AGENDA #1c
MEMORANDUM
TO: Mayor and Town Council
FROM: W. Calvin Horton, Town Manager
SUBJECT: Proposed 2002-2003 Community Development Program
DATE: March 26, 2002
The purpose of tonight’s public hearing is to receive citizen comments on a proposed plan for use of Community Development funds in fiscal year 2002-2003.
The U. S. Department of Housing and Urban Development has informed us that the Town will receive $445,000 of Community Development funds in fiscal year 2002-2003. During the 2001-2002 program year we received approximately $21,000 of program income in excess of the $35,000 we anticipated receiving. We also anticipate that we will receive an additional $4,000 of program income during 2002-2003 from repayment of mortgages and a small business loan. Therefore, we propose activities for a total of $470,000.
· We propose to return to the Council for consideration of the Community Development Plan on April 22, 2002.
· We propose to submit an update to the 2000–2005 Consolidated Plan to the Department of Housing and Urban Development on May 15, 2002.
INTRODUCTION
We propose the following use of Community Development funds for 2002-2003. This plan is based on comments received at a January 29, 2002 public hearing and applications submitted by agencies requesting funds.
Public Housing $170,000
Renovations (Airport Gardens) $115,000
Refurbishing Program $ 55,000
Neighborhood Revitalization $157,500
Community Services
(YMCA, Orange County Literacy Council, Police Dept.) $ 30,500
Property Acquisition (Habitat for Humanity) $ 17,000
Administration $ 95,000
Total $470,000
Program Income
The proposed budget includes program income beyond what was budgeted that we have received during the 2001-2002 program year, plus funds we anticipate that we will receive during the 2002-2003 program year. In the 2001-2002 program year, we anticipated that we would receive $35,000 of Community Development program income. To date, we have received approximately $56,000 of program income from the sale of two Tandler homes and the repayment of a small business loan to the Cookie Bear Company. Of this amount, $35,000 was budgeted in the current year, resulting in $21,000 available to budget in the proposed program for 2002-2003. The proposed budget also includes $4,000 of Community Development program income that we anticipate receiving in fiscal year 2002-2003. Therefore, in addition to the grant of $445,000, the proposed plan includes $25,000 of program income for a total of $470,000.
The benefit to programming projected program income is that the funds would be earmarked for a particular project and we would not have to amend the Community Development program mid-year. We believe that the Council can better set priorities when it reviews all requests and all projected revenues at the same time. Typically, when we receive program income during the program year, the Council schedules a public hearing to receive citizen comments on how to spend the funds, and the Housing and Community Development Advisory Board reviews the proposal and provides the Council with a recommendation. The public hearing on March 26 would satisfy our public participation requirements. In addition, the Housing and Community Development Board will have the opportunity to review the proposed Community Development Plan at its meeting on March 26, 2002.
We note that our projection of anticipated program income to be available next year is lower than previous years due to our expectation that program income received from the resale of Tandler homes will be used to convert homes to the Land Trust.
The Town of Chapel Hill has received Community Development grants since 1975 under the Housing and Community Development Act of 1974. This legislation provides funds to cities and counties to carry out activities that benefit low- and moderate-income families including: housing repair, public improvements, acquiring land for housing and economic development.
The primary objective of the Community Development program is to develop viable urban communities, by providing decent housing and a suitable living environment and expanding economic opportunities for low- and moderate-income households. Federal regulations define low-income as up to 50% of the median income and moderate-income as up to 80% of the median family income. According to the U.S. Department of Housing and Urban Development (HUD), 80% of the current median income for a family of four in the Raleigh-Durham-Chapel Hill Metropolitan Statistical Area is $54,400. (Please see Attachment 1 for the 2002 Raleigh-Durham-Chapel Hill Median Family Income by Household Size).
Since the mid 1980’s, the Council has used a significant amount of Community Development funds for the renovation of public housing communities. These funds have been used to rehabilitate the exterior of public housing apartments, for drainage improvements, and to refurbish the interior of apartments. Over the past several years, the Council has also budgeted funds for affordable housing development such as the Scarlette Drive and Meadowmont Townhomes and Habitat for Humanity’s New Homeplace Subdivision, Neighborhood Revitalization activities with EmPOWERment, Inc., and community service activities programs with the YMCA, Community Cuisine and the Orange County Literacy Council.
The Consolidated Plan
On May 15, 2000, the Town and Orange County submitted to the U.S. Department of Housing and Urban Development a five-year Consolidated Plan covering fiscal years 2000–2001 through 2004–2005. The purpose of the Plan is to identify and prioritize the housing and community development needs for Chapel Hill and Orange County. The Plan also suggests how the Town and the County will address the needs over a five-year period.
Each year, we are required to submit an update to the 2000-2005 Consolidated Plan that would include an annual plan for spending Community Development and HOME Program funds. The Plan for use of Community Development funds is approved by the Council and the HOME Program Plan is approved by the Council, the Orange County and Hillsborough Commissioners, and Carrboro Board of Aldermen.
This year’s update to the Consolidated Plan will include the 2002-2003 Community Development and HOME Program Plans as well as updates on housing and community development initiatives and programs in Orange County. We will prepare a draft Consolidated Plan for the Council’s consideration on April 22, 2002.
Public Participation Process
On January 29, 2002, the Council held the first public hearing to receive ideas from citizens about how funds could be spent in five areas: the Capital Improvements Program, the Town Budget, the Community Development Program, the HOME Program and the Comprehensive Grant. The hearing represented the first step in the Community Development planning process for 2002-2003.
Please see Attachment 2 for a summary of Community Development related comments and requests received at the January 29, 2002 public hearing and a summary of applications received.
This year we asked agencies requesting Community Development and/or HOME Program funding to submit a standardized application. The application requested detailed information about the agencies requesting funds and the proposed projects. The application also included a list of eligible Community Development activities, as well as a list of the housing and community development priorities from the 2000–2005 Consolidated Plan adopted by the Council in April 2000. We believe that this process allowed agencies to more clearly understand the criteria by which the projects would be evaluated. This revised application process, along with our new monitoring procedures (including site visits to each agency to evaluate progress), is designed to improve our overall Community Development performance.
We also note that this year we will be placing additional emphasis on performance and timeliness because of changes in the requirements of the U.S. Department of Housing and Urban Development. Beginning this year, the agency intends to sanction communities which have not met spending thresholds by withdrawing a percentage of new grant funding. We expect Chapel Hill to meet these spending thresholds this year. However, our evaluation criteria for new grants include an evaluation of whether funds could be spent readily.
DISCUSSION
Five-Year Plan
In April 2000 the Council adopted a five-year plan (please see Attachment 3). The plan includes a projection of Community Development funds through fiscal year 2004–2005, and proposes an amount of funds budgeted for each activity. The proposed plan serves as a guide to the Council when considering the use of future Community Development funds.
The plan proposes to continue funding public housing renovations, affordable housing projects, and community service activities over the next five years. In practice, our recommendations for the Community Service activities budget last year and this year is lower than the projected $56,000. Reducing funds for community service activities allows us to continue focusing our efforts on neighborhood revitalization and the development of affordable housing, especially in the Sykes Street and Northside, and Pine Knolls areas.
Proposed 2002-2003 Community Development Plan
We propose the following activities for the 2002–2003 Community Development grant:
Rehabilitation of Public Housing: $170,000
We propose to budget $115,000 of Community Development funds for the rehabilitation of twenty-six units at the Airport Gardens public housing community. Community Development funds would be used for architectural work related to the renovation and a portion of the Assistant Housing Director’s salary for oversight of the public housing renovation projects. Housing Capital Grant funds would be used for renovation expenses for the community. Proposed renovation work would include the abatement of lead-based paint and asbestos, replacement of windows and screens, replacement of interior and exterior doors, replacement of furnaces, replacement of floor tiles, replacement of bathtub liners and surrounds, bathroom fixtures, plumbing and electrical upgrades, and interior and exterior painting.
We propose to appropriate $55,000 of Community Development funds to continue the public housing refurbishing program. This program includes minor repairs of public housing units.
Neighborhood Revitalization: $157,500
We propose to budget $157,500 of Community Development funds to continue neighborhood revitalization activities. We recommend that we concentrate use of funds in the in the Northside, Pine Knolls, and public housing neighborhoods. Funds could be used for second mortgage assistance, property acquisition or renovation, code enforcement, demolition, public improvements, or community service activities. Activities must serve households earning less than 70% of the HUD published area median income.
We recommend an increase in these funds this year to underscore the recent emphasis on improving living conditions in the Sykes Street area of Northside. We propose to continue our efforts in this area by undertaking an interdepartmental effort with the Police Department, Planning, Inspections, and Public Works to improve the neighborhood environment. Specific activities in the Sykes Street area would include acquisition and rehabilitation of housing for homeownership, code enforcement, and where necessary, demolition of unsafe homes. We will continue to examine the feasibility of locating sidewalks in the area, and continue to evaluate the objectives of a possible realignment of the Sykes/Nunn/Whitaker Street intersection.
We received two requests for funds from agencies to use Community Development funds to develop housing for the elderly and for the developmentally disabled. If the agencies are able to identify properties in either the Pine Knolls or Northside neighborhood, they could request funding for these projects. However, it is likely that these would have a lower priority due to the recommended emphasis on providing increased funding for improving neighborhood conditions in the Sykes Street strategy area.
In addition, Neighborhood Revitalization funding could be provided to Youth Creating Change’s outstanding request if the group is able to develop an eligible job training program. If the Youth Creating Change Serteen Club submits a well-developed and viable proposal for both the retail business, including a well developed business plan, and a job training program, we could consider either partially or fully funding the project with Community Development funds set aside for Neighborhood Revitalization.
We recommend that the Council continue to authorize the Manager to approve specific projects for use of these funds. We also recommend that the Council authorize the Manager to approve converting Neighborhood Revitalization funds into grants to Orange Community Housing and Land Trust as opportunities appear to achieve long term affordability of housing projects to be placed in the Land Trust.
We propose to budget $17,000 to Habitat for Humanity to acquire property adjacent to property Habitat currently owns on Rusch Road located off of Rogers Road. Habitat intends to develop sixteen houses on the land for households earning less than 50% of the area median income. Acquisition of the additional property would allow Habitat to develop a larger subdivision.
Because of the schedule of the development approval process, we do not expect that Habitat will be able to begin construction until April 2003 and therefore would not spend all of the $100,000 requested in the 2002-2003 program year. We recommend that the Council consider reserving $83,000, the balance of this request, in the 2003-2004 Community Development program budget for this activity. Because of the new federal guidelines involving possible sanctions of the Town’s grant if funds are not spent in a timely manner, we do not recommend that the Council budget all the requested funds in one year.
In 2001-2002, the Council budgeted $50,000 from Community Development funds and $50,000 from the Housing Loan Trust Fund for this activity. Habitat intends to use $30,000 to acquire portions of this property before June 30, 2002. Remaining funds would be used to acquire additional properties.
Community Services: $30,500
We propose to budget funds for three community service activities that meet the Community Development regulations:
Program Administration: $95,000
We propose to budget $95,000 for administration of the Community Development program. Currently, the Community Development staff administers the Housing Loan Trust Fund, coordinates efforts with non-profit organizations that receive Community Development funding from the Town, coordinates activities with the HOME Program Consortium, monitors compliance with Performance Agreements and federal regulations, and coordinates with the U.S. Department of Housing and Urban Development to achieve compliance with federal regulations. Funds would be used for the Community Development Coordinator’s salary, a portion of the Long Range Planning Coordinator’s salary, a part-time contract Community Development Program Monitor, and overhead costs.
NEXT STEPS
All comments received during tonight’s public hearing and after the hearing will be summarized and submitted with the Consolidated Plan to the Department of Housing and Urban Development. The Housing and Community Development Advisory Board reviewed the proposed plan on March 26, 2002, and will forward its recommendation.
We will submit a recommended Community Development plan to the Council for consideration on April 22, 2002. A final Consolidated Plan must be submitted to the Department of Housing and Urban Development by May 15, 2002.
ATTACHMENTS
1. 2002 Median Household Income for Raleigh-Durham-Chapel Hill area (p. 8).
2. Summary of Comments and Community Development Requests (p. 9).
3. Adopted Five-Year Community Development Plan (p. 15).
4. National Objectives of Community Development Legislation (p.16).
2002 Raleigh-Durham-Chapel Hill MSA
|
# in Household |
100% of Median |
80% of Median |
|
1 |
$49,900 |
$38,100 |
|
2 |
$57,040 |
$43,500 |
|
3 |
$64,150 |
$48,950 |
|
4 |
$71,300 |
$54,400 |
|
5 |
$77,000 |
$58,750 |
|
6 |
$82,700 |
$63,100 |
|
7 |
$88,400 |
$67,450 |
|
8 |
$94,100 |
$71,800 |
Source: U.S. Department of Housing and Urban Development (HUD)
Note: HUD has declared the Raleigh-Durham-Chapel Hill MSA a Low Housing Cost area therefore, income figures are adjusted to reflect this designation.
1/2002
ATTACHMENT 2
The citizen comments received at the January 29, 2002 public hearing and applications for funding are summarized below. We note that all agencies that requested funding were required to submit an application.
Activities eligible for Community Development funding must meet one of three National Objectives:
· Benefit low- and moderate-income persons; or
· Aid in the prevention or elimination of slums and blight; or
· Treat urgent needs posing an immediate threat to public health and welfare.
Examples of eligible activities include acquisition and /or renovation of property, second mortgage assistance, and site development.
The following comments and applications were considered:
1. Chapel Hill Department of Housing
The Chapel Hill Department of Housing requested $198,000 of Community Development Program funds for the following purposes: $115,000 to renovate twenty-two apartments in the Airport Gardens public housing community; and $83,000 to continue the Five Year Refurbishing Program to refurbish about fifty apartments.
Staff Comment: We propose to budget $115,000 for renovation of Airport Gardens and $55,000 for refurbishing apartments. We recommend a reduction in the refurbishing budget because approximately $25,000 remains in the refurbishing budget for the current year. The Town’s public housing is an important source of affordable rental housing and the Town’s investment in this property should be maintained. The renovation of public housing units is an eligible Community Development activity. Based on past levels of spending activity, we believe $55,000 in new funds plus continued access to current funds will be sufficient for this activity in the 2002-2003 year.
2. Habitat for Humanity of Orange County
Habitat for Humanity requested $100,000 of Community Development funds for development of up to twelve single family homes and six rental units in three duplexes on land it owns on Rusch Road. The homes would be available to very low-income households earning 50% or less of median income.
Staff Comment: The request would continue to fund a currently funded project. This project would meet the objectives of the Consolidated Plan to provide homeownership opportunities for low-income households, and is therefore a priority.
The acquisition of property is an eligible Community Development program activity. We propose to budget $17,000 of Community Development funds to acquire the additional property. Because of the schedule of the development approval process, we do not expect that Habitat will be able to begin construction until April 2003 and therefore would not spend all of the requested funding in the 2002-2003 program year. We recommend that the Council consider reserving $83,000 of 2003-2004 Community Development funds for this activity for the balance of the requested funds. Because of the new federal guidelines involving possible sanctions of our grant if funds are not spent, we do not recommend budgeting all the requested funds in one year.
3. Residential Services
Residential Services requested $75,000 to purchase a home in an existing neighborhood in Chapel Hill would be available to four adults with autism, each earning below 30% of area median income. Each resident would have his or her own room and would share the kitchen, dining, and living areas with other residents. The agency has also requested $75,000 of HOME Program funds for this project.
Staff Comment: If the home is located in one of the community development focus areas of Pine Knolls or Northside neighborhoods, we could consider either partially or fully funding the project with Community Development funds set aside for Neighborhood Revitalization. However, we suggest that priority for use of these funds be for neighborhood improvements in the Sykes Street strategy area. We note that the HOME Program Review Committee recommends budgeting $75,000 of 2002-2003 HOME Program funds for this activity.
4. First Baptist and Manley Estates
First Baptist and Manley Estates requested $36,960 for the following purposes: $33,000 to construct an additional 20 parking spaces to serve residents’ needs; and $3,960 for an adult computer/learning lab.
Staff Comment: We have reviewed the Community Development regulations and conferred with our HUD representative and determined that purchasing computer equipment for a computer lab is not an eligible use of Community Development program funds. We informed the Managing Agent of the facility that Community Development funds could be used purchase computer equipment if a specific program were developed to support these activities. If the organization were to develop a program, we could consider funding this portion of the request in the future. We also do not recommend funding for the twenty parking spaces because of the overall emphasis on affordable housing objectives contained in the Consolidated Plan.
We note that First Baptist also submitted an application for HOME Program funds for the parking lot request. Orange County staff has determined that this activity would not be eligible for HOME Program funding.
5. Carrboro/Chapel Hill Cooperative Housing Association (with EmPOWERment, Inc.)
The Carrboro/Chapel Hill Cooperative Housing Association requested $100,000 to create an Affordable Senior Housing Co-op. The project would contain six units for senior citizens earning less than 60% of the area median income. The organization has also requested $100,000 of HOME Program funds for this project.
Staff Comment: If the agency is able to identify a house in one of the community development focus areas of Pine Knolls or Northside neighborhoods, the project may be eligible for Neighborhood Revitalization funds. However, we recommend that priority for use of these funds over the next year be for neighborhood/housing improvements in the Sykes Street strategy area.
6. Sewer Connection Assistance to Rogers Road Residents
A resident of the Rogers Road neighborhood requested assistance from the Town to help Rogers Road residents connect to the public sewer system.
Staff Comment: Community Development funds could be used to provide assistance to help lower income households connect to the public sewer system. We understand that connection could be possible through the construction of the infrastructure for Habitat for Humanity’s proposed project on Rusch Road. Because the infrastructure will not be completed during the 2002-2003 fiscal year, we recommend that the residents of the Rogers Road request sewer connection assistance from the Council during the 2003-2004 budget process.
The use of funds for public service activities is eligible under federal Community Development regulations. Examples of public service activities includes programs concerned with employment, crime prevention, child care, health, drug abuse, education, fair housing counseling, energy conservation, homebuyer down payment assistance or recreational needs. The amount of Community Development funds used for public services cannot exceed 15% of the Town’s Community Development grant ($66,150 in 2002-2003).
In addition to meeting one of the National Objectives listed above, community or public service activities must provide:
(1) a new service; or
(2) a quantifiable increase in the level of an existing service than what was provided over the last fiscal year.
In the past, the Council has funded public service projects that support other Community Development objectives and activities, especially public housing and Neighborhood Revitalization. Some emphasis has also been placed on job training for low-income residents. We evaluated the following applications in terms of previous performance and their relationship to other Community Development objectives. In general, we are recommending that some funding be set aside for community services, but that the Council emphasizes housing objectives as contained in the Consolidated Plan.
The following agencies submitted applications for Community / Public Service activities:
1. Chapel Hill – Carrboro YMCA
The Chapel Hill – Carrboro YMCA requested $13,860 of Community Development funds to continue operation of After School Programs for children living in the Pine Knolls and South Estes Drive Family communities.
Staff Comment: We propose to budget $13,500 to the YMCA to continue its after school program for youths living in the Pine Knolls and South Estes Drive public housing communities.
Since 1994, the Town has provided Community Development funds to the YMCA for its After School Program at the Pine Knolls Community Center. In 1999, the YMCA established a similar program at the South Estes Drive Community Center. This year, approximately three children from Pine Knolls and fourteen children from South Estes were served by these programs. In February, the YMCA moved the program from the South Estes Drive Community Center to the YMCA facility so the children could receive a more enriching and diversified after school experience.
2. Orange County Literacy Council
The Orange County Literacy Council requested $11,500 to continue funding a Program Coordinator for the Community Computer-based Literacy Program. The Program provides computer-based literacy and GED classes to public housing residents and low-income Chapel Hill residents.
Staff Comment: We believe that the Literacy Council operates a needed service for public housing and other lower-income Chapel Hill residents in an effective manner. We recommend that the Council allocate $11,500 to the Literacy Council.
The Town Council previously appropriated $15,000 of 1999–2000 Community Development funds to the Literacy Council to establish the computer literacy lab program, and $9,000 of 2001-2002 funds to expand the program. The Literacy Council has provided computer literacy tutoring at South Estes, Trinity Court/Pritchard Park, and the Hargraves Community Center using equipment purchased with Community Development funds. The agency has also provided one-on-one tutoring for lower income Chapel Hill residents at various sites. During the 21 months of the initial grant, the Literacy Council served 65 lower income Chapel Hill residents. The Literacy Council has continued to outreach to public housing residents and other low-income citizens to try to recruit participants for the programs.
3. Chapel Hill Police Department
The Chapel Hill Police Department requested $5,160 to help fund a Summer Youth Work Program. The Police Department proposes to recruit approximately ten, 14-17 year old youths who reside in either Pine Knolls, Northside, or public housing neighborhoods. The youths would work twenty hours per week in various Town departments including Police, Housing, Public Works, Parks and Recreation, the Fire Department, the Town Clerk, and the Library. The funds would pay the youths’ salaries at a pay rate of $6.00/hour.
Staff Comment: We recommend that the Council provide $5,500 of Community Development funds for this program. We believe it would provide an enriching work experience for youth from the areas targeted for neighborhood revitalization. The Police Department has successfully operated this program since 1995.
4. EmPOWERment, Inc.
EmPOWERment has requested $7,000 to provide a Transitional Housing Financial Education program to public housing residents who wish to move out of public housing into the housing market. The program would be implemented by Harvey Reid of H.R. Consulting, who would provide classes and one-on-one counseling to participants in the Town’s Transitional Housing Program.
Staff Comment: Though provision of financial education for public housing residents would be an eligible Community Development activity, we do not recommend funding this program at this time. A similar service is currently being provided by the Town’s ACHIEVE program operated by the Housing Department. If during the year we determine that there is a strong need for additional financial management services for public housing residents, EmPOWERment could request Neighborhood Revitalization funding for this activity.
5. Youth Creating Change Serteen Club
In March 2001, the Youth Creating Change Serteen Club requested Community Development funds from the Town to open a youth arcade in the Northside neighborhood. At that time, we recommended that if the group’s business plan were more fully developed and other resources and funding were committed, the Council could consider using up to $9,000 of Community Development program income or reallocate residual Community Development funds to match the funds raised. The group has since modified its original proposal and has instead opened a retail shop on North Graham Street.
We have met with Youth Creating Change representative Maxecine Mitchell and informed her that for this new proposal, Community Development funds could be provided if the group developed a job training program for youths to be run in the retail clothing store.
Staff Comment: At this time, we do not propose to budget Community Development funds for this activity because the job training program is not sufficiently developed and incorporated into the organization’s business plan. If the Youth Creating Change Serteen Club submits a well-developed and viable proposal for both the retail business, including a well developed business plan and a job training program, we could consider either partially or fully funding the project with Community Development funds set aside for Neighborhood Revitalization.
ATTACHMENT 3
|
Activity |
2000–2001 |
2001–2002 |
2002–2003 |
2003–2004 |
2004–2005 |
|
Public Housing Renovation |
$120,000 |
$120,000 |
$120,000 |
$120,000 |
$120,000 |
|
Public Housing Refurbishing |
$70,000 |
$60,000 |
$60,000 |
$50,000 |
$50,000 |
|
Neighborhood Revitalization |
$72,600 |
$79,000 |
$79,000 |
$80,000 |
$80,000 |
|
Meadowmont Townhomes |
$80,000 |
$80,000 |
$0 |
$0 |
$0 |
|
Affordable Housing Projects |
$0 |
$0 |
$71,000 |
$80,000 |
$80,000 |
|
Community Services |
$47,000 |
$47,000 |
$56,000 |
$56,000 |
$56,000 |
|
Administration |
$76,400 |
$80,000 |
$80,000 |
$80,000 |
$80,000 |
|
TOTAL GRANT |
$466,000 |
$466,000 |
$466,000 |
$466,000 |
$466,000 |
National Objectives of Community Development Legislation
Congress established the Community Development program in 1974 by consolidating a number of grant programs into one “block grant”. The primary objective is:
“development of viable urban communities, including decent housing and a suitable living environment and expanding economic opportunity, principally for persons of low and moderate-income.” (Housing and Community Development Act of 1974)
To receive future Community Development Block Grant funds, Chapel Hill must certify that its overall program carries out this primary objective. In addition, each Community Development Block Grant activity must:
1. Benefit low- and moderate-income persons; or
2. Aid in the prevention or elimination of slums and blight; or
3. Treat urgent needs posing an immediate threat to public health and welfare.
Eligible activities for Community Development Block Grant funding
(from Federal Regulations)
Community Development Block Grant funds may be used for the following types of activities (provided national objectives are also met):
· acquisition of property
· disposition of property
· public facilities and improvements
· clearance, demolition and removal of buildings
· some public services (subject to some limits in regulations)
· relocation
· housing rehabilitation, preservation and code enforcement
· economic development activities
· new housing construction (subject to some limits in regulations)
· planning and administrative costs
Alternatives that are generally not eligible include:
· buildings used for the general conduct of government
· general government expense
· political activities
· purchase of equipment and personal property
· operating and maintenance expenses