In order to receive program funds administered by the Office of Community Planning and Development (CPD) of the Department of Housing and Urban Development (HUD), jurisdictions must submit planning, application and monitoring documents to HUD. Previously each CPD program had its own planning requirements, including the HOME Investment Partnerships (HOME) program’s Comprehensive Housing Affordability Strategy (CHAS). In January 1995, HUD replaced its regulations for the CHAS with a final Consolidated Planning Submission Requirements rule, consolidating into a single submission the planning and application requirements of the Community Development Block Grant (CDBG), Emergency Shelter Grant (ESG), HOME Investment Partnerships (HOME), and Housing Opportunities for Persons with AIDS (HOWPA) formula programs. The Consolidated Plan rule also replaces the CHAS and four program performance reports with one performance report.
Rural communities and the organizations that serve them generally receive HUD CPD program funds through their states. Applications for nearly all existing HUD programs must be consistent with a state’s HUD-approved Consolidated Plan. States are also expected to use their Consolidated Planning processes as public participation tools for planning for the use of state-generated housing and community development funds.
One of the most important things to note about the Consolidated Plan is that it is both a plan and a process. Housing development organizations should not only be familiar with their states’ existing Consolidated Plans, but involved in the formulation of future plans.
CITIZEN PARTICIPATION AND THE CONSOLIDATED PLANNING PROCESS
HUD’s January 5, 1995 final rule on the Consolidated Plan includes planning process regulations by which all participating jurisdictions must abide. States must submit complete Consolidated Plans every five years and updates and performance reports annually. The annual performance report assesses state performance in meeting overall priorities and objectives and identifies the housing and community development resources available within the state.
HUD regulations establish minimum citizen participation requirements for the Consolidated Plan process. While drafting a Consolidated Plan or annual update the state must consult with other public and private agencies that provide assisted housing, health services, and/or social services. The regulations also require that every state adopt a citizen participation plan, which sets forth the state’s policies and procedures for citizen participation and acts as a set of rules that govern the planning process.
HUD requires each state’s citizen participation plan to “provide for and encourage citizens . . . to participate in the development of the consolidated plan, any substantial amendments to the consolidated plan, and the performance report.” Regulations require states “to take whatever actions are appropriate” to encourage the participation of all citizens, including minorities and non-English speaking persons, as well as persons with disabilities.
States must hold public hearings every year to obtain citizens’ views and to respond to proposals and questions. The hearings must address housing and community development needs, proposed activities, and review of program performance. At least one hearing must be held before the proposed Consolidated Plan is published for comment.
States must provide at least 30 days for comments from citizens on the Consolidated Plan and any substantial amendments. Each citizen participation plan must specify what changes constitute a substantial amendment to the state’s plan and the actual use of the block grants. For the annual performance report, states must provide at least 15 days to receive comments. Regulations also require the state to consider any comments or views of citizens received in writing, or orally at the public hearings, in preparing the final Consolidated Plan. A summary of these comments or views, and a summary of any comments or views not accepted and the reasons therefore, must be included in the final plan, substantial amendments, and performance reports.
The citizen participation plan also describes how the jurisdiction will take the required step of publishing a proposed Consolidated Plan in a manner that affords citizens, public agencies, and other interested parties a reasonable opportunity to examine its contents and to submit comments. Summaries of the proposed plan must be published in a newspaper (and not just in the legal section). Copies of the proposed Consolidated Plan must be available at libraries, government offices, and public places. In addition, each state must provide a reasonable number of free copies of the plan to citizens and groups that request it.
CONSOLIDATED PLAN CONTENT REQUIREMENTS
HUD requires that every state Consolidated Plan contain six basic elements:
- a housing and homeless needs assessment;
- a housing market analysis;
- a strategic plan for meeting housing, homeless and community development needs, including a description of proposed accomplishments specifying the number of extremely low-income, low-income and moderate-income families to whom the state will provide affordable housing;
- a one-year action plan, which includes a description of how the proposed distribution of funds addresses the priority needs and objectives of the strategic plan;
- a certification section, including certifications that housing activities to be undertaken with HUD CPD funds will be consistent with the Consolidated Plan and that each unit of local government to be distributed funds will be required to identify its community development and housing needs; and
- a description of the standards and procedures that the state will use to monitor activities carried out in furtherance of the plan.
Each state must include in the body of its Consolidated Plan a detailed description of the housing needs of residents by income category, race, tenure (owners or renters), and household types of those needing assistance, including extremely low-income, low-income, and moderate income persons, elderly persons, single persons, and large families. The plan must describe the nature and extent of homelessness, including rural homelessness, in the state. The state must analyze housing market conditions, including trends in population and housing costs, the size and type of units available, areas of concentration of different race groups, and the facilities available for helping homeless people. Each Consolidated Plan identifies the resources available to meet stated needs, including federal, state, local, and private resources. Lastly, the plan establishes the priority housing needs and numeric goals for meeting priority needs.
FOR MORE INFORMATION
General information on the Consolidated Plan can be obtained from American Communities at 1-800-998-9999. For information specific to your state’s Consolidated Planning process and/or to obtain a copy of your state’s Consolidated Plan, contact the agency that administers the HOME program in your state (generally an office of the state administrative branch or a Housing Finance Agency) or the nearest HUD field office.
This Information Sheet was prepared by the Housing Assistance Council. The work that provided the basis for the publication was supported by funding under Cooperative Agreement H-5971 CA with the U.S. Department of Housing and Urban Development. The substance and finding of that work are dedicated to the public. The publisher is solely responsible for the accuracy of the statements and interpretations contained in this publication and such interpretations do not necessarily reflect the views of the government.