Consolidated Plan Improvement Initiative Steering Committee

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Consolidated Plan Improvement Initiative Summaries of Steering Committee Meetings

Wednesday, August 13, 2002 - Key Issues Discussed

I. Fast Track

Fast Track ideas currently being discussed by each Working Groups were summarized as follows:

States: Is the ConPlan a Plan or an Application? - States believe the ConPlan should be 1) an application for federal funds; 2) for HUD-funded programs only; 3) of a 10-year term, tied to census data, with a one-year action plan updating a) State method of distribution, b) program data, as applicable; and c) the SF 424 form. Eliminate High, Medium and Low Priority Needs Designation

CDBG Plus: Streamline ConPlan to have the same due date and comment period as the PHA plan.

CDBG Only: ConPlan and PHA Plans should have the same submission dates and CDBG grantees should have access to the following PHA information:   Deconcentration data.   Demolition of PHA units.   Loss of Section 8 units.   Families on waiting list.   Resident Characteristics Report.   Availability of privately owned, affordable rental units. The ConPlan, Annual Action Plan and CAPER should use consistent terminology, including definitions for income categories, families-households, units-beds, and chronic homelessness. Also, the strategy section of the plan should ask for breakout by income categories similar to the Housing Needs table. Allow for abbreviated plans for CDBG-only grantees. Eliminate sections that were added to ConPlan for purposes of supporting HOME, ESG and HOPWA grant applications. From NAHA Section 105 (b) - - Secretary may provide for submission of abbreviated housing strategy for jurisdictions not otherwise expected to be participating under Title II of the Act (HOME Investment Partnerships Program Act), appropriate to the types and amounts of assistance jurisdiction receives.

II. Questions for "Q and A"

The questions being considered for responses was reviewed with the group. HUD HQ will get some Answers out to all Steering Committee members within the next few weeks. The discussion was opened to the Members for comments on the questions themselves and/or for additional questions to be added to the list.

It was suggested that first questions should be "What was the intention on the Consolidated Plan?" A discussion then ensued about the census and the use of census data as the primary data source for preparing ConPlans. Some members felt that census can't be the only data used or relied upon while others felt that for now there really is no other source of data as reliable and comprehensive. Concern was expressed that so much time was spent discussing data when the ConPlan is really to be about Strategies for dealing with needs. The American Communities Survey was mentioned but it was suggested that this may not in fact solve the data issues for all communities. It was agreed that after the Questions were more finalized and some Answers drafted and added, that the list could be shared with Steering Committee Members for review and comment.

III. Income Category Crosswalk

The draft Income Category Crosswalk was reviewed. Most members felt it was a positive tool. Some expressed concerns about attempts to actually "change" the categories specifically for CDBG and HOME. Due to the history of those programs and the support behind the development of the terms and classifications, it was suggested that this would be a difficult thing to accomplish. Some felt that there was enough support to change them. Others did not. Some wondered which group would hold on to it and why. Since, it was pointed out, that the suggestion is not to change the targeting requirements of the programs but to simply the terminology being used in order to provide consistency. It was suggested that consistency of terms could be viewed as a Federal Government issue. Such consistency would in fact be very helpful across all government programs. It was offered that it would be great for HUD to "get out in front" of such a cause.

It was commented that in order to recommend changes, grantees and others would need to make a case as to how this is causing difficulties now. It was mentioned that ConPlan uses percentages and not the category names.

ACTION ITEM#3: Aspen/ComCon will revise the Income Category Crosswalk document per the comments received from the Committee.

IV. Citizen Participation

Citizen participation continues to be a topic among the Working Groups. It was stated that there is no really leadership or willingness to change the requirements but that HUD understands there are frustrations. So as part of this Initiative, HUD is seeking out better ways for getting input from citizens and for communicating with citizens in general. HUD is asking for Steering Committee members to send forward examples of strong effective Citizen Participation efforts. States have recommended being allowed to meet the Citizen Participation requirements through convening advisory committees in lieu of public hearings. Others suggested that training for staff is needed to ensure that good practices are implemented and that communities are attempting to do more than the minimum. It was mentioned that CDBG Training funds will be available in the next budget so such an effort could possibly be undertaken. It was offered that one community has a Director of Citizen Engagement. Some members liked this idea. Many agreed that CP should be more about the outcome of the process rather than the mechanics of the process.

ACTION ITEM #4: Anne Doody Wiedl will follow up with the community that has the Citizen Engagement position and report back to the group.

ACTION ITEM #5: HUD and ComCon staff will continue to research "best practices" for Citizen Participation.

V. Performance Measurement

So far most Working Group members agree that Grantees are already supplying HUD with more than enough information and reports. Working Groups feel OMB and others should be able to make a determination about their performance and the impact of the programs, especially CDBG, with what is available via IDIS and the drawdown information.

HUD HQ staff suggested that there are two aspects to this issue:

	What can HUD do better right now on reporting accomplishments with the information already being supplied
	CAPER and IDIS not working as well as it should to gather the appropriate information - HUD needs to be asking the right questions.

1. A new process… to be undertaken by one or more volunteers
2. A local process that has grown out of the Consolidated Plan that should be tested and/or evaluated elsewhere…by volunteers
3. A local process that needs to be reviewed and evaluated on site locally.
   

	States, Counties and CDBG Plus: 1) Use Existing State Documents / Certifications - Satisfy the CHAS requirements using State plans or other State documents, in other words, no separate Consolidated Plan especially prepared for HUD in a prescribed format. Instead, States would "crosswalk" to other existing State documents as much as possible and send those already prepared documents to HUD. This would help to see whether States can comply with the statute without having to prepare reams of paper to submit to HUD and whether this approach is less onerous than the current regulatory requirements. Also, States ConPlan submission would focus only on those priority needs expressed by the State, with States reporting to HUD based on these State priorities. States could then use ConPlan as "communication tool" to discuss priority needs throughout State.
	States and Consortia: 2) Eliminate Non-Housing CD Strategy - Provide the housing strategy only and see if this cuts down on the administrative burden, and whether it is useful to the agency and citizens as a plan.
	States: 3) States Format for ConPlan Submission - Allow States to design their own format for the ConPlan while complying with HUD regulatory requirements. This differs from number #1 in that all of the regulatory requirements would still have to be met, but instead of a prescribed format, permit States to submit what they believe is the most appropriate information in the most user-friendly way. Also, create "Master ConPlan" for those elements that do not change, and the "Annual Action Plan" will address areas of change and include only 1) methods of distribution; 2) program data, as applicable; and 3) SF-424. Then if no activity in a given year, it is possible the "Annual Action Plan" is comprised of a SF-424 only. 4) Electronic Submission - All required elements of ConPlan submission be electronic only-no paper requirement. 5) Effective Citizen Participation - In lieu of in-person public hearings, permit States to conduct online "cyber-hearings". Purpose is to make CP process more meaningful for States, its citizens and HUD. A variation on this would be to prepare a separate submittal called the "ConPlan", but only distribute it electronically to HUD. 6) States Format for ConPlan Reporting - States will develop a template for reporting accomplishments specific to States as a grantor agency. Purpose is to reduce burdensome reporting requirement of IDIS (grants management) and CAPER / PER reporting (4 formula grants programs) and to make the process more meaningful to States, its citizens, and HUD. States requesting a like reduction in other reports currently required by HUD.
	CDBG Plus: Developing a matrix encompassing needs, goals, and achievements for the ConPlan, Action Plan, and CAPER. It will be difficult to develop one matrix that accommodates all grantees' activities. Therefore, grantees need a flexible format without rigid categories to convey activities and accomplishments.
	CDBG Only: Establish same due date for ConPlan and PHA Plan. The ConPlan template provided is very similar in format to PHA template. Check boxes work for grantees, but be careful not to mandate a one-size-fits-all approach. Provide template as minimum requirement that communities can build upon if desired. Allow addenda to cover additional material. No need to have one template that covers both ConPlan and PHA Plan as it would be too long and only appropriate for a few agencies that are in charge of both plans. Create ConPlan template for grantees that receive only CDBG funds. Possible option is to develop a CDBG-only template that has HOME, ESG and HOPWA attachments as needed? Draft template is good starting point. Add hot links to census web sites (e.g. data profiles page on American Fact Finder) and other Web resources. Add % of funds and owner/renter breakout for each strategy area under Part E: Strategy for Addressing Need. This is very useful for the public. Also, adding a little narrative to this part may make it more descriptive to citizens. Streamline Certifications. It is currently the simplest part of ConPlan but it could be simpler if only one signature is required for all applicable certifications. Lead Paint and Fair Housing certifications are significant for public input but some communities will sign without giving much thought. (e.g. Most jurisdictions don't have Fair Housing Action Plan but sign certification anyway.) It requires complaints to prompt HUD inspection on Fair Housing. Maintain the Analysis of Impediments to Fair Housing requirement. Template could mention resources for the kind of attachments that would be useful to grantee/public and more explanations on certification template could clarify requirements (i.e. that communities should be affirmative in pursuing fair housing in their community.)
	Technology: Implement selected tools for carrying strategic plan data forward to subsequent Annual Action Plans and performance reports. The tools being considered are from: Madison, WI; San Francisco, CA; Clark County, NV; State of Wisconsin; Columbus, OH; Los Angeles County, CA and a spreadsheet devised by Dee Ann Ducote. Some tools are in spreadsheet form while others are html. The Working Group will recommend the type of grantees that should be selected for optimal testing of each tool. The test will be devised to see if a grantee can adapt the tool and if it is helpful at different stages of the Consolidated Plan life cycle (3- to 5-Year Strategic Plan to Annual Action Plan to Performance Reporting.) HUD HQ staff informed the Steering Committee that the CPII had received approval to proceed with pilots. It was agreed by legal counsel that the language of 91.200(a) "or in such other format as jointly agreed upon by HUD and the jurisdiction" provides the basis for pilots for FY 2003 and a reg isn't required. It was suggested that HUD try to do the easiest things first. Members felt that each pilot recommendation should have a developed work plan which would explain what is being tested and why, and also the next steps to move it forward. Members felt that initially things may seem like a good idea but once people get in to it, it may change or become more complicated.