HUD Publishes Community Development Block Grant Mitigation Notice
The Community Development Block Grant- Mitigation Program is designed to provide assistance in areas affected by recent disasters through funding high-impact activities aimed at reducing future losses from natural hazards. On August 23rd, HUD published the requirements for this new CDBG–MIT Program.
The notice allocates $6.87 billion in mitigation funds to nine states and five localities recovering from 2015, 2016 and 2017 natural disasters. Texas and Louisiana topped the list of states allocated mitigation funding, each receiving more than $1 billion to assist in their recovery efforts. The notice lists out the guidelines for the CDBG-MIT program to enable the grantees to develop and submit for approval their plans and ultimately receive their allocated mitigation funds.
Congress initially appropriated almost $16 billion in mitigation funding for these states in February 2018. Now, more than a year after Congress first approved these dollars, HUD is enabling some of these jurisdictions to access a portion of the funds.
The agency is choosing to withhold funds from Puerto Rico, however, and just recently released specific guidelines for the U.S. Virgin Islands. According to HUD, the separate tracks are due to alleged “fiscal irregularities and financial mismanagement” in Puerto Rico and “capacity issues” in the USVI.
Time line for the submission, review, and approval of action plan
The notice breaks down the timeline for when jurisdictions must submit their action plans to HUD for approval. For state grantees affected by a 2015 or 2016 disaster the submission deadline is February 3, 2020. The states that fall into this category are Florida, Louisiana, North Carolina, South Carolina, Texas, and West Virginia. Local government grantees effected by disasters during those two years must submit on no later than March 2, 2020. States such as California, Georgia and Missouri who were impacted by disasters in 2017 will have to submit their action plans by April 6, 2020. HUD will review each action plan within 60 days from the date of receipt.
Change to the set aside for low-and moderate-income families
One notable change to the most recent notice was the choice to reduce the percent of funds that must principally benefit low- and moderate-income families. In recent CDBG-DR notices the threshold was set at 70 percent. That amount has now been brought down to 50 percent. Disaster recovery funds historically have targeted these communities because research by the federal government makes clear that natural disasters tend to hit low- and moderate-income families the hardest.
Requirement for mitigation needs assessment
This Federal Register Notice also requires grantees to asses the characteristics and impacts of current and future hazards identified through its recovery from the disaster. The mitigation needs assessment will evaluate the potential risk to critical service areas such as communications, food, water, shelter, transportation, health and medical services, hazardous materials, and energy (Power & Fuel). Risk and vulnerability vary among communities so maximizing the use of resources for planning will allow grantees to better comprehend their current and future risk and ensure that this investment of taxpayer dollars will not throw good money after bad.
Plans to minimize displacement and ensure accessibility
HUD also clearly states in this notice that grantees must minimize displacement and ensure accessibility for impacted communities in their pursuit of these mitigation activities. This provision will require grantees to describe how they plan to minimize dislocation of people and assist anyone displaced by their projects. It also calls on grantees to take into consideration the need of people with disabilities in the relocation process.
Other important topics touched on in this notice include the coordination of mitigation projects and leveraging of assets, guidelines for the construction of natural infrastructures projects, as well as detailing certain requirements for building codes. Enterprise is encouraged by this level of investment in pivotal mitigation work that will go a long way in keeping our communities and families safe.