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CDBG-MIT 101: Understanding HUD’s Community Development Block Grant mitigation funding

CDBG-MIT 101: Understanding HUD’s Community Development Block Grant mitigation funding
Oct 27, 2020
CDBG-MIT funds offer state and local governments a way to invest in a more resilient future, but there’s a lot to learn. We’ll unpack the basics for you here.

More severe climate and weather events are here to stay. States and localities affected by wildfires, hurricanes, and other natural disasters are in dire need of protective risk mitigation actions and proactive resilience before the next devastating event comes to pass.

That’s why Congress appropriated $15.9 billion to create the Community Development Block Grant Mitigation (CDBG-MIT) funding source in 2018. This new grant, administered by the U.S. Department of Housing and Urban Development (HUD), allows areas that were impacted by federally declared disasters in 2015, 2016, and 2017 to make investments in mitigation. State and local governments are eager to take advantage of these new mitigation dollars.

While CDBG-MIT funds allow communities to build holistic resilience, the process requires extensive planning and coordination to execute effectively. As CDBG-MIT Action Plans are published and programs get underway, here’s a breakdown of what CDBG-MIT is all about—and what state and local governments need to know about this promising new federal funding source.

How much money has been allocated for the CDBG-MIT grant?

Congress allocated $12 billion in CDBG funds in February 2018 to assist with mitigation activities related to 2015-2017 disasters. HUD also allocated an additional $3.9 billion, raising the amount to almost $16 billion in total. This $16 billion was then allocated across several states and local governments.

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How do governments get the funding?

To successfully receive the funding, eligible state or local governments must develop what is known as an Action Plan. This document acts as the formal application to HUD for the funding—and outlines how the state intends to spend its mitigation funds.

What do CDBG-MIT Action Plans include?

  • Mitigation Needs Assessment. First and foremost, a CDBG-MIT Action Plan must include a Mitigation Needs Assessment that analyzes current and future disaster risks. This analysis looks at how disasters have historically impacted the state, and how future conditions may only exacerbate those impacts if mitigation measures aren’t implemented. The Mitigation Needs Assessment establishes why the state needs mitigation funding in the first place—and requires a data-driven justification for the intended mitigation projects, which should tie back to the risks addressed.

    But it doesn’t happen in a vacuum. The Needs Assessment requires grantees to collaborate with stakeholders that administer FEMA’s Hazard Mitigation Grant Program (HMGP) in order to streamline the goals of the CDBG-MIT funding. Grantees must use the most recent assessment from their governmental jurisdiction Hazard Mitigation Plans (HMP). In addition, the Mitigation Needs Assessment must analyze how disasters impact what FEMA defines as the Community Lifelines, which are critical services that enable the continuous operation of government and business functions—and are essential to human health and safety or economic security.

  • Mitigation projects tied to stated needs. With the Mitigation Needs Assessment serving as the foundation, the state or local government then proposes programs, projects, and activities that will mitigate against the current and future risks identified in the Needs Assessment in its Method of Distribution section of the Action Plan. The tie-back to the Needs Assessment is important. For example, if your Mitigation Needs Assessment shows that you are historically impacted by flooding and will continue to be, it’s wise to put forward flood mitigation projects.

How are CDBG-MIT funds being used?

HUD CDBG-MIT is funding high-impact activities that help disaster-impacted communities mitigate disaster risk and reduce future losses. Here are some specific ways that state and local governments can use CDBG-MIT funding:

  • Adopt policies specific to local and regional needs, including future disaster risk reduction to community lifelines. CDBG-MIT funds can be used to update or develop building codes and land use plans. Modern disaster-resistant building codes are often credited with mitigating damage and cascading impacts of disasters in areas where they are enforced. 
  • Analyze and better understand disaster risks through more comprehensive disaster mapping and data collection. CDBG-MIT funds can also be used to update hazard mitigation plans—encouraging advanced disaster preparedness. An enhanced focus on disaster data and planning can provide better access to critical information for vulnerable communities.
  • Make smart investments that focus on preventing the loss of property and infrastructure. CDBG-MIT funds can be used for construction activities such as retrofitting existing infrastructure to withstand stronger storms.
  • Maximize funds by leveraging public/private partnerships as well as federal money. Many state and local governments use CDBG-MIT funds in combination with funds from other federal agencies such as FEMA (see FEMA BRIC) to carry out high-impact activities.
  • Recuperate financial losses from recent qualifying disaster events. CDBG-MIT funds can also be used to support disaster-impacted communities through housing activities such as buyouts.

What role do state and local government officials play?

HUD passes down CDBG-MIT funds to state or local offices of community development, which are tasked with administering the money and managing the types of projects noted above. With CDBG-MIT, states may directly fund local governments (subrecipients) within their state. This is often through an application period where eligible units of government submit applications for mitigation projects. CDBG-MIT recipients (noted in the table above) can also carry out activities directly. State and local government officials must form a team in order to plan, prepare, and coordinate efforts among the various stakeholders.

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To maximize the impact of all available funds, state and local governments should be coordinating to align the CDBG-MIT funding with other mitigation projects funded by FEMA, the U.S. Army Corps of Engineers (USACE), the U.S. Forest Service, and other agencies as appropriate.

They should also be getting input from local communities on what impacts have been felt—and what’s most important from a local perspective.

Creating this coordination between relevant agencies and stakeholders can help state and local governments:

  • Identify common problems to better align mitigation activities.
  • Ask questions about previous work that’s been done in their communities.
  • Learn what types of projects have and haven’t been successful.
  • Determine the best use of funds based on a broader set of experience.

Since CDBG-MIT funds can be used as additional funding for FEMA mitigation programs, a collaborative relationship with the agencies that oversee the emergency management assistance is especially critical to establish—and carry out—the highest-impact mitigation programs.

What happens after the Action Plan is submitted?

Once states have submitted their Action Plan, there are three key steps they need to take to successfully implement and manage their CDBG-MIT-funded programs.

  1. Run a Duplication of Benefits check. Before accepting and using any funds received from the CDBG-MIT grant, grantees need to check for Duplication of Benefits (DOB) to ensure that benefits are not duplicated from multiple funding sources—as this is illegal.
  2. Know the deadlines. Grantees must make sure they are aware of the expenditure deadlines put forth by state and local jurisdictions.
  3. Staff up. Acquiring the necessary staff and materials to successfully implement CDBG-MIT-funded programs is crucial to effective program implementation and management.

Are there any other requirements?

A main goal of HUD’s CDBG grants is to ensure that communities most in need receive benefits from mitigation funding. To deliver on this mission, CDBG-MIT requires that each funded activity meet one of the following named national objectives:

  • Low- and moderate-income households, persons, areas, etc.
  • Intentional long-term maintenance of infrastructure and public facility projects.
  • Proposed CDBG-MIT activity must not increase the risk for loss of life or property in a way that negatively affects funding benefits.
  • Addresses all needs from the grantee’s Mitigation Needs Assessment.
  • Has demonstrable effects on lessening loss of life, property, and overall future damage from natural disasters.
  • Can be sustained long-term and efficiently with clearly explicated operational goals and maintenance plans.

Preparation and peace of mind

The best defense is a strong offense. It takes a lot of work to make it through the CDBG-MIT hurdles, but by teaming up with the right partners, it’s not only achievable—it’s also a huge service to communities in at-risk areas. Committing to the process can save lives, homes, and businesses. When you have a solid plan and the proper funding to support it, you’ll be far better prepared to weather the storms ahead.