HUD’s Office of Community Planning and Development (CPD) issued Notice CPD-14-15 on October 21, advising grantees not to submit a new 3-5 year Consolidated Plan (ConPlan) or an Annual Action Plan until after Congress enacts an FY15 HUD appropriation and CPD announces FY15 grantee formula allocations. Grantees may delay submitting a ConPlan or Annual Action Plan until 60 days after formula allocations are announced by CPD. The ConPlan-oriented formula programs are Community Development Block Grants (CDBG), HOME Investment Partnerships (HOME), Emergency Solutions Grants (ESG), and Housing Opportunities for Persons with AIDS (HOPWA).
FY15 began on October 1 without an appropriation for HUD or other federal agencies. Instead, HUD and the rest of the government are operating at FY14 appropriation levels under a continuing resolution (CR) until December 11 (see Memo, 9/22). Congress will return after the November elections to determine the fate of the FY15 appropriations process. Once Congress acts, CPD will know how much is appropriated for the formula programs.
The Notice provides revised procedures for submitting ConPlans and Annual Action Plans prior to Congress enacting an FY15 HUD appropriation. Although grantees could estimate amounts they might receive, if there are major differences grantees, might have to undertake the substantial amendment process, which entails public participation. The revised procedures in the Notice apply to any grantee with a normal ConPlan or Action Plan submission deadline that falls either before or less than 60 days after the date HUD announces FY15 formula allocation amounts. Submission deadlines are 45 days before the start of a grantee’s program year.
The Notice provides a hypothetical example of CPD announcing FY15 allocations on February 20, 2015, which would allow grantees with program year start dates between January 1 and June 1 to postpone submissions until April 21, 2015. About 308 grantees have program years that would fit that situation. The remaining 910 grantees, those with a program year start date of July 1 or later, would be expected to submit their ConPlan or Action Plan on time.