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

Action Plan Development 1

The “big picture” 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 2

Goals of this Presentation  Address Step 1 (effects of disaster)  Address Step 2 (plan development) A beach house struck by Hurricane Sandy Bayville, New Jersey 3

References / Useful Tool  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 4

Step 1: Assess recovery needs post-disaster 5

Needs assessment  An evaluation of disaster-related impacts on a state, city, and community  At a minimum, must evaluate three core aspects of recovery:  housing  infrastructure  the economy 6

Needs assessment  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 other public structures  Economy  Evaluate estimated job losses or revenue loss 7

Needs assessment  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 8

Purpose 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 9

Evolving Recovery Needs  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 10

Step 2: Develop a CDBG Disaster Recovery Action Plan 11

Research  Using needs assessment, ascertain what types of 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 other communities? What didn’t work so well? 12

Allowable activities  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 13

Eligible CDBG activities – links  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 14

National Objective  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 objective, see the Guide to National Objectives and Eligible Activities 15

Tie to the disaster  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 A residence badly damaged by Hurricane Sandy Leonardo, New Jersey 16

Ways to distribute funds  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 17

Method of distribution  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 18

Method of distribution  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 19

Direct implementation  Grantees (including states) can design and carry out 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) 20

Direct implementation  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 of 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 21

Combination  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 22

Combination  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 of local government if they fail to maintain open and continuous communication 23

Citizen participation  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 24

DRGR Action Plan  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 25

DRGR Action Plan  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 26

DRGR Action Plan  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 27

Performance Schedule  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 28

Action Plan submission  Each grantee receiving an allocation under the Notice must submit an Action Plan within 90 days of the effective date of the Notice 29

Timeliness  Section 104(e)(1) of the HCDA requires HUD to determine whether the grantee has carried out 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 30

Resources  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 31