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

Public Housing, Affordable Rental Housing, and Housing for Vulnerable Populations

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.

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Critical Partners and Data Tools

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.

The longstanding data sharing agreement between FEMA with HUD and CDBG-DR grantees has been revised to address privacy-related issues 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 latest Individual Assistance program data from FEMA in order to build out their impact and unmet needs assessment, market their programs to potentially impacted individuals, and complete their duplication of benefits analyses for individual benefits. Grantees can view this revised agreement here: HUD & FEMA Data Matching Program Notice More information and guidance on the new data sharing process for CDBG-DR grantees can be found here:

However, 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 serval 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.

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