BPC Comments on HUD’s Requests for Information on CDBG-DR
BPC, working with our Disaster Response Reform Task Force, submitted comments in response to two Requests for Information (RFI) that the U.S. Department of Housing and Urban Development (HUD) issued to solicit feedback on:
- Modifying Community Development Block Grant – Disaster Recovery (CDBG-DR) rules, waivers, and alternative requirements to expedite long-term recoveries and address barriers that grantees face in using CDBG-DR funding.
- Refining the methodology used to calculate CDBG-DR allocation amounts.
BPC’s comments provide a set of recommendations to HUD on CDBG-DR rules, waivers, and alternative requirements, emphasized:
- Using HUD’s waiver and alternative requirement authority to implement planning mechanisms that allow for “blue sky” anticipatory planning ahead of future disasters, accelerate CDBG-DR allocations, and allow for an expedited review process;
- Training potential CDBG-DR grantees on grant requirements and other programs that can address unmet recovery needs; and
- Proactively deploying Technical Assistance (TA) resources to put grantees in a position to move quickly once they receive a grant.
In response to the CDBG-DR allocation formula, BPC’s comments emphasized:
- Expediting allocation decisions to account for the critical need for recovery, resilience, and expansion of rental housing in disaster-impacted areas;
- Providing a thorough assessment of overall post-disaster resilience and mitigation needs; and
- Addressing imbalances between single-family per unit damage estimates and the true cost of rebuilding.
BPC continues to support legislative action to achieve a permanent authorization of CDBG-DR, which would allow for a standard set of regulations and procedures across all grant allocations and expedite federal support for disaster survivors and affected communities. Yet recognizing that legislative action may not be imminent, these letters identify key opportunities for HUD to establish a firmer, interim foundation for federal assistance flowing through the CDBG-DR program.
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