SECTION 3: Action Plan & Implementation

This section includes guidance on developing a CDBG-DR Action Plan in response to the Consolidated Notice, including steps to take when submitting the required pre-award submissions, the Implementation Plan, and the Public Action Plan. This section also moves into the Implementation phase of projects and activities, and includes relevant guidance on resilience planning and best practices when incorporating mitigation into long-term recovery.

Action Plan Development

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:

  1. An impact and unmet needs assessment to inform the use of the grant;

  2. Description of the connection of programs and projects to the unmet needs;

  3. Descriptions of public housing, affordable rental housing, and housing for vulnerable populations;

  4. Assessment of fair housing using civil rights data and advancing equity;

  5. Description of infrastructure investments;

  6. Description to minimize displacement;

  7. Description of applicable allocation and award caps;

  8. Standards of cost controls and warranties; and

  9. Resilience planning.

Grantees 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

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.

A Guide on How CDBG-DR Grantees Can Meet the Requirements of the Consolidated Notice