Multiple Grant Cities Working Group

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Summary of ConPlan Improvement Initiative Multiple Grant Cities Working Group Meetings

1. Needs Assessments have both advantages and disadvantages. WG discussed the pros and cons of retaining this section of the ConPlan. On the one hand, needs assessments document why communities need additional funding, thereby enhancing lobbying efforts. On the other hand, assessments typically indicate that grantees are addressing only a small portion of community needs.
   
   Therefore, there is a need to refine the assessment and develop categories of need, such as "Priority for CDBG Program," or "Intermediate Need." Establishing more specific categories will allow grantees to specify what it can realistically accomplish, given the level of CPD funding and the ConPlan/Action Plan time period.
   
   
2. WG has different opinions about the length of the public comment period. Most participants favor shortening the public comment period to 15 days or keeping the 30-day period. However, some WG members support lengthening the comment periods. They point out that, when ConPlans are long and not user-friendly, the public needs more time to read and analyze information before making comments.
   
   
3. There is need for HUD to provide more ConPlan training to Field Offices (FOs) to achieve greater consistency in FO review. WG members stressed that FO reviews are often subjective.
   
   
4. It would streamline the ConPlan to have the same due date and comment period for the Con Plan and the PHA plan. The ConPlan has a 30-day comment period while the PHA plan had a 45-day requirement. For one grantee, the ConPlan is due on May 15th, but the PHA Plan has a July 1st deadline.
   
5. CDBG+ Streamlining Issue/Pilot No. 1--Developing a matrix encompassing needs, goals, and achievements for the ConPlan, Action Plan, and CAPER:
   
   

   Many WG members indicated they had developed a matrix that they combine with text to describe goals, needs, activities, and accomplishments.

   Issues surrounding developing a common matrix: It will be difficult to develop one matrix that accommodates all grantees' activities. Some activities, such as numbers of housing units produced, are more amenable to a matrix. Other items, such as public service activities or multi-year capital projects, are harder to capture in a matrix. Therefore, grantees need a flexible format without rigid categories to convey activities and accomplishments. HUD should not mandate one format for all grantees. Most WG members had already developed a matrix that they found useful. Matrix needs to distinguish and accommodate 1 year and 5 year goals. Most participants favored retaining a narrative to accompany the matrix. For example, grantees often need to add explanations about accomplishments, barriers to meeting goals, or other issues. Working Group members asked to send examples of matrix or chart to Aspen Systems: Pheidel@aspensys.com and to Jsmith@aspensys.com or fax: 301-519-6757. Aspen will distribute materials to WG members.

6. CDBG+ Streamlining Issue/Pilot No. 2: To reduce duplication with applicable local plans (for example, local economic development plan), ConPlan could incorporate or link to these existing documents and not create new ones.
   
   

   As a pilot, a small group of grantees would work with CPD staff on the following:

   1. Determine if summaries of or references to other local plans meet CPD requirements.
   2. Prepare a ConPlan incorporating or referring to existing local plans.
      
      

   Currently, grantees use different approaches to required ConPlan elements (such as economic development, continuum of care):

   1. Attaching executive summaries as an appendix to ConPlan.
   2. Summarizing the applicable local plan.
   3. Cutting and pasting sections of other plans into ConPlans.
   4. Giving Website link to relevant local plan.
   5. Citing and referring reader to relevant page in local plan.
   6. Establishing committees with membership from applicable local agencies or asking local agencies to prepare these sections of the ConPlan.
      
      

7. Discussion: Performance Standards Issues

   	How can we make goals and objectives more meaningful to generate more meaningful performance measurements?
   	How do we establish meaningful standards, given the variety of activities that most grantees undertake?
   	Existing performance standards tend to reflect outputs--they are numerical and precise (for example, number of housing units produced or rehabilitated).
   	It is more difficult to develop, longer-term impact measures (e.g. number of persons moving to full-time jobs). However, some WG members are developing outcome measurements.
   	There is a need to refine and develop performance measurements for different types of activities. Developing performance measurements for multi-year, public service, or more complex programs is challenging. There is a need to refine measurements for these activities. For example, breaking a project into stages (for example, planning, environmental review, design, construction, completion, and occupancy) can allow grantees to measure performance and show progress.
   	Having different time periods for expending HOME, CDBG, and other CPD funds complicates performance measurements.

	There is a lack of accountability and enforcement in the con plan process. Jurisdictions fail to comply with con plan requirements and, when complaints are filed with HUD, HUD fails to take any action. The result is that cities are not held accountable because HUD fails to enforce the con plan regs.
	The public participation process for the con plan should NOT be shortened. The con plan is a lengthy document and the public needs ample time to review it and make comments. 30 days is barely enough time. Shortening the public comment period would diminish public input, which is critical.
	The public participation process for the con plan is somewhat of a sham. The public makes comments, jurisdictions provide non-responsive answers (if they answer at all) and jurisdictions fail to modify the con plan based upon valid public comments. The public participation process must be made meaningful.
	Fair housing issues are glossed over in the action plan and the con plan. This is not acceptable. In the City of Long Beach, CA, for example, I filed a complaint with HUD stating that the City's Analysis of Impediments to Fair Housing ("AI") was deficient in many ways. I filed the complaint in January 2002. HUD has yet to make a decision regarding my complaint. In its most recent action plan, the City of Long Beach alleged that it was affirmatively furthering fair housing ("AFFH") because it had updated its AI in 2001. The City should not be able to rely on its AI, as it is deficient. If HUD fails to resolve fair housing complaints, jurisdictions will not satisfy their AFFH obligations. The problem is further complicated because the AI (and other supporting docs) are not attached to the con plan. Thus when the city council approves the con plan, it does so without seeing the AI. The AI is approved by a city commission and it is not submitted to council.