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

Impact and Unmet Needs Assessment

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.

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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 in a reasonably proportional manner. Other considerations for the impact and unmet needs assessment are estimating which needs are likely to be addressed by other funding sources (e.g., projected FEMA funds and estimated insurance) and whether public services (e.g., housing counseling, legal advice and representation, job training, mental health, and general health services) are necessary for recovery and how those services would need to be made accessible to individuals with disabilities including, but not limited to, mobility, sensory, developmental, emotional, cognitive, and other impairments.

Grantees must also take into account the costs and benefits of incorporating hazard mitigation measures to protect against the specific identified impacts of future extreme weather events and other natural hazards. This analysis should factor in historical and projected data on risk that incorporates best available science (e.g., the most recent National Climate Assessment). Grantees can also access additional tools through HUD’s Community Resilience Toolkit.

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