Consolidated Plans

The Consolidated Plan is a strategic plan for housing and community development required by the U.S. Department of Housing and Urban Development (HUD) as a condition for participation in various federal programs, including the Community Development Block Grant (CDBG), HOME Investment Partnerships (HOME), Emergency Shelter Grants (ESG), and Housing Opportunities for Persons with AIDS (HOPWA). Other HUD programs require that a jurisdiction receiving funds have a Consolidated Plan approved by HUD or certification that the application to be funded is consistent with the Consolidated Plan.

The Consolidated Plan has its origins in the Cranston-Gonzalez National Affordable Housing Act of 1990 (Pub. L. 101-625), which gave new resources to states and local governments to address affordable housing needs. The act required that jurisdictions receiving funds under a variety of federal housing programs prepare a Comprehensive Housing Affordability Strategy (CHAS). The CHAS replaced the Housing Assistance Program (HAP) plans, required for CDBG recipients, and the Comprehensive Homeless Assistance Plan (CHAP), required for McKinney Act homeless programs. The HAP involved defining housing needs and setting goals, but little attention was given to how goals were to be achieved. The CHAS, in contrast, emphasized strategic planning, including identifying where intervention would be most effective, coordinating public and private housing activities, and providing means for public participation. Although the CHAS raised the visibility of housing as an issue, it did not fulfill HUD's expectations. The agency wanted a more holistic approach, as the structure of the CHAS was such that it was prepared independently from nonhousing issues and strategies. In response, HUD replaced the CHAS in 1995 with the Consolidated Plan.

The overall intent of the Consolidated Plan is to define a specific course of action for revitalization, taking into account the local context and linkages to the larger region. It is at once a collaborative process for the community to establish a unified vision for community development, a CHAS strategy for addressing housing needs, an application for federal funding, a plan for carrying out HUD-funded programs, and a management tool for assessing progress. The Consolidated Plan substantively considers economic, physical, environmental, community, and human development issues. HUD evaluates each plan against three basic goals defined by statutes for the formula grant programs. These include the following:

• Decent housing, including retaining and increasing the stock of affordable housing, with particular attention to low- and moderate-income families, members of disadvantaged minorities, the homeless, and those with disabilities
• A suitable living environment, including improving safety and neighborhood livability, reducing isolation of lower income groups through spatial deconcentration of housing opportunities and neighborhood revitalization, increasing access to public and private facilities, historic preservation, and energy conservation
• Expanding economic opportunities through job creation and retention, especially for low-income persons, small business establishment and expansion, access to capital and credit and reducing generational poverty for those in federally assisted and public housing

Preparation of a Consolidated Plan is a substantial undertaking with a public reporting burden estimate of 395 hours on average, including reviewing instructions and obtaining, maintaining, and reviewing data. Requirements for preparing Consolidated Plans place strong emphasis on meaningful consultation and coordination with a full range of organizations, agencies, and groups to ensure coordination and efficiency in providing services and to build capacity for further collaborations. An effective citizen participation process is also required, with a particular emphasis on facilitating the involvement of minority, non-English speaking, and low- and moderate-income residents. Citizens must be given full and timely access to information as to what can be [Page 92]funded, the amount of funding available, what is being proposed, and who will benefit. Public hearings need to be well publicized and accessible. The proposed Consolidated Plan must be well publicized so that affected citizens have an opportunity to review and provide comments.

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