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a metropolitan area, which has a population of 50,000 or more. Any city that was classified <br />as a Metropolitan City for at least two years shall remain classified as a Metropolitan City. <br />Metropolitan Cities are eligible to directly receive annual CDBG formula grant funding, <br />which is why they are considered CDBG Entitlements. <br />Non -Entitlement Area: An UGLG which is not a Metropolitan City or part of an Urban County <br />and does not include Indian Tribes. Non -Entitlement Areas are UGLGs (smaller cities and lower - <br />population counties that cannot qualify as Urban Counties). Non -Entitlement Areas are eligible <br />to seek State CDBG Program funding and that process varies based on each state's "method <br />of distribution." <br />Nonparticipating UGLGs: UGLGs in an Urban County that have chosen not to participate in <br />the Urban County's CDBG program. Nonparticipating UGLGs can join an Urban County each <br />year during the Urban County Qualification Process. If a Nonparticipating UGLG wishes to <br />join an Urban County, in general they must authorize and execute a Cooperation Agreement <br />with the Urban County (unless the county has Essential Powers in UGLGs). Nonparticipating <br />UGLGs may also be considered Non -Entitlement Areas. Nonparticipating UGLGs may seek <br />State CDBG Program funding (process varies based on each state's "method of distribution"). <br />OGC Field or Regional Counsel: Attorneys in HUD's field and regional offices. HUD's Office <br />of General Counsel (OGC) provides legal opinions, advice, and services for all HUD programs <br />and activities. During Urban County qualification, OGC Field or Regional Counsel must review <br />Cooperation Agreements, Joint Agreements, and County Counsel Legal Opinion Letters and <br />certify that the Cooperation and/or Joint Agreements are legally sufficient for the purposes of <br />Urban County qualification and the CDBG program. OGC Field or Regional Counsel also <br />complete the Determination of Essential Powers. <br />Participating UGLGs: UGLGs in an Urban County that have chosen to participate in the Urban <br />County's CDBG program. An UGLG can join an Urban County any year of the Urban County's <br />Qualification Period (during the spring and summer months when the Urban County Qualification <br />Process occurs). But once an UGLG joins an Urban County as a Participating UGLG, they must <br />remain part of the Urban County for the remainder of that Urban County Qualification Period. <br />Essentially, they are locked into that CDBG program participation decision for 1-3 years based <br />on when they join. In general, Participating UGLGs must execute a Cooperation Agreement <br />(unless their Urban County has Essential Powers in UGLGs). Metropolitan Cities may also <br />become Participating UGLGs by Relinquishing CDBG Entitlement Status and executing a <br />Cooperation Agreement with the Urban County, if necessary. <br />Principal City: A specific type of Metropolitan City, as defined in Sec. 102(a)(4) of the HCDA <br />of 1974. Congress originally used the term "central city" in the HCDA of 1974: "a city within a <br />metropolitan area which is the central city of such area." In 2003, OMB replaced "central city" <br />with "principal city." HUD changed CDBG regulations to ensure the definition of Metropolitan <br />City for the CDBG program was consistent with OMB's use of Principal City. OMB periodically <br />re -designates Principal Cities in bulletins updating their designations of metropolitan statistical <br />37 <br />593 <br />