Title
FY2027 Community Development Block Grant (CDBG) Participation Decision - Recommendation to Accept Entitlement Status and Execute a Joint Agreement with Cook County
History
HUD has formally notified Orland Park that we are eligible to become a CDBG Entitlement Metropolitan City for FY2027. The FY2027 planning estimate associated with Entitlement status is $314,985 (final award subject to change as Census data and grantee participation are updated). HUD requires our written program participation decision by August 31, 2026. I recommend that the Village accept Entitlement status and enter into a Joint Agreement with Cook County for FYs 2027-2029 so the County administers our grant, with funds expended only within Orland Park. This approach secures our allocation while minimizing first-year administration burdens and preserving local investment priorities.
Background
On August 11, 2026, we received an email from HUD CPD Program Manager David J. Pray transmitting HUD’s letter and guidance memorandum regarding Orland Park’s potential Entitlement status and required decision timeline.
The attached HUD letter confirms Orland Park’s eligibility and outlines four decision options (accept Entitlement; accept Entitlement with Joint Agreement; defer and remain in the Urban County; defer, opt out of the Urban County, and seek State CDBG). It specifies an August 31, 2026 deadline for our response.
HUD’s memorandum places Orland Park in Category 2 (cities currently participating in Urban Counties that are requalifying now), reiterates the August 31 decision requirement due to Urban County qualification impacts, and lists Orland Park’s planning estimate of $314,985. It also notes Orland Park is a “split place” (partly in Will County) but currently participates only in Cook County’s Urban County program.
Decision Options (per HUD)
1. Accept Entitlement status as an independent Metropolitan City (administer locally).
Orland Park would receive a direct grant and fully administer CDBG (planning, citizen participation, Consolidated Plan/Action Plan, IDIS setup, compliance/monitoring). Planning & administration are capped at 20% of the grant (plus 20% of program income).
2. Accept Entitlement status and enter into a Joint Agreement with Cook County for FYs 2027-2029.
Cook County administers our CDBG grant; Orland Park’s funds must be spent within the Village. This requires a formal joint request to HUD under 24 CFR 570.308 and execution of a Joint Agreement with Cook County.
3. Defer Entitlement status and remain in Cook County’s Urban County (status quo).
We would continue as a Participating UGLG via a Cooperation Agreement for FYs 2027-2029.
4. Defer Entitlement status, opt out of Cook County, and seek State CDBG as a Non-Entitlement.
We would not receive a direct HUD entitlement grant and would compete under the State’s CDBG program.
Analysis for Orland Park
Eligible public improvement projects would likely be limited to the 3 block groups near Village Hall mapped in the attached file that are more than 50% low-moderate income when the program starts up through the County. There could be up to 8-9 of the 31 to 36 block groups that might be included in Orland Park once we become a direct entitlement Metropolitan City. We won’t know exactly which of the other block groups might be included until HUD provides us better guidance: some of our block groups include multiple jurisdictions or both incorporated and unincorporated areas and some of our block groups are in Will County.
Grant funding for projects within eligible areas in Orland Park could include:
1. Public facilities & infrastructure
Examples: ADA curb ramps, sidewalk gap closure, street and lighting upgrades, water/sewer and stormwater improvements, park/playground rehab, and energy-efficiency retrofits in public facilities. The Village has plans for all of these categories.
2. Housing rehabilitation & related activities
Examples: Lead hazard reduction, code-required repairs, and energy efficiency improvements. There are still a few homes in Orland Park that have lead water service lines.
3. Blight remediation, clearance & site preparation
Examples: Demolition of unsafe structures, brownfields remediation, lot clearance and site preparation to eliminate blighting conditions. The Village is finalizing plans for demolition of three existing, long-term structures - the former El Cortez, the former bus barn, and the former Prairie House.
4. Local economic development & small business support
Examples: Microenterprise assistance (training, working capital, equipment), façade improvements, revolving or gap-financing loans/grants that create or retain LMI jobs, business incubator build-out. Covered under HUD’s “Special Economic Development Activities” and “Microenterprise Assistance” categories. The Village is reviewing ways to encourage façade improvements.
5. Public services
Examples: Senior services, crime prevention/public safety, health and mental health services, and recreation programs. It is planned that the future Eastern Field House will have senior specific elements. As far as public safety, funds could be used for the continued build-out of the new Emergency Management Agency. For mental health services, funds could be used for the annual Care Solace expenses.
6. Acquisition & disposition for community purposes
Examples: Acquire strategic parcels for parks, community facilities, right-of-way, or redevelopment; and dispose/manage acquired property until redevelopment.
Timing & Regulatory Compliance:
- HUD requires our written decision by August 31, 2026 (Category 2). Delay risks County qualification complications and missed participation for FY2027.
- New entitlement grantees must establish a program year (HUD recommends July-October starts for first-year grantees), adopt a Citizen Participation Plan, and prepare a Consolidated Plan/Annual Action Plan in IDIS/eCon Planning Suite. Failure to submit plans by federal deadlines can result in loss of funding for that year.
Capacity & Administrative Considerations:
- Independent administration (Option 1) requires immediate staffing/consultant procurement, IDIS onboarding, and robust compliance/monitoring. Planning/administration costs are limited to 20%, which-based on the planning estimate-equates to approximately $63,000 available for first-year administrative functions.
- A Joint Agreement (Option 2) leverages Cook County’s established infrastructure while safeguarding that Orland Park’s allocation is spent within our jurisdiction and aligned with local priorities.
Geography & Use of Funds:
- CDBG funds should primarily benefit within Village boundaries; using funds outside requires documentation under 24 CFR 570.309 demonstrating Village benefit and program purpose.
Financial Planning Flexibility:
- HUD allows pre-award costs for preparation activities (Citizen Participation Plan, Consolidated Plan/Action Plan) under 24 CFR 570.200(h), if properly noticed and compliant-valuable if we proceed with any local planning work immediately.
Recommendation
Accept Entitlement status for FY2027 and execute a Joint Agreement with Cook County for FYs 2027-2029. This path secures the Village’s allocation (planning estimate $314,985) and minimizes near-term administrative burden by employing the County’s established systems, while ensuring expenditures are restricted to Orland Park projects. It positions us to direct funding to our priorities with lower startup risk, meets HUD’s August 31 deadline, and avoids disruptions to Urban County qualification.
Action Requested
1. Authorize the Village Manager to transmit Orland Park’s written decision to HUD by August 31, 2026 and to submit the required joint request under 24 CFR 570.308.
2. Authorize negotiation and execution of a Joint Agreement with Cook County specifying administration roles, reporting visibility, project selection coordination, and timelines for FYs 2027-2029.
3. Direct staff to begin local priority setting and community engagement consistent with Citizen Participation requirements so Village priorities drive the Orland Park-dedicated allocation administered by the County.
Financial Impact
The financial impact for the Village of Orland Park involves an estimated $314,985 in direct federal grant revenue for Fiscal Year 2027 through CDBG Entitlement status. While independent local administration would cap overhead expenses at 20% (roughly $63,000), opting for a Joint Agreement with Cook County allows the Village to bypass heavy startup, software, and staffing overhead while ensuring the entire allocation goes toward local projects. Additionally, HUD pre-award cost regulations enable the Village to safely finance initial preparatory tasks without risking non-reimbursable expenses, provided compliance guidelines are met.
Recommended Action/Motion
I move to pursue CDBG Entitlement Metropolitan City status and approve entering into a Joint Agreement with Cook County regarding the CDBG Entitlement status;
AND
To authorize the Village Manager to execute all necessary documents, subject to Village Attorney review.