In recent years, there has been growing recognition of the systemic barriers faced by marginalized communities, particularly when it comes to accessing housing and community development resources. The U.S. Department of Housing and Urban Development (HUD) established new equity goals in response to Executive Order 13985 issued by President Biden to direct the federal government to advance equity and support underserved communities.
Disaster Recovery as a Vehicle for Equity This extends to HUD’s disaster recovery work where it is placing equity, fairness, and inclusivity at the forefront. We see this reflected in the recent Federal Register Notices that govern HUD Community Development Block Grant Disaster Recovery (CDBG-DR) funding, which the department is leveraging to “address the intersections between disaster recovery, civil rights, and fair housing.” Now, state and local governments that administer CDBG-DR funding must plan and implement programs that protect and benefit federally protected classes (race, color, national origin, religion, sex – including gender identity and sexual orientation, familial status, and disability[1]), underserved communities, and other vulnerable populations.
Incorporating Equity into Programs
Operationalizing equity goals into disaster recovery programs adds another layer to the already complex tasks of disaster recovery grant administration, program design, and implementation. Grantees must take steps to meet new requirements without additional administrative funding or staff capacity. However, the new requirements will lead to more equitable programs and more resilient communities.
A New Approach for Equitable Recovery
HUD’s equity goals challenge grantees to approach disaster recovery differently. The traditional model looked at what was impacted by a disaster and what it would take to replace the damage. Now, grantees must also consider who was impacted and how they will be affected by the recovery. Even before the new federal equity priorities, grantees analyzed the demographics and assessed vulnerabilities of the impacted communities, but HUD now requires that information to be reflected in disaster recovery program design and implementation. HUD’s equity goals require grantees to rethink not only how programs are designed, but also how grantees rank, score and prioritize projects in a manner that centers equity. These requirements mean that existing recovery programs should be re-evaluated using an equity lens wherever they are in the planning and implementation process. With a wide array of HUD-funded disaster recovery programs and grantees at different phases of their recovery, making equity a priority for disaster recovery programs is possible at any phase of grant implementation. Disaster recovery programs vary depending on the type of disaster, impacts, community needs, and now must consider how funds can be used to further equity goals. Program range from multifamily housing, business and workforce development programs, infrastructure, to homeowner recovery programs.
Furthering equity in disaster recovery can look different in different communities, but housing recovery is commonplace across disasters. To further equity in multifamily renter housing, grantees can look beyond building back rental housing that may have been damaged – in some cases housing located in historically segregated areas, in poor condition or in areas of high environmental risk. Disaster recovery funds can create new rental housing in areas of opportunity, with design standards that reduce renter’s risk from future disasters. While gaps remain in serving people impacting survivors, particularly the most vulnerable, including renters, renters impacted by a disaster remain. Scarce and prohibitively expensive rental prices in post-disaster areas, delays in building permanent rental housing, and limited funding for temporary shelter, CDBG-DR funds can both address current needs, such as temporary rental assistance, and address long-term housing needs through building new housing.
Equity is in the Details HUD requires disaster recovery grantees to develop an action plan before funding is made available to communities that explains how CDBG-DR funding will be used to reduce barriers for applicants of federally protected classes[2], identify nearby natural and environmental hazards, and explore ways to address environmental injustices and build climate resilience[3]. Much of this work begins with an assessment of unmet recovery needs that must look at how planned uses of funds may impact, benefit and discriminate against protected class groups and other vulnerable populations. The assessments are informed by new data requirements that have grantees closely examine the makeup of populations in the Most Impacted and Distressed (MID) areas, as determined by HUD threshold requirements. To fully describe these impacts, either direct or indirect, grantees should include data and analysis of each federally protected class – including demographic information, any direct impacts from the disaster on each protected class, and efforts to mitigate future impacts on these populations.
SIX STEPS TO OPERATIONALIZE EQUITY GOALS
To help grantees operationalize equity goals throughout program design and implementation, Civix’s team of disaster recovery and mitigation experts recommend the following six steps:
Step One: Analyze vulnerable populations and their pre- and post-disaster conditions When developing a CDBG-DR Action Plan grantees should begin with HUD’s guidance on vulnerable populations and underserved communities and listing federally protected classes within disaster-impacted areas. HUD’s guidance provides a framework of this analysis, but leaves room for grantees to define vulnerable populations, underserved communities or add any state-specific protected classes. Next, gather demographic data for these areas and describe direct and indirect impacts of the disaster on these populations. For programs, describe the benefits or barriers for each protected class.
For example, an examination of a multifamily housing program’s impact on elderly persons would start with a review of Census data for each impacted area and would include contacting service providers and reviewing FEMA data to determine any direct impacts. These findings would inform program design, which should also include developing scoring criteria that provides additional points for projects that prioritize persons 65 years of age or older.
Step Two: Prioritize citizen participation and equitable engagement Along with data analysis, incorporating equity through community stakeholder and public engagement starts immediately post-disaster. Along with the required consultations – such as with Continuum of Care, housing authorities, tribal governments, impacted local governments, and private and nonprofit sectors – grantees should develop an outreach plan to consult with federally protected classes throughout the planning and launch phases of recovery (as well as during implementation). Early and consistent engagement, from information sharing to assisting with program decisions, are critical for buy-in and successful program implementation. In developing an outreach plan centered on equity, grantees should identify organizations and community leaders in each impacted community and engage them throughout the process, including, but not limited to: understanding community impacts and barriers to recovery, briefings on disaster recovery requirements, presenting programmatic options for consideration and feedback, and assistance with marketing programs once developed.
Step Three: Connect application criteria to equity goals When developing application or Notice of Funding Availability (NOFA) and program implementation guidelines criteria, they should align with HUD’s equity goals. This includes identifying the proximity of natural and environmental hazards to affected populations in MID areas as well as incorporating how programs and projects will increase resilience to protect vulnerable populations against the effects of extreme weather events and other natural hazards. For example, in a public service program[4] or the development of a community facility, ensure that the project site is in a low-hazard area, is proximate to evacuation routes that adequately serve low- and moderate-income communities, and is accessible to persons with disabilities. The equity goal requirements must be outlined in the program’s policies and procedures and posted to the grantee’s website when the NOFA or solicitation is launched.
Step Four: Evaluate applications according to equity goals After applications are received, grantee’s have another opportunity to understand and evaluate equity goals through a due diligence process. This step can include a review of an applicant’s policies and procedures, such as their public participation plan and Affirmative Fair Housing Marketing Plan to ensure that the applicant has sufficient equity framework to ensure implementation meets equity goals. If the grantee finds that the applicant does not have sufficient framework, they may use the opportunity to educate the applicant and provide technical assistance to develop equity policies and procedures. It also ensures the grantee and the applicant agree on the equity standards through program implementation.
Step Five: Incorporating equity during Action Plan Amendments After a grantee’s CDBG-DR Action Plan is submitted and approved by HUD, recovery conditions change and disaster recovery programs need to adapt to the needs of the group, often requiring nonsubstantial and substantial amendments[5] to the action plan on how the disaster recovery funding will be spent. Action Plan Amendments provide opportunities to integrate additional equity measures into an approved action plan. This can include adding new equity data to needs assessments, program applications to date, new outreach efforts to encourage participation from federally protected classes, and updates on barriers faced by protected classes and how the grantee is working to address them. Mapping program data along the way is also a useful way to spatially understand if projects fall into Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) or historically underserved communities.
Step Six: Evaluating equity at program closeout Once projects are complete, the grant closeout provides a final opportunity to evaluate how programs measured up to HUD’s equity goals. This evaluation can assist grantees to understand where their programs may have fallen short. Grantees should examine the list of applications and applications that led to completed projects. They should assess how the projects served or impacted federally protected classes and consider how future programs could incorporate the lessons learned. Beyond disaster recovery, this type of evaluation should also be used with mitigation grants to measure the extent to which a project reduced risk to vulnerable and underserved communities and to determine how future programs could be improved. Aligning with Federal Priorities Drives More Effective Recoveries While each community faces unique challenges in recovery and incorporating resilience post-disaster, these six foundational steps can ensure all grantees advance equity in their disaster recovery and mitigation programs.
About Civix Grants
Civix provides expertise in federal grant management, program management, policy, and community planning as well as a suite of technology solutions to manage every aspect of HUD and FEMA grants. With a deep bench of professionals across disciplines, it offers a full spectrum of services, including strategic planning, policy analysis, project evaluation, performance and process improvement, grants and program administration, and on-call technical assistance and training for federal programs. Over 40 years, Civix’s grant team has developed best practices that it applies to meet each community’s unique objectives. This approach has earned the renowned grant management team a reputation as being innovative while delivering meaningful results. It’s proven this time and again through the management of numerous large-scale projects and the administration and implementation of over $28 billion in federal grants.
Citations [1]https://www.hud.gov/program_offices/fair_housing_equal_opp/fair_housing_act_overview#_Who_Is_Protected [2]https://www.hud.gov/program_offices/fair_housing_equal_opp/fair_housing_act_overview [3]https://files.hudexchange.info/resources/documents/Disaster_Recovery_Disaster_Impact_Needs_Assessment_Kit.pdf
[4] https://www.hudexchange.info/sites/onecpd/assets/File/Basically-CDBG-State-Chapter-7-Public-Services.pdf
[5] https://www.hud.gov/sites/dfiles/CPD/documents/Substantial-Amendment-AP-checklist-Final-2022-09-06.pdf