Steve Gold, The Disability Odyssey continues

In March 2006, HUD promulgated new Consolidated Plan requirements in the F ederal Register. Participating jurisdictions that receive federal HOME Investment Partnership funds and Community Development Block Grant funds must complete Consolidated Plans.

The "new" Consolidated Plan requirements emphasize identifying "need" and assigning a "priority" to each need. After these have been identified, jurisdictions that receive HOME and CDBG funds must indicate, for five years, how much money from these funds will be allocated to meet the identified "needs" and "priorities."

For example, if renters whose household incomes are at or below 30% of your area's "area median income" (aka "median family income") are identified as having a housing need and it's a "high" need, then some of the HOME and/or CDBG funds should address them. If they're not identified as having a very high need, then shame on you; your advocacy should be reexamined.

Here's one idea how disability housing advocates might use the Consolidated Plan process to increase HOME's tenant-based rental assistance, aka housing subsidies in your area. It's a two-stepper.

First, HUD instructs jursidictions that to determine housing need in the ConPlan they should use data from HUD's SOCDS:CHAS, i.e.,State of the Cities Data Source: Comprehensive Housing Affordability Strategy.

Second, HUD also defines that households should pay approximately no more than 30% of their income on housing costs, i.e., for renters that's both the rent plus utilities. For households which pay more than 30% of their household incomes on housing costs, they have, according to HUD, a "cost burden."

Go to the State of the Cities Data Systems website (or by going to HUD User website, click on CHAS Data and then click on the "nonframe version of CHAS.") Under "housing problems," click on your State and then the specific jurisdiction you want. You can then see, e.g., for "All Renters" whose incomes are at or below the 30% of the AMI/FMI, the percentage of renters which spend MORE than 30% of their incomes for rent and utilities b they have a "cost burden." You can also see the percentage who pay MORE than 50% of their incomes for rent and utilities. They have a really big "cost burden." (The annual "Priced Out" reports from TAC, Inc., are also very helpful and should also be used.)

The larger the percentage of the lowest income families with severe "cost burdens," the great the housing need in your jurisdiction! If your ConPlan does not use the CHAS information to identify as a priority need the percentage of households that have "cost burdens" and/or then does not allocate a reasonable portion of their HOME/CDBG for rental assistance for persons whose family incomes are at or below 30% of the AMI/FMI and whose "cost burdens" exceed 50% of their incomes, you should be asking HUD to not approve the ConPlan.

How could HUD approve a ConPlan where there is a significant percentage of the lowest income households (i.e., incomes at or under 30% of the AMI) with significant "cost burdens," but the ConPlan does not either identify this as a need and/or does not allocate rental assistance to alleviate that need?