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  Special Consideration for Defense Communities

  We request that EDA establish preferential selection criteria recognizing communities that are impacted by Defense Department actions such as base realignment and closure (BRAC), specifically base closure and mission growth. Defense Department actions however, are not limited to BRAC and can include changes due to Overseas re-basing and transfer of missions. In most communities, the Defense Department is the largest ...more »

  We request that EDA establish preferential selection criteria recognizing communities that are impacted by Defense Department actions such as base realignment and closure (BRAC), specifically base closure and mission growth. Defense Department actions however, are not limited to BRAC and can include changes due to Overseas re-basing and transfer of missions.

  In most communities, the Defense Department is the largest employer and the economic engine. Changes to the local military installation, whether through downsizing or growth, and done without regard to the local community, have significant impacts on the adjacent community. Communities have no input into the actions of the Defense Department, but must address all of the impacts on their own.

  For these defense communities, EDA funding is a critical resource to deal with the incredible strain placed on their community. A selection criteria recognizing the unique challenges of defense communities would assist them in their economic development efforts. In addition, EDA should also consider establishing and funding a dedicated program solely for defense communities.

  Some of the major concerns with EDA is that the process to approve projects takes too long, is very bureaucratic and project decisions are made at the regional and national levels versus the at the state level. EDA should consider establishing a state-by-state block grant formula (much like CDBG), and allow the State Economic Development Representatives more decision-making authority on projects in their respective regions.

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  Submitted by Community Member 2 years ago

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  Regional Innovation Clusters (RICs) »

  CEDS, RLF, local match

  • Federal-Local Cost Share: EDA should modify its guidelines for local match requirements for planning and project investments in areas of distress. While Congress sets some very basic requirements for the federal cost share, the agency’s regulations actually guide the specific criteria for raising the federal share of projects in areas with higher unemployment, poverty or sudden and severe dislocation (including using ...more »

  • Federal-Local Cost Share: EDA should modify its guidelines for local match requirements for planning and project investments in areas of distress. While Congress sets some very basic requirements for the federal cost share, the agency’s regulations actually guide the specific criteria for raising the federal share of projects in areas with higher unemployment, poverty or sudden and severe dislocation (including using its existing authority to waive the local match for FEMA-declared disasters). The agency made harmful changes to these requirements in 2005, resulting in dramatic increasing in local match for most planning and project awards. NADO strongly supports the revised federal-local cost share provisions included in S. 2778 by the U.S. Senate Committee on Environment and Public Works during the 111th Congress.

  • Board and CEDS Committee Requirements for Economic Development Districts: The agency’s 2005 rulemaking made a series of unnecessary and overreaching regulatory changes as related to the governance structure and makeup of EDD policy boards and CEDS committees. In addition, the agency now requires a standardized, one-size-fits-all CEDS document that limits regional flexibility and creativity. As outlined during a recent NADO CEDS Innovation Forum, the agency should provide greater flexibility and local control of the CEDS process, while also requiring EDDs and others to identify and achieve specific performance measurements and outcomes. (See attached for very preliminary concept of EDD industry-led Standards of Excellence that were developed and discussed at the NADO forum. The idea is to move from a regulator-driven planning process to an industry-led, peer reviewed and monitored process with regional flexibility yet performance oriented.)

  o Increased flexibility for governance structure and local control of EDD policy boards

  o Increased flexibility and recognition of regional diversity with respect to makeup of EDD CEDS committees

  o Allow EDDs to focus CEDS on specific strategies (Put the S back into CEDS), rather than a comprehensive narrative of the region; CEDS document could have different parts: executive summary with high level strategies, followed by appendix with project examples, census data and other related resources.

  o Streamline CEDS plan requirements to allow for more regional asset-based strategies

  o Ensure EDA project implementation investments are tied to EDD CEDS

  • Regional Collaboration Incentives: The agency should consider using its flexibility with respect to federal-local cost share to re-establish federal incentives for regional collaboration of local governments and other related entities through the national network of Economic Development Districts. The agency should use its discretion and existing authority to increase the federal share in project investments with regional significant and/or significant regional collaboration, including with multi-EDD or statewide EDD planning initiatives and multi-jurisdictional projects.

  • Revolving Loan Funds (RLFs): The agency should work to fully defederalize RLFs within the constraints of the current law. The agency should pursue some more flexible options to minimize the reporting burdens for RLF intermediaries with a proven track record. In addition, EDA should use its existing authority to allow for shared management, marketing and administration of RLFs for underperforming loan funds. In addition, the agency should establish an RLF Advisory Committee of RLF practitioners to assist in the development of a more streamlined and user-friendly RLF reporting system and process.

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  Submitted by Community Member 2 years ago

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  Adopt NADO "Peer Standards of Excellence" for CEDS

  As an Economic Development District employee charged with leading my region through the Comprehensive Economic Development Strategy (CEDS) plan-writing process, my recommendation is that EDA implement the seven "Peer Standards of Excellence" principles which were established at the NADO CEDS Innovation Forum in January of 2011. The Forum was made up of a large and representative group of national economic development ...more »

  As an Economic Development District employee charged with leading my region through the Comprehensive Economic Development Strategy (CEDS) plan-writing process, my recommendation is that EDA implement the seven "Peer Standards of Excellence" principles which were established at the NADO CEDS Innovation Forum in January of 2011. The Forum was made up of a large and representative group of national economic development peers who work in the trenches of CEDS development and who understand what is effective vs. what is simply prescriptive. The most recently published CEDS "Interim Final Rules" is a very long list of requirements, many of which are redundant. The list is so long that plan writers spend most of their time trying to check off its boxes rather than focus on a plan that is truly relevant to the unique circumstances and assets of any given region. This long and prescriptive list of reg’s truly encourages "data dumping" rather than real plan writing. Furthermore, many EDD's are obsessed with the idea that if a particular project is not listed in their CEDS annual update, it will not be eligible for potential EDA grant funding. Plan writers thus try to inventory every single possible project (large or small) in their large regions "just in case" a grant application is one day needed. This is a bad incentive to place on EDD's and I think clarity is needed from EDA to ensure that a community does not jeapordize its EDA funding chances by not including some unforeseen project in a CEDS update. It all goes back to longs lists of requirements which encourage data dumping and regulations which are just too prescriptive. The solution is to simplify the CEDS guidelines by adopting the above-noted “Peer Standards of Excellence” principles. EDA (including the Assistant Secretary) was extremely receptive to our ideas in January and I hope that positive changes will result to encourage real regional economic development planning in this country.

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  Submitted by David Shellhorse 2 years ago

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  Unnecessary EDA forms

  Administrative requirements should be streamlined and mandates that do little to enhance the intent of a program should be eliminated (eg. background check). These are intrusive, especially when the form is required for political leaders of a community. It creates mistrust and impatience with EDA as an agency.

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  Submitted by Community Member 2 years ago

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  Project Review Process

  EDA should not depend solely on a strict standard application and point grading system. The strength of EDA has been its work with communities in need and project evaluation that goes beyond adding up points or percentages in a table. There are many nuances that cannot be quantified in a good project.

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  Submitted by Community Member 2 years ago

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  Projects granted to entities outside of a District

  EDA should recognize the strength of its Districts and require coordination with Districts for projects submitted by those outside the District but proposing activities that affect a District's communities. Recent initiatives have bypassed District scrutiny and no input from EDDs have been required. Those receiving EDA funds through initiatives see no need to work with Districts.

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  Submitted by Community Member 2 years ago

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  Increase incentives for working with Districts

  Increase incentives for working with Districts by restoring the 10% project bonus for active participation with a District.

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  Submitted by Community Member 2 years ago

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  Project review process

  Conditional granting of funds using written documentation that lists conditions and timeframe for meeting requirements would give applicants the confidence to spend more money if needed for studies to move a project closer to acceptance.

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  Submitted by Community Member 2 years ago

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  Shovel-ready projects

  Restricting projects to those that are shover-ready are likely to eliminate promising projects in need of some extra funding to become a reality.

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  Submitted by Community Member 2 years ago

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  Costs associated with applying for an EDA grant

  Applicants are occasionally asked to pay for costly studies to verify eligibility for EDA funds. EDA should consider these as part of the local match and recognize that they often place an undue burden on applicants. Applicants might also be more willing to take on an expense if there is written confirmation of an EDA award (subject to meeting specific conditions).

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  Submitted by Community Member 2 years ago

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  Private-public partnerships

  Greater flexibility is needed for EDA regulations concerning public-private partnerships. EDA encourages these partnerships but makes it hard to fund a project where a private entity expects to earn a profit without additional (and deal-killing) paperwork.

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  Submitted by Community Member 2 years ago

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  Regional Innovation Clusters (RICs) »

  Coordinated Regional Research Networks

  There is a need for coordinated regional research networks for depressed regions such as the Midwest. The BEA efforts are too locally focused and do not emphasize the broader regional problems that underlie the persistent economic distress. For example, it is not just a “Youngstown” problem or a “Detroit” problem, but a more systemic problem across the entire Midwest region. While publications have been produced by the ...more »

  There is a need for coordinated regional research networks for depressed regions such as the Midwest. The BEA efforts are too locally focused and do not emphasize the broader regional problems that underlie the persistent economic distress. For example, it is not just a “Youngstown” problem or a “Detroit” problem, but a more systemic problem across the entire Midwest region.

  While publications have been produced by the likes of Richard Longworth and the Brookings Institution’s Metropolitan Policy Program and efforts have been initiated by the likes of the Detroit Regional Chamber and plans offered by the Great Lakes Association of Regional Councils, the impact in shaping a regional Midwest agenda has been small. There is a need to pull together the efforts underway to offer a sustained, rigorous study and portrait of the Midwest’s diverse economies and to disseminate these study findings to the end-user constituencies.

  Coordinated regional research networks can provide local political, economic development and business leaders with an understanding of the regional economic context in which they operate, set policy, attract investment and attract and retain jobs. Such networks can offer courses and workshops to disseminate research findings to empower public and private decision-makers with the understanding of their local economy that will help them make more informed policy decisions, and apply the appropriate tools and strategies for economic development and enhanced quality of life.

  Research dollars ought to be invested in building coordinated broad-based regional efforts that provide for better dissemination and application of research findings to improve the life of Midwest residents and the competitiveness of Midwest employers.

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  Submitted by Community Member 2 years ago

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  CEDS regulations inconsistent for entities not in a District

  CEDS from entities not participating with an Economic Development District should be held to the same standards as EDDs having to comply with EDA's CEDS regulations. CFR 303.7 gives EDA the discretion to determine that "a CEDS is acceptable without fulfulling all the requirements." This undermines districts and places greater regulations on an entity that complies with EDA's guidelines.

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  Submitted by Community Member 2 years ago

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  EDA Reporting requirements

  Documentation on how to prepare CEDS Updates, GPRA reports and CEDS Annual Performance reports is ambiguous and results in confusion.

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  Submitted by Community Member 2 years ago

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  Economic Development Representatives

  Field representatives in the states are absolutely necessary. Without them, District staff shoulder a larger share of the work without additional compensation.

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  Submitted by Community Member 2 years ago

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  Regional Innovation Clusters (RICs) »

  Support Sustainable Communities

  EDA should adopt grant guidelines that reward communities for sustainable development strategies such as locating new development on previously developed land, or close to existing activity centers, and near transportation choices. This would support community and regional efforts toward sustainable development, support community reinvestment, rebuild our infrastructure, and build on past public investment and spending. ...more »

  EDA should adopt grant guidelines that reward communities for sustainable development strategies such as locating new development on previously developed land, or close to existing activity centers, and near transportation choices. This would support community and regional efforts toward sustainable development, support community reinvestment, rebuild our infrastructure, and build on past public investment and spending. This would also provide needed funding for existing communities to leverage place based assets and integrate those assets into broader efforts for economic transformation and growth. Additionally, EDA should support regional and local planning and economic visioning efforts that take into account local and regional assets (including natural, social, community, and geographic resources) and global economic change.

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  Submitted by Community Member 2 years ago

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  Fund Operations at Business Incubators

  I suggest you consider the funding of operations for business incubator projects for the start up phase.

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  Submitted by Barbara Zwetzig 2 years ago

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  Federal agency partnering

  I suggest EDA's funding be less restrictive when it comes to matching other Federal Funding sources. MOU's should be negotiated between EDA and all other Federal agencies to allow for Federal funds that are designated to local state agencies, to be considered as eligible matching funds for EDA funding. If Federal agencies are serious about “partnering” then EDA’s regulations need to be revised. For instance, the Federal ...more »

  I suggest EDA's funding be less restrictive when it comes to matching other Federal Funding sources. MOU's should be negotiated between EDA and all other Federal agencies to allow for Federal funds that are designated to local state agencies, to be considered as eligible matching funds for EDA funding. If Federal agencies are serious about “partnering” then EDA’s regulations need to be revised. For instance, the Federal Transportation Dept. designates funds to a state’s highway department program for transportation/economic development projects. Because of those funds come directly from the Federal Government, (even though they are in the control of the state agency to utilize), these funds cannot be utilized as eligible match to EDA’s funds. In this particular instance, the Federal Highway Agency allows for other Federal funds to match their monies, but EDA does not allow the same without an MOU between EDA and the Federal Highway Agency.

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  Submitted by Debra Beavin 2 years ago

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  RRLF

  I suggest you defederalize RRLFs which have been in existence and in compliance for more than ten years. Also have reporting dates of March 31 and September 30 instead of an entity fiscal year makes accurate reporting extremely difficult and very expensive to audit.

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  Submitted by Gwen Luper 2 years ago

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  Allow Ongoing Innovation of SOW

  The very rigid legal interpretations of scope of work compliance and conflict of interest should be relaxed. Frequently innovation efficiencies emerge after project work has begun but these efficiencies, and the related potential for over delivering the project are not allowed because they were not specifically identified in the original project scope of work. Within a true innovation culture adjustments and resultant ...more »

  The very rigid legal interpretations of scope of work compliance and conflict of interest should be relaxed. Frequently innovation efficiencies emerge after project work has begun but these efficiencies, and the related potential for over delivering the project are not allowed because they were not specifically identified in the original project scope of work. Within a true innovation culture adjustments and resultant over delivery should not be discouraged.

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  Submitted by Community Member 2 years ago

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  CEDS-Economic Development Planning in the 21st Century

  Comments and Recommendations for EDA: The Michigan State University Center for Community and Economic Development has a twenty five year history of working with Economic Development Districts (EDDs) and EDA. In 2010 we completed, in partnership with three Economic Development Districts (EDDs) a major initiative to transform their Comprehensive Economic Development Strategies (CEDS) and empower regional planners to ...more »

  Comments and Recommendations for EDA:

  The Michigan State University Center for Community and Economic Development has a twenty five year history of working with Economic Development Districts (EDDs) and EDA. In 2010 we completed, in partnership with three Economic Development Districts (EDDs) a major initiative to transform their Comprehensive Economic Development Strategies (CEDS) and empower regional planners to compete more effectively in the global knowledge economy.

  That project’s strategies, specific accomplishments are fully described in the project’s report which is available for review at http://www.knowledgeplanning.org/ . Below is a brief summary of the recommendations we put forward as a result of the project partnership and the lessons learned in working with EDA, EDD’s in advancing their capacity to do effective economic development planning in the global knowledge economy. We believe these findings to be of value to EDA in considering your current regulations, policies and practices and your stated desire to “improve them to help the agency better advance innovative economic development in the 21st century”.

  Taking the Comprehensive Economic Development Strategy to the Next Level:

  • CEDS data sets at a minimum must be updated to include relevant 21st Century global knowledge economy indicators and measures at the regional level such as; high speed internet and the digital economy, indicators of a regional global capacity/economy , measures of the knowledge jobs sector, indicators of economic dynamism (entrepreneurial growth and transformation), and human talent attraction and retention.

  • The development of a CEDS should be a data-driven regional economic development planning process that prioritizes projects for which EDA and other federal agency support is sought. This prioritization process should be transparent to regional partners and fully supported by EDA and other federal agencies. Only in rare and unusual circumstances should projects not prioritized in the CEDS be supported without a full CEDS amendment including public review of project priorities.

  Improving the Performance of Economic Development Districts to Empower Competitive Regions:

  • EDA must increase its financial support to the multiple roles played by EDD planners. EDA should commit to making EDD economic development planners recognized regionally and nationally as the “best economic development professionals” in a region.

  • EDD planners must have access to regularly-scheduled professional development opportunities to insure that their skill sets are at peak performance. EDA’s University Center program should be encouraged to provide this professional development for EDD’s to improve and enhance their professional capacity. Professional training topics could include:

  - Data gathering and analysis relevant to the needs of conditions of the 21st century Global Knowledge Economy,

  - Working with public and private leaders in building consensus,

  - Managing conflict,

  - Presentation skills,

  - Building and managing networks,

  - Community and economic development in the 1st century,

  - State of the art business and market analysis,

  - Grant writing, and

  - Cutting edge knowledge of public and private resources for community and economic development.

  • Rural regions should have grant-writing support that could be provided by EDDs to respond to opportunities beyond EDA’s program portfolio. EDDs should have additional resources to support this function.

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  1 comment for Idea: CEDS-Economic Development Planning in the 21st Century

  Submitted by Rex LaMore 2 years ago

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  New Grant Process

  I suggest that you return to the rolling submission of grant requests. The new process fails communities that need additional infrastructure in order to land a prospect. Prospects are unwilling to wait until the next submittal deadline to decide if a community can provide adequate water pressure or sewer capacity. The new process also favors mega-projects that would likely suceed without EDA's assistance. Meanwhile, smaller ...more »

  I suggest that you return to the rolling submission of grant requests. The new process fails communities that need additional infrastructure in order to land a prospect. Prospects are unwilling to wait until the next submittal deadline to decide if a community can provide adequate water pressure or sewer capacity. The new process also favors mega-projects that would likely suceed without EDA's assistance. Meanwhile, smaller projects are unable to compete with flashy, high-tech projects even though these projects would have significant impact on the local economy.

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  2 comments for Idea: New Grant Process

  Submitted by Community Member 2 years ago

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  Regional Innovation Clusters (RICs) »

  Importance of Districts

  District representation needs to be very much in the forefront of all grants selected by the Regional Office for funding. You are marginalizing the Districts when you fund projects that aren't on our CEDS.

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  Submitted by Community Member 2 years ago

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  Match

  A 50% match is too burdensome on our communities made EVEN MORE SO with the new rules asking that environmental and engineering be done ahead of time. As I speak with people about potential projects, and they hear the 50% match requirement, almost every time it ends the conversation immediately.

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  Submitted by Community Member 2 years ago

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  Background checks

  the background checks (Form CD346)are intrusive and potentially a problem for elected officials who may be asked to sign. This is the only Federal agency (that we have delt with) who does an FBI background check on grantees. Why make things even more difficult than they already are for someone looking for funding through EDA?

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  Submitted by Community Member 2 years ago

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