FY2024 Data Update for Low- and Moderate-Income (LMI) Area Benefit Designation for HUD's Indian Community Development Block Grant (ICDBG)

ICDBG applicants who are proposing projects with an area-wide benefit must provide information about the beneficiaries of those projects (NOFO Rating Factor 2). To allow maximum flexibility under 24 CFR 1003.208(a)(3), HUD permits applicants to choose from multiple sources of LMI data for the purposes of determining low- and moderate-income (LMI) benefit areas. The applicant then presents the highest LMI percentage in their ICDBG application.

Option 1

ICDBG applicants may choose from three different aggregations of the American Community Survey (ACS) for estimating the LMI benefit area at the TRIBAL AREA geography.

1. Estimate of the percent of people that are LMI
2. Estimate of the percent of households that are headed by an “AIAN alone” person (or spouse of the head of household) that are LMI
3. Estimate of the percent of households that are headed by an “AIAN alone or in combination with another race” person (or spouse of the head of household) that are LMI

All tribal area estimates can be downloaded here. (Note that only tribes with federally-recognized reservation or off-reservation trust land that has been incorporated into Census geographies will appear on this Option 1 list. If data is not showing for your tribe, you will need to self-define the service area of your ICDBG project and use Option 2 or Option 3 (below) to establish LMI percentages.)

Option 2

ICDBG applicants may also use custom tabulations of the ACS that designate LMI qualifying CENSUS TRACTS. Only households that are headed by a person who is AIAN alone or AIAN in-combination with other races are included in this dataset. Tract-level LMI estimates can be downloaded here.

Option 3

In lieu of using the special AIAN LMI data provided above, ICDBG applicants may use the same criteria, data, and methods used by HUD’s Community Development Block Grant (CDBG) program to determine LMI benefit areas at the neighborhood level. For ICDBG applicants choosing this option, HUD’s newest CDBG LMI data, which is also drawn from the ACS at the CENSUS BLOCK GROUP level, can be downloaded here.

Any one of these LMI datasets may be used by ICDBG applicants to determine if proposed projects meet the primary objective of the program. These datasets will also be used by Area ONAP staff when measuring LMI need in rating factor 2 of the ICDBG Notice of Funding Opportunity (NOFO) for public facility and improvement projects as well as economic development projects.

Tips for Using the LMI Data

The latest versions of LMI data all include data dictionaries (see “Dictionary” tab within each file) for improved clarity.

In many instances, the proposed service areas for ICDBG-funded activities will not be perfectly represented by individual Census geographies as presented in the linked tables above. In such cases, applicants should aggregate (add) the LMI estimates from two or more geographic units. To calculate accurate estimates of the percentage of LMI persons (or households) in such combined areas, add the estimated number of LMI persons (or households) and divide by the sum of the total number of persons (or households) in the combined areas. (Do not try to average the LMI percentages.)

For example, an applicant is proposing a project that will serve all of Winston County, Alabama, which consists of 8 census tracts. The applicant can use the tract-level LMI data (the Option 2 table linked above) to calculate county-level LMI percentages for either:

1. All households with a householder who identifies as AIAN alone; or
2. All households with a householder who identifies as AIAN alone or AIAN in combination with one or more other races.

Column D	E	F	G	H	I	J	K	L	M
Households that are AIAN alone	AIAN alone households that are LMI	% of AIAN alone households that are LMI	Households that are AIAN alone or in combination w/ another race	AIAN alone or in combination w/ another race households that are LMI	% of AIAN alone or in combination w/ another race households that are LMI	State	County	Tract	AIAN
4	0	0	14	4	28.6	01	133	965501	9999
0	0	0	0	0	0	01	133	965502	9999
10	10	100	30	14	46.7	01	133	965503	9999
30	30	100	55	49	89.1	01	133	965601	9999
0	0	0	0	0	0	01	133	965602	9999
0	0	0	0	0	0	01	133	965700	9999
0	0	0	30	20	66.7	01	133	965800	9999
0	0	0	0	0	0	01	133	965900	9999

For the first calculation, the county-level LMI percentage is the sum of the AIAN alone households that are LMI (Column E) divided by the total number of households that are AIAN alone (sum of Column D). In this case, 40 divided by 44, or 90.9%.

For the second calculation, the LMI percentage is the sum of the AIAN alone or in combination with another race households that are LMI (Column H) divided by the total number of households in that race category (Column G). In this example, the LMI percentage is 87 divided by 129, or 67.4%.

A similar process can be used for combining block group-level data in Option 3 (above).

Alternative LMI Data

ICDBG applicants who feel that the CDBG LMI tables or the special AIAN tabulations do not accurately measure the LMI needs in their area or that census boundaries do not coincide sufficiently well with their service area may propose alternative survey data to HUD as further outlined in 24 CFR 1003.208(a)(3) and the NOFO. HUD will accept such data if it determines that the survey was conducted in such a manner that the results meet standards of statistical reliability. ICDBG applicants may submit data that are unpublished, not generally available, and not older than the latest data available from the U.S. Census Bureau. As explained in the NOFO, if applicants choose to submit demographic data other than that available from the U.S. Census Bureau the application must contain a statement that all of the following criteria have been met:

• Generally available published data are substantially inaccurate or incomplete;
• Data that you submit have been collected systematically and are statistically reliable;
• Data are, to the greatest extent feasible, independently verifiable; and
• Data differentiate between reservation and BIA service area populations, when applicable.

The data accompanying the statement must identify the total number of persons benefiting from the project and the total number of low- and moderate-income persons benefiting from the project. To be considered, supporting documentation must include all of the following: a sample copy of a survey form, an explanation of the methods used to collect the data and a listing of incomes by household including household size.

Refer to the NOFO for a definitive list of requirements for submitting your own data.