Action Plan Development 1 The big picture A CDBG disaster recovery - - PowerPoint PPT Presentation

Action Plan Development

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A CDBG disaster recovery grantee must:

 Step 1: Determine the effects of the disaster  Step 2: Develop a plan to respond to the most critical disaster recovery needs not addressed by other resources  Step 3: Implement the plan; ensure activities are completed in an efficient & timely manner

The “big picture”

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 Address Step 1 (effects of disaster)  Address Step 2 (plan development)

Goals of this Presentation

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A beach house struck by Hurricane Sandy Bayville, New Jersey

 The Disaster Relief Appropriations Act, 2013 (Pub. L. 113–2, approved January 29, 2013)  The Department’s Federal Register Notice– 78 FR 14329 (published March 5, 2013)  The Action Plan Checklist– a guide to assist grantees and Action Plan reviewers

References / Useful Tool

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Step 1: Assess recovery needs post-disaster

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 An evaluation of disaster-related impacts

• n a state, city, and community

 At a minimum, must evaluate three core aspects of recovery:

 housing  infrastructure  the economy

Needs assessment

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 Housing

 Evaluate the needs for interim and permanent, owner and rental, single family and multifamily, affordable and market rate, including public and HUD-assisted housing and housing for the homeless

 Infrastructure

 Evaluate the needs for restoration of roads, bridges, or

• ther public structures

 Economy

 Evaluate estimated job losses or revenue loss

Needs assessment

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 Also take into account other assistance available, or likely to be available, for affected communities and individuals

 E.g., FEMA funds available for public infrastructure, or insurance funds available for homeowner rehabilitation

 Why? Disaster recovery resources are scarce; ensure CDBG disaster recovery funds meet critical, unaddressed needs

Needs assessment

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Use the best available data to:

 Identify & document needs  Allocate CDBG disaster recovery funds  Illustrate the connection between the recovery needs and the allocation of funds

Purpose

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 Disaster recovery needs evolve over time, the needs assessment (and Action Plan) may need to be updated periodically  Contact FEMA/SBA for additional unmet housing and business needs data

Evolving Recovery Needs

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Step 2: Develop a CDBG Disaster Recovery Action Plan

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 Using needs assessment, ascertain what types

• f activities or programs will best address the

grantee’s (unmet) recovery needs

 Get as much input as possible– reach out to affected communities and citizens  Talk to existing grantees– what worked well in

• ther communities? What didn’t work so well?

Research

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 All activities must clearly address an impact and show a tie to the disaster  Each activity must:

 be CDBG eligible (or receive a waiver),  meet a national objective, and  address a direct or indirect impact from the disaster in a Presidentially-declared county identified in the Notice

Allowable activities

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 105(a) of the Housing & Community Development Act (HCDA) of 1974

http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/co mmunitydevelopment/rulesandregs/laws/sec5305#sec5305(a)

 Guide to National Objectives and Eligible Activities for State CDBG Programs

http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/co mmunitydevelopment/library/stateguide

 Guide to National Objectives and Eligible Activities for Entitlement Communities

http://portal.hud.gov/hudportal/HUD?src=/program_offices/comm_planning/co mmunitydevelopment/library/deskguid

Eligible CDBG activities– links

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 The grantee must document that each eligible activity meets a national objective–

 Benefits low- and moderate-income persons, or  Addresses an urgent need, or  Aids in the prevention or elimination of slums or blight

 For an in-depth discussion of national

• bjective, see the Guide to National

Objectives and Eligible Activities

National Objective

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 The grantee must also demonstrate how each activity and program is tied to the disaster

 Both the Action Plan and individual activity files should document the connection

Tie to the disaster

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A residence badly damaged by Hurricane Sandy Leonardo, New Jersey

 Local government grantees carry out activities directly  State grantees must determine whether to:

 Use a method of distribution, or  Carry out activities directly, or  Use a combination of the above

Ways to distribute funds

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 State grantees may award funds to local governments based on damage estimates

 i.e., could use a method to distribute funds for an infrastructure or housing project or activity

 May use a method of distribution for all funds, but should ensure that method will adequately address needs identified by the assessment

Method of distribution

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 Pros

 Quickly get funds to local governments  Local governments have flexibility to determine most critical needs

 Cons

 Strictly competitive method may lack a clear connection between activities and recovery needs  Requires significant oversight to ensure funds comply with applicable state and Federal laws, regulations, and Federal Register notices

Method of distribution

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 Grantees (including states) can design and carry

• ut activities directly

 Typically, this means the grantee develops the activity/program, reviews submitted applications, monitors applicants, etc.  Can use a subrecipient or procure a contractor, but grantee remains responsible for inherently governmental responsibilities related to management of the funds (e.g., oversight, policy development, and financial management)

Direct implementation

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 Pros

 Able to develop and implement specific activities/ programs that are narrowly tailored to meet identified recovery needs  More oversight of CDBG disaster recovery funds– less risk

• f fraud, abuse, or waste

 Cons

 Significant capacity needed to design and implement programs directly; may delay initial expenditures and could increase administration expenses if not properly executed

Direct implementation

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 State grantees may design an activity/ program (or several) and use a method of distribution to award funds to units of local government

 E.g., Ohio designs an economic development program; uses a method of distribution to award funds to eligible local governments

Combination

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 Pros

 Able to develop and implement specific activities/ programs that are narrowly tailored to meet identified recovery needs  Units of local government are responsible for day-to- day administration of specific recovery activities

 Cons

 May be a disconnect between the state and the units

• f local government if they fail to maintain open and

continuous communication

Combination

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 Prior to formal submission to HUD, the grantee must post the Action Plan for public comment for a minimum of 7 days  Action Plan submitted to HUD must address all comments received through the public comment period

Citizen participation

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 Once the published Action Plan is accepted by HUD, the grantee may enter information from the plan into the Disaster Recovery and Grant Reporting System (DRGR)  HUD will review the DRGR Action Plan; when approved, funds will be made available for use

DRGR Action Plan

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 Key difference between published Action Plan and DRGR Action Plan:

 Published plan provides detailed information regarding the needs assessment, general requirements applicable to the CDBG disaster recovery award, and rules for each program developed by the grantee  DRGR plan provides greater specificity for measuring performance of individual activities

DRGR Action Plan

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 Each activity must identify “start” and “end” dates

 Although standard CDBG timeliness requirements are waived (24 CFR 570.494 and 570.902), grantees must still ensure activities are completed in accordance with their performance measures  The Appropriations Act requires grantees to expend funds within 2 years of the date HUD signs a grant agreement with the grantee

DRGR Action Plan

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 The Action Plan must be updated to include the grantee’s expected performance (i.e., expenditures and outcomes) each quarter  The Action Plan must also include a projected expenditure schedule for the entire grant  Guidance is available on the CDBG Disaster Recovery website

Performance Schedule

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 Each grantee receiving an allocation under the Notice must submit an Action Plan within 90 days of the effective date of the Notice

Action Plan submission

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 Section 104(e)(1) of the HCDA requires HUD to determine whether the grantee has carried

• ut its activities in a timely manner

 The Department will, absent substantial evidence to the contrary, deem a grantee to be carrying out its programs and activities in a timely manner if its performance schedule is substantially met

Timeliness

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 CDBG Disaster Recovery website:

http://www.hud.gov/offices/cpd/communitydevelopment/ programs/drsi/index.cfm

 Includes:

 Supplemental appropriations laws  Federal Register notices  Contact information, Action Plans and Quarterly Performance Reports for CDBG disaster recovery grantees

 Peer CDBG-DR grantees  Your HUD CPD representative

Resources

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Questions?

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