Grants

Under DC law, certain expenses are not eligible for grants. These include most meals, refreshments, and travel, lobbying, legal costs other than for representation of the Commission before certain bodies, programs that duplicate DC government programs, and any funds that would directly benefit an individual. 

ANC 7E will review applications as they are submitted and will ask applicants to make a presentation regarding a grant request at an ANC meeting.

ANC 7 E may also solicit proposals and in such instances, will likewise request such applicants to present such a proposal at an ANC meeting. Decisions on grant applications will typically be rendered at the next meeting after a presentation is made. 

Applicants must submit a written application on the form and a representative of the applying organization must also appear in person at the ANC meeting where the application is being considered. Given the time investment in completing an application, potential applicants are encouraged to contact one of the ANC commissioners to learn more about this process, including the scale of grants and the kinds of things for which grants have been given. 

5 specific requirements for grants:

(1) Public Purpose: ANC grants, like other expenditures not for the maintenance of

the ANC office, must be for “public purposes within the Commission area.”11 A

public purpose is one “that benefits the community as a whole and is not done for

the primary purpose of benefitting a private entity.”12 We have explained that this

does not preclude a grantee organization from receiving some indirect benefit

from the grant, as long as the public is the grant’s primary beneficiary.13

(2) Local Benefit: A grant must “benefit persons who work or reside in the

Commission area.”14 This does not mean the grant may only benefit

Commission residents; it simply means the grant’s benefits should be focused on

those residents.15

(3) Proposed Project: A grant must be for a “proposed project.”16 The word

“project” means a grant must be for a specific undertaking, not for general support of an organization, and the word “proposed” means that a grant cannot reimburse an organization for expenses connected to an existing or completed project. 17 

(4) Organization: A grant must be to an “organization,” not an individual or a government entity,18 although the organization need not be incorporated.19 

(5) Non-Duplication: A grant must be for services that are not “duplicative of any that are already performed by the District government.”20 An ANC grant thus cannot fund services that the District government already provides.

Grants must also abide by the limits applicable to ANC expenditures more generally. They thus cannot be for “any purpose that involves partisan political activity, legal expenses other than for Commission representation before an agency, board, or commission of the District government, or travel outside of the Washington metropolitan area.”21

References:

11 Id. § 1-309.13(l)(1). 

12 Id.

 
13 See Letter to Shane Anthony, Dec. 10, 2008, at 2, available at https://oag.dc.gov/sites/default/files/2018-02/ANC4-C-07-December-10-2008-Purchase-of-Electronic-Communication-Equipment.pdf (citing Letter to Philip C. Spalding, July 13, 2005, at 2) (all internet sites last visited April 13, 2022). 

14 D.C. Official Code § 1-309.13(m)(1). 

15 See Letter to Deborah K. Nichols, Nov. 9, 2006, at 2 n.2 (on file) (ANC 4C grant was permissible where “[b]enefit to other ANCs would be incidental to the benefit conferred on ANC 4C residents,” because a grant’s benefits need not “be exclusive to the ANC that gives the grant funds”); see Letter to Comm’r Fletcher, Mar. 15, 2022, at 2, available at https://oag.dc.gov/sites/default/files/2022-03/ANC-7E-Letter-to-Commissioner-Fletcher-RePublic-Purposes-Within-the-Commission-Area-.pdf (making the same point with respect to the public-purpose requirement). 

16 See D.C. Official Code § 1-309.13(m)(2)(A).

17 See Letter to Comm’r Varzi, Dec. 3, 2019, available at https://oag.dc.gov/sites/default/files/2019-12/ANC-4CAfter-the-Fact-Grant.pdf 

18 D.C. Official Code § 1-309.13(m)(1); see Letter to Deborah K. Nichols, Jan. 14, 2010, at 4, available at https://oag.dc.gov/sites/default/files/2018-02/ANC-January-14-2010-Guidelines-for-Use-of-ANC-Funds.pdf (a public school is not an “organization” and therefore cannot receive ANC grants).

19 See Letter to Deborah K. Nichols, Aug., 4, 2000 at 3, available at https://oag.dc.gov/sites/default/files/2018-02/ANC-August-4-2000-Grants-by-ANCs-Public-Purpose-and-Corporate-Status-of-Recipients.pdf (“The plain meaning of the term ‘organization’ includes unincorporated associations”). 

20 D.C. Official Code § 1-309.13(m)(1). The ANC Act does not apply this same restriction to non-grant expenditures. See id. § 1-309.13(l). 

21 Id. § 1-309.13(l)(2).