Generally, planning costs are activities that support comprehensive planning.

To assist state CDBG-DR grantees in carrying out comprehensive planning initiatives, the Department typically waives the requirements at 24 CFR 570.483(b)(5) and (c)(3). Instead, states must comply with 24 CFR 570.208(d)(4) when funding disaster recovery-assisted, planning only grants, or directly administering planning activities that guide recovery in accordance with the applicable appropriations act. State CDBG-DR grantees can award these “planning-only” grants to units of general local government for studies, analysis, and data gathering.

In addition, the types of planning activities that states may fund or undertake are expanded under the HUD waiver and alternative requirement provided in the Consolidated Notice, to be consistent with those of the CDBG Entitlement program, described at 24 CFR 570.205 which defines planning as “activities which consist of all costs of data gathering, studies, analysis, and preparation of plans and the identification of actions that will implement such plans.” (24 CFR 570.205(a)). These planning activities may include functional land-use plans, open space plans, historic preservation plans, comprehensive plans, community recovery plans, the development of housing codes, zoning ordinances, and neighborhood plans. In the CDBG Entitlement program, these planning activities are presumed to meet a national objective under the requirements at 24 CFR 570.208(d)(4).