Urban Counties

What are Urban Counties?

Counties in a metropolitan area that qualify to directly receive Community Development Block Grant (CDBG) funding because they meet a population threshold. In general, the population threshold is 200,000, and it must exclude the population in the county’s Metropolitan Cities. A county that has a minimum population of 200,000 may also qualify as an Urban County if its unincorporated areas and participating units of general local government (UGLGs), in total, contain the majority of low and moderate income residents in the county (called the “preponderance test”). See Section 102(a)(6) of the Housing and Community Development Act (HCDA) of 1974, as amended, for the official definition of an Urban County.

Urban Counties are entitlement communities under the CDBG Entitlement Program, and must be qualified by HUD every three years in accordance with:

  • Section 102(d) of the Housing and Community Development Act of 1974 (HCDA) (42 U.S.C. 5301 et seq.) and
  • 24 CFR § 570.307(d) of the CDBG regulations.

How many Urban Counties are there?

There are currently 198 Urban Counties.

What HUD programs do Urban Counties administer?

Three HUD programs apply in Urban Counties:
  1. CDBG Entitlement Program
  2. HOME Investment Partnerships (HOME) Program (if the county receives HOME funding)
  3. Emergency Shelter Grants (ESG) Program (if the county receives ESG funding)

How do Urban Counties work?

In general, Urban Counties function the same as Metropolitan Cities, the other type of CDBG Entitlement community. Two key differences are: 1) Urban Counties operate at a larger geographic scale (county-wide) and 2) Urban Counties are made up of the county government itself, its unincorporated areas, and units of general local government (UGLGs) in the county that choose to participate in the Urban County.

Urban Counties may carry out community development and housing assistance activities in unincorporated areas of the county and in participating UGLGs (by executing a “cooperation agreement” with UGLGs).

Urban Counties may choose to award CDBG funds to participating UGLGs to independently carry out eligible activities in their UGLG or the Urban County may carry out activities on behalf of the UGLG. As an Entitlement grantee, Urban Counties have all the rights and responsibilities for administering their CDBG grant according to the HCDA of 1974 and CDBG regulations at 24 CFR § 570.501(b).

Who can I contact with questions?

Urban Counties, and other local governments participating in Urban Counties, are encouraged to contact their CPD Representative or CPD field office with questions about Urban County qualification.

The CPD Entitlement Communities Division at HUD Headquarters may also be reached via email at urbancounties@hud.gov.