NLIHC

• The National Low Income Housing Coalition (NLIHC)
• Founded in 1974
• “Solely dedicated to achieving racially and socially equitable public policy that ensures people with the lowest incomes have quality homes that are accessible and affordable in communities of their choice.”
• Advocates Guide
• The Gap
• Out of Reach

Disaster Housing Recovery Coalition (DHRC)

• An NLIHC-led group of over 900 local, state, and national organizations working to ensure that all disaster survivors receive the assistance they need to fully recover.
• Federal Advocacy
• Info Sharing
• Technical Assistance
• Advocacy Support

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Long-term Recovery

• FEMA is required by law to close its programs 18 months following a disaster (NOTE: This can be extended)
• Obviously, there is still a large amount of recovery left to do – FEMA is not going to get to it all
• FEMA programs are largely built around emergency fixes and repairs – both for infrastructure and for impacted families
• This is where HUD’s Community Development Block Grant – Disaster Recovery (CDBG-DR) comes in

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What is CDBG-DR?

• Since 1992, Congress has approved $100 billion through this program to assist in disaster recovery. It relies on one-off spending bills from Congress
• When funds are approved, HUD looks at FEMA data, disaster impacts, information on housing markets, homelessness, etc… to calculate an area’s “unmet need”
• HUD then allocates out funds based on that number to states, territories, and localities
• Whether a state or a local jurisdiction get it depend on their “administrative capacity” (e.g. it’s ability to handle huge grants like this directly).
• HUD will also identify “Most Impacted and Distressed (MID) Areas” where 80% of the funds must be used – this keeps state governments from redirecting funds to those who need it less.
• Fact sheet

What can it be used for?

How does it work?

• Governments receiving funds need to create an “Action Plan” – this plan details the impacts of the disaster, the needs, and how program funds will be used.
• The government works with “stakeholders” – other agencies and local governments usually, to draft it.
• The action plan then must be up for public review and comment for 30 days.
• If the plan is insufficient, HUD will work with the grantee to fix it and then sign grant agreements providing the funds.

CDBG-DR Timeline

Action Plan – Public Comment Consideration

• Grantee must host public comment on Action Plan or substantial amendment for 30 days
• Any updates or changes made to the action plan in response to comments must be clearly identified
• Summary of comments must be included with the action plan itself
• Grantee must address the substance of the comment rather than merely acknowledging the comment was received

Action Plan – Citizen Advisory Group

• A grantee is required to convene a Citizen Advisory Group composed of individuals from a community who volunteer or are appointed to provide input, advice, and recommendations on the recovery process in their community.
• They are a bridge between the general public and decision makers – offering expertise, perspectives, and insights to help inform and shape decisions that impact the community’s well being.
• A grantee must review policies and procedures with the advisory group at least every year.

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Past Successes

• After tornados in Kentucky comments calling for additional public housing prompted the commonwealth to leverage CDBG-DR and state funds to build nearly 1,000 additional affordable rental units.
• After Hurricane Ian, comments prompted Florida officials to double down on housing construction with $542 million in CDBG-DR funding
• After Hurricane Ida, organizers used the comment process as an opportunity to highlight the need for additional funding – later receiving $149 million in additional funds from Congress.

Changes by Current Administration

• Proposed cutting staff at HUD office overseeing CDBG-DR by 85%
• Changes to program rules that remove:
• Any Civil Rights Certification Requirements
• All but 1 mention of civil rights
• Any requirement that a grantee conduct an analysis of fair housing needs/mention of fair housing
• Any mention of protected classes
• Any language access requirement
• Any reporting information on demographics of applicants/recipients
• Any language directing funds towards “vulnerable” “distressed” or “historically marginalized” communities
• Any mention of climate change
• Any requirement involving Building Codes
• Any requirement involving the Federal Flood Risk Management Standard

Hands Off Housing!

• DOGE Cuts are already happening in HUD Field Offices across the country
• Would reduce HUD CPD by 85%
• The agency would be unable to get disaster funding out the door. $12 billion in the most recent allocation alone!