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A State grantee is required to include in its Implementation Plan how it will provide technical assistance and fill the knowledge gaps for successful and timely recovery. The Consolidated Notice establishes that the aggregate total for administrative and technical assistance expenditures must not exceed 5 percent of the grant plus program income.
There are two ways a state may provide technical assistance under CDBG-DR, depending on the purpose of the technical assistance activity. The grantee may provide technical assistance to increase the capacity of an entity carrying out an eligible activity that will meet a national objective or as part of its administrative costs set aside to support technical assistance and capacity building.
When a state grantee is providing technical assistance, the grantee should consider if a national objective will be met once the entity receiving technical assistance has undertaken the activity. The grantee should consider the following factors:
The nature of the organization receiving the assistance;
The type and eligibility of the activity to be carried out;
The location of the activity; and
The entity’s expected clientele.
classify its technical
assistance as an
administrative cost, the
activity will not be
required to meet a
national objective. The
methods for providing
technical assistance to
an entity should be
described in its action
plan and should be
identified in the
grantees budget table.
The action plan for disaster recovery describes the proposed use of all funds, including the criteria for eligibility and how the uses address disaster relief and recovery in the most impacted and distressed areas. The action plan is made up of the following elements:
An impact and unmet needs assessment to inform the use of the grant;
Description of the connection of programs and projects to the unmet needs;
Descriptions of public housing, affordable rental housing, and housing for vulnerable populations;
Assessment of fair housing using civil rights data and advancing equity;
Description of infrastructure investments;
Description to minimize displacement;
Description of applicable allocation and award caps;
Standards of cost controls and warranties; and
are encouraged to incorporate
disaster-recovery needs into
their consolidated plan updates
as soon as practicable. HUD has
issued guidance for
incorporating CDBG-DR funds into
consolidated plans via
HUD’s eCon Planning Suite.
This guidance has been recently
updated and posted to HUD.gov.
Additionally, CDBG-DR funds may be used to reimburse allowable pre-agreement costs incurred by the grantee, its recipients or subrecipients (including Indian tribes and PHAs) on or after the incident date of the covered disaster, which can include eligible costs to develop an action plan. However, grantees must include any pre-agreement activities in their action plan once submitted, including any costs of eligible activities that were funded with short-term loans.
As part of the action plan, grantees must develop an impact and unmet needs assessment to understand the type and location of community needs and to target limited resources to the areas with the greatest need. The ultimate goal of the impact and unmet needs assessment is for the grantee to tell their community’s story and demonstrate that the proposed use of funds will be responsive to the actual community needs.
At a minimum, the impact and unmet needs assessment must evaluate all aspects of recovery, including housing, infrastructure, and economic revitalization. For housing, the assessment must evaluate:
Interim vs permanent housing,
Owner vs rental housing,
Single vs multifamily units,
Affordable vs market rate units, and
Housing needs of persons who were homeless before the disaster.
An evaluation of each category is necessary to determine what the community’s needs are and propose assistance that is responsive to the needs identified. Other considerations for the impact and unmet needs assessment are estimating which needs are likely to be addressed by other funding sources, whether public services are necessary for recovery, and the costs of incorporating hazard mitigation measures. For any planning activities, the grantee must describe how the activity will benefit the HUD-identified MID areas. All disaster impacts should be described geographically by type at the lowest level practicable.
The action plan must provide a clear connection between a grantee’s impact and unmet needs assessment and its proposed use of funds in the MID areas. The proposed use of funds should demonstrate a reasonably proportionate allocation of resources relative to areas and categories of greatest need or provide an acceptable justification for a disproportional allocation.
It is important that the grantee analyzes and describes unmet need in various housing categories. To successfully analyze each type of housing, the grantee should coordinate with local public housing authorities (PHAs), State Housing Finance agencies, and other HUD-funded programs (e.g., Section 8 Housing Choice Voucher Program, HOME, ESG, etc.) in the MID areas. When evaluating housing for vulnerable populations, the grantee must describe how CDBG-DR funds (or other sources) will promote housing and address transitional housing, prevention measures to keep LMI families from becoming homeless, and special needs of persons who require supportive housing.
Key agencies that may be helpful in developing the impact and unmet needs assessment are FEMA, the U.S. Department of Transportation and Federal Highway Administration for transportation issues, the U.S. Small Business Administration, the U.S. Census Bureau, the U.S. Department of Agriculture, the U.S. Department of Labor, state departments of transportation, housing, community development, and housing finance agencies.
between FEMA with HUD
and CDBG-DR grantees has
been revised to address
identified in the
applicable FEMA System
of Records Notices
(SORN). HUD worked with
FEMA on a computer
matching agreement (CMA)
to ensure that HUD
grantees will get the
Assistance program data
from FEMA in order to
build out their impact
and unmet needs
assessment, market their
programs to potentially
and complete their
duplication of benefits
analyses for individual
benefits. Grantees can
view this revised
agreement here: HUD
& FEMA Data
information and guidance
on the new data sharing
process for CDBG-DR
grantees can be found
multiple entities collect data
after a disaster occurs and may
provide assistance. CDBG-DR
grantees typically think of
Federal sources such as FEMA,
SBA, and the U.S. Army Corps of
Engineers due to the nature of
their programs. However,
grantees may also find that the
U.S. Department of
Agriculture’s Data and
Statistics Agency and Farm
Services Agency may provide
valuable data that can be
incorporated into the
grantee’s unmet needs
assessment, depending on the
type of the disaster and the
disaster-damage. The U.S.
Department of Labor also has
disaster unemployment assistance
data that can be used to further
inform the data collected and is
often not considered in the
unmet needs assessment.
Additionally, there are other
agencies and bureaus that can
provide information when looking
to compare the pre-disaster and
post-disaster conditions. For
example, the National Oceanic
and Atmospheric Administration
is a bureau within the
Department of Commerce that aims
to understand and predict
changes in climate, weather,
oceans, and coasts. They have
several tools and resources
available on their website
that can be used when developing
the unmet needs assessment.
Grantees are reminded that data for disaster assistance is also being collected by national and local aid organizations, state insurance providers, public transit providers, local utility companies, and local universities. To collect all necessary data, grantees should establish data exchanges with these types of entities to assist in determining the necessary and reasonable amount of assistance that has been, and potentially will be, provided. To facilitate the process, grantees are encouraged to involve community leaders in the process, execute data sharing agreements with key agencies, and to the extent possible, use existing systems to collect, store and protect data.
Additionally, grantees are encouraged to update their impact and unmet needs assessment on a regular basis to reflect how the recovery needs are evolving over time and if any additional resources have become available.