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City approves pass-through grant funding for Union Bethel church restoration project

City Commissioners voted during their May 6 meeting to approve a pass-through grant for the Union Bethel African Methodist Episcopal Church.

The approval comes after months of discussion as commissioners expressed concern about handling pass-through grants and declined to administer the full $497,712 grant from the U.S. Department of Interior’s National Park Service and its Historic Preservation Fund’s African American Civil Rights grant program that were awarded to the Montana Historical Society for the church project.

Commissioner Shannon Wilson moved to approve the action and Commissioner Rick Tryon seconded.

There was no public comment on the item.

“We kinda hammered this one pretty well,” Mayor Cory Reeves said in asking if there was any further commission discussion.

City delays decision on pass-through funding for Union Bethel AME church restoration project

Wilson said she had concerns with the way grants were being cut lately and asked if the city had skin in the game without the grant already in hand.

Brock Cherry, city planning director, said no and if the grant funding was cut, it would only affect the church.

There was no further commission discussion on the grant and they voted unanimously to approve the pass-through funding.

Sam Long, the city-county historic preservation officer, told The Electric that she didn’t believe the commission’s deliberations delayed the project.

Coupled with the church’s $200,000 grant from the National Trust for Historic Preservation’s Saving Black Churches program, the NPS funds will provide repairs to the failing exterior brick; installation of a new lift to provide access; create ADA-compliant bathrooms; and update the electrical system, according to the Montana Historical Society.

The NPS grant program focuses on preserving sites and stories directly associated with African Americans’ struggles to gain equal rights.

Like many federal grant programs, the grant was temporarily halted earlier this year, but Long said the funds were unfrozen and the specific grant program for the church project is operational.

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The Union Bethel church was built in 1917 at 916 5th Ave. S. and has been listed on the National Register of Historic Places for its significance in the areas of social history, religion and African American heritage.

“The church served as a community center as well as a religious institution and was a meeting place for organizations including the Ladies’ Aid Society, Masonic Lodge, Odd Fellows, and the Dunbar Art and Study Club. The last organization was very active in opposing discrimination and advocating for civil rights in the area. Among many other campaigns, in 1950, a year after the integration of the U.S. armed forces, they worked on an interracial committee to help Black airmen at Malmstrom obtain access to local establishments,” according to city staff.

Last year, the Montana State Historic Preservation Office asked the city to administer the grant to allow more of the grant funding to pass through to the church project since the state is required to take a portion of the grant for administrative costs.

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During a Nov. 19 City Commission work session, Kate Hampton, community preservation coordinator at SHPO, wrote the grant application for the church, said that her office negotiates that rate with NPS annually and the 2024 rate was 23.5 percent, which is a “big chunk of change,” for administrative costs.

During the November meeting, city staff and commissioners expressed some concerns with administering the grant and eventually opted not to serve as the pass-through for the grant.

Instead, SHPO is contracting directly with the church to pass the grant funds to them directly, which requires more administrative work to certify the church with the federal agency.

In February, Hampton told The Electric that the combined grants are about $700,000 for the project, but bids came back much higher, around $1.3 million, so they were scaling back plans and redesigning the project.

Hampton said they had shifted gears a bit and asked the city to pass about $20,000 from other SHPO funding sources through to cover the cost of those redesigns. That project funding was included in the city’s annual certified local government application for historic preservation funding, which was split into two separate applications.

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Hampton sent that proposal to city staff in a Jan. 27 letter.

The Electric reported that plan on Feb. 12, the same day Sam Long, the city-county historic preservation office, told the city-county Historic Preservation Advisory Commission that the application, with the $20,000 pass-through request was scheduled to go before commissioners at their March 4 meeting.

The application was not on the March or April commission agendas.

During their March 18 work session, Tom Hazen, city grants manager, asked commissioners for their thoughts on moving forward.

Commissioners said they wanted more information and weren’t collectively ready to direct city staff to move forward.

During the March 19 city-county Historic Preservation Advisory Commission, Long told the group that there was “some confusion” among city officials and the decision had been delayed.

Mayor Cory Reeves said in March that he was comfortable with the reduced liabilities but “fundamentally disagree with the government being involved in these types of projects, just my own ideologies.”

City finance staff indicated that the pass-through grant was unique and would set a precedent for the city during the March 18 work session, while Long and Brock Cherry, city planning director, said it wasn’t unusual.

“I don’t know how drastic it is participating in this type of process,” Cherry said.

Long, the city’s historic preservation officer, said that her office had done similar pass-through grants in the past as technical assistance grants to multiple properties, including the Arvon Block, and that was the catalyst for the major project that is now the Celtic Cowboy and Arvon Hotel.

Long said the federal funds pass through the state and have to go to a certified local government, which the city is.

If the city opts not to pass the $20,000 through to the Union Bethel restoration project, the money will go to another Montana community, Long said.

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Long, who has been with the city for a few years, said during the March 18 work session that she wasn’t sure of the specific grant rules at the time of those technical assistance funds, which were allocated in 2011-2012, according to multiple city documents, but “we found the liabilities acceptable at that time.”

McKenney asked staff to help settle his “angst” at having been told by staff that the pass-through grant request was unusual and the city had never done it before and then hearing that wasn’t correct and the city had administered similar grants.

In her Jan. 27 letter to city staff, Hampton wrote that commissioners had declined administering the full $497,712 NPS grant as a pass-through due to:

Hampton wrote that the revised request of passing through the $20,000 of state funding toward the church design costs would address those concerns by:

The letter also includes a note that the architectural design firm on the project is a Great Falls firm.

That letter was not included in the March 18 work session materials on the pass-through funding request.

In a Feb. 14 memo to commissioners regarding the revised SHPO request, Hazen wrote that in considering the full NPS grant pass-through request, staff was concerned about precedence.

That memo was also not included in the March 18 work session packet.

Both Hampton’s letter and Hazen’s memo were included in the May 6 meeting packet.

“Generally, the city does not voluntarily act as a pass-through administrative entity. Typical awards received by the city are spent on city projects. Funds that have been received by the city and passed through to private entities are limited to those in which the city has already received the funds (ARPA), those that prioritize distributions to local partners (CDBG), or programs that require municipal participation by law (Big Sky Economic Trust Fund Montana Main Street). The Park Service award did not align with these exceptions,” Hazen wrote.

In his Feb. 14 memo, Hazen wrote that the revised SHPO request to pass through $20,000 in CLG funding for the design portion of the project addressed all of the city’s initial concerns other than precedent.

“It should be stressed that the city did not request the designs or select the designer, nor was the city not party to the original grant application that secured the funding, and, finally, the city is under no statutory pressure to accept this award. The city would be voluntarily accepting an administrative role in this award,” Hazen wrote.

But the precedent differs from the original request to pass through the full $497,000 NPS grant, Hazen wrote, in that the revised proposal didn’t ask the city to front costs and was only distributing funds that would be already in hand.

The revised request also limited monitoring requirements for city staff as they wouldn’t have to ensure the project was complying with federal regulations as they would in the initial request. Instead, city staff will only ensure the costs were incurred and invoiced correctly, according to Hazen’s memo and that review would take city staff about two to three hours.

“Again, there is no denying that this project still establishes a precedent of city involvement in grants to private entities. However, this model does limit the scope of that precedent to awards that issue funding up-front to the city, have limited scopes that impart minimal monitoring requirements, and to allocation sizes that limit the length of performance and amount of city overhead,” Hazen wrote, making the revised request more “palatable” to city staff.

In his agenda report for the May 6 commission meeting, Cherry, city planning director, wrote that the pass-through funding is “the same grant channel that was used to create the 2011-2012 technical assistance program that catalyzed rehabilitations of downtown buildings such as the Arvon Hotel and the Baum-Trinastch Building.”

SHPO is required to pass a percentage of their federal funds through to certified local governments, so if the city declined the passthrough, the funding would go to another community, according to the city planning office.

Cherry wrote that the revised request addressed the commission’s concerns from November.

“At the same time, it should be clearly acknowledged that this proposal reflects a continuing practice of city involvement in providing grant support to private entities, with potential implications for future policy decisions,” Cherry wrote, and it complied with the city growth policy, which identified the need to “establish incentives for the preservation, rehabilitation, and maintenance of historically or architecturally significant properties.”

The growth policy includes an objective to “identify financial resources that may be used to assist in renovating or maintaining qualified properties, resource planning and tourism related to historic appreciation” and a goal of “support[ing] capacity building, grant collaboration and fundraising efforts by the city’s non-profits.”

The administrative burden on city staff should be minimal and include paying up to three invoices from the funds, according to Cherry’s staff report.

Long, the local preservation officer, will have staff time paid through the SHPO annual contribution to that office and finance staff time will be paid through internal service charges, according to city staff.

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