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assistance activities" in your county's 1) unincorporated areas and 2) UGLGs (without consent by UGLG governing bodies). In carrying out its review, OGC Field or Regional Counsel may request and consider information provided by your county, in addition to other relevant information obtained from independent sources. To be qualified as an Urban County, your county must have "essential powers" in its unincorporated areas, at a minimum, per the HCDA of 1974, as amended. This requirement and the quoted language on "essential powers" is in the HCDA of 1974, as amended, and CDBG program regulations on Urban Counties at 24 CFR 570.307, as shown below: • Per Section 102(a)(6)(A)(i) of the HCDA of 1974, as amended, an Urban County must be "authorized under State law to undertake essential community development and housing assistance activities in its unincorporated areas, if any, which are not units of general local government... " Per the Urban Counties regulations at 24 CFR 570.307(b)(1): "the Secretary shall determine which counties have authority to carry out essential community development and housing assistance activities in their included units ofgeneral local government without the consent of the local governing body and which counties must execute cooperation agreements with such units to include them in the urban countg for qualification and grant calculation purposes." NOTE: "Essential powers" are granted (or not granted) by state governments under state laws. Most states only grant counties "essential powers" in unincorporated areas, and not in their UGLGs because UGLGs are granted authority over their jurisdictions. Because most states do not grant their counties "essential powers" in UGLGs, Cooperation Agreements are generally required for all Participating UGLGs that wish to join an Urban County. Joint Agreements are required between Urban Counties and Metropolitan Cities. 15 571