. Target assistance geographically to:
a. Maximize access to jobs, transit, and other key amenities,
b. Implement neighborhood revitalization plans, and/or
c. Stabilize or improve areas of priority to the City, including NRTs.

Conditions
1. The Committee will fund non-profits that provide technical assistance or appropriate space for nascent businesses, or loans to individuals starting or operating micro-enterprises where:
a. The low- and moderate-income owner’s job within the business is expected to become that individual’s principal occupation within three years of provision of assistance, or
b. The micro-enterprise is expected to create at least one full-time equivalent (FTE) position for a low- and moderate-income person, other than an owner, within four years.
2. Assist potential entrepreneurs by providing extensive education opportunities for start-up and operational assistance to the small business for at least 3 years.
3. Assistance to any micro-enterprise is limited to a three-year period which begins with the first CDBG-funded contact with the non-profit agency funded by the CDD.
4. The CDD will require the recipients of loans to create, at a minimum, one full-time job for every $35,000 of CDBG funds received (Table 1). At least 51% of the jobs created must be taken by low- and moderate-income persons. Positions need to be created and filled within 2 years and will be tracked for the length of the loan.
Table 1
Amount of Assistance Number of Jobs Created
1 job $1 – $35,000
2 jobs $35,000 – $70,000
3 jobs $70,001 – $105,000
5. Projects funded must have a well developed business plan that considers, among other things: focus of the business and intended customer base, expected costs and revenues, a particular sector of the economy (“green” jobs, etc.), a particular stage of development (start up business, second stage business, etc.), and size of business (number of employees).

Provide needed support and opportunities to help individuals overcome barriers to gainful employment and achieve economic stability.
Priorities and Strategies
1. Seek to align activities to support the Mayor’s Employment Initiative.
2. Provide quality employment related training and skill building opportunities that connect unemployed, underemployed, and underrepresented individuals to employment opportunities.
3. Provide supplemental services to increase likelihood of success, e.g., case management, job mentoring, transportation and childcare.

Conditions
1. The Committee will consider activities that connect residents to job training opportunities leading to permanent employment, and that continue to support the individual for at least six months.
2. The project will track the number of jobs obtained by participants, along with job titles and wage information.

Strengthen neighborhoods through strategic investments in physical assets and amenities like neighborhood centers, community gardens or other community facilities, as well as other planning and revitalization efforts.

Create, enhance, or sustain the development and operation of physical assets, such as neighborhood centers, community gardens or other physical amenities that help bring people of diverse backgrounds together, serve as neighborhood focal points, or help residents develop skills or take advantage of opportunities that will strengthen neighborhoods.
Priorities and Strategies
1. Target assistance geographically to:
a. Implement neighborhood revitalization plans, and/or
b. Stabilize or improve areas of priority to the City, including NRTs.

Conditions
1. Projects must demonstrate coordination with other community groups, service providers, and the support and participation of neighborhood residents.
2. Projects must demonstrate that their service area contains a minimum of 51% low- and moderate-income individuals, or at least 51% of their participants are low- and moderate-income individuals.

Create or improve safe, accessible, energy efficient and well-maintained community and neighborhood facilities.
Priorities and Strategies
1. Target assistance geographically to:
a. Implement neighborhood revitalization plans, and/or
b. Stabilize or improve areas of priority to the City, including NRTs.
2. Focus on major, large impact projects that leverage other funds.

Conditions
1. Funds will be used for the acquisition and/or rehabilitation of the nonresidential facilities of agencies that can demonstrate that a minimum of 51% of their customers are both low- and moderate-income persons and City of Madison residents.
2. The City will provide assistance in the form of a non-recourse, deferred payment loan that will be due and payable upon the sale, transfer, or change in use of the property. The CDD will secure the loan with a promissory note and a mortgage on the property. The promissory note will require one of the following loan terms to be requested at the time of application:
Option 1: Long-term deferred loan payable upon sale, transfer or change in the use of the property. The promissory note will require repayment of a percent of the appraised value based on the amount of the CDD funds invested in the property or net proceeds, whichever is less.
Option 2: Long-term deferred loan, plus 2% accrued interest, payable upon sale, transfer or change in the use of the property. Repayment will be equal to the amount of the CDD funds invested plus 2% accrued interest over the life of the loan.
3. Deferred payment loans to neighborhood centers shall include a City option to purchase the property or to find another agency to operate the project.
4. For agencies renting space, the City may provide up to $25,000 as a ten-year forgivable loan (the approximate period of depreciation for many improvements), unless the property owner will secure the loan with a mortgage on the property. Agencies renting space will be asked to provide a ten-year lease from the owner instead of a mortgage on the property.
5. The maximum cumulative amount that will be provided per property is $150,000, or $25,000 for property that is leased.
6. The City will not fund projects smaller than $25,000, except in the case of ESG funds.
7. In the interest of promoting longer-term maintenance and planning, the City will limit agencies to one application per property in a 3-year period.
8. Funds to address this objective are available through the Acquisition/Rehab Reserve Fund. (See Section 4, Reserve Funds.)

Help residents within designated neighborhoods identify, plan for and implement projects and activities that promise to enhance the quality of life for neighborhood residents.
Priorities and Strategies
1. Target assistance geographically to:
a. Implement neighborhood revitalization plans, and/or
b. Stabilize or improve areas of priority to the City, including NRTs.

Conditions
1. The Committee will reserve funds solely for use within an eligible CDD-designated neighborhood/census tract(s). Designated neighborhoods/census tracts shall be selected by the Committee using a variety of criteria, such as demographics of the neighborhood, other data from Neighborhood Indicators, other active initiatives, neighborhood changes and date of last plan (if one exists), existing neighborhood resources and potential opportunities.
2. The Committee will provide planning funds for a 1-year period for each designated neighborhood/census tract, to include appropriate technical assistance for increasing the capacity of the neighborhood, and planning assistance for preparation of a neighborhood plan or assistance in updating an existing neighborhood plan followed by a period of project funding.
3. The Committee will provide project funds for a 2-year period, for proposals submitted by a qualified entity sponsored by a City-designated neighborhood committee in the designated census tract(s) with a Council-approved neighborhood plan.
4. The Committee will provide funds to capitalized projects which are either one-time or will demonstrate self-sufficiency after the period of CDBG assistance. Projects categorized by HUD as planning/administrative or “public service” are not eligible.
5. Capital and infrastructure projects normally funded by the City as part of the capital budget process are not eligible except for projects addressing accessibility or those providing the neighborhood share of Madison Arts Committee projects or neighborhood park improvements.
6. Projects must be consistent with the neighborhood plan or update developed by the neighborhood committee and approved by the Common Council. Neighborhoods will be encouraged to recommend projects that address interrelated issues within a comprehensive strategy and which generate a long-term positive impact on the neighborhood.

The CDD will require projects to meet these national, state and local cross-cutting regulatory requirements, where applicable:
1. Serve low- and moderate-income (LMI) persons.
2. Take affirmative steps to utilize minority, women, and disadvantaged business enterprises (M/W/DBEs).
3. Comply with the goals and requirements of the City’s Section 3 Program, which seeks to extend employment, training and contracting opportunities to low- and moderate-income people and businesses.
4. Promote affirmative action, non-discrimination and equal opportunity for all citizens.
5. Comply with physical accessibility standards.
6. Minimize negative environmental impacts, and comply with environmental review requirements.
7. Comply with Federal Fair Labor Standards, and local Living Wage requirements.
8. Affirmatively further fair housing, housing diversity, and housing choices.
9. Reduce lead paint hazards using certified inspectors, supervisors, workers and companies, as well as established lead safe work practices when required.
10. Reduce hazards caused by asbestos and asbestos containing materials and/or remove asbestos and asbestos containing materials using a certified asbestos abatement supervisor and a certified asbestos worker.
11. Minimize both the direct and indirect displacement of persons and/or businesses. Where appropriate, the CDD will adhere to the state and federal assistance levels and procedures. The CDD will also use its funds only in projects that minimize the demolition of affordable housing units or their conversion to another use.
12. Design program operations to safeguard vulnerable populations, such as young children and frail elderly people.
13. Avoid conflict of interest situations, and comply with anti-lobbying requirements. Note: If a group is seeking approval of a development that has over 40,000 gross square feet of non-residential space, or a residential development of over 10 dwelling units, or if a group is seeking assistance from the City with a value of over $10,000 (this includes grants, loans, TIF or similar assistance), then the group is likely to be subject to Madison’s lobbying ordinance, sec. 2.40 MGO. The group is required to register and report its lobbying. Please consult the City Clerk for more information. Failure to comply with the lobbying ordinance may result in fines of $1,000 to $5,000.
14. Adhere to the constitutional and regulatory provisions of separation of church and state and avoidance of public funding of inherently religious activities.