Texas General Land Office (GLO) has issued its State Action Plan for administering the $4.3 billion in U.S. Department of Housing and Urban Development (HUD) Community Development Block Grant for Mitigation (CDBG-MIT) allocated to Texas. A 45-day public comment period for the draft State Action Plan will open until January 6, 2020.

The draft State Action Plan identifies the proposed activities for long-term recovery and restoration of housing, infrastructure, planning, and economic development in areas affected by disaster. Key differences from past federal funding allocations are:

• Funds are for mitigation activities projects are not required to tie back to a specific disaster.

• 50% of the funds must benefit low- and moderate income (LMI) persons and all programs have a LII priority. 

• The GLO is encouraging larger, broad based regional mitigation projects that promote coordination and partnerships.

The draft State Action Plan describes allocations across 13 different statewide programs. Major categories include:

Other programs include: 2015 Floods State Mitigation Competition, HMGP:  Supplemental, Coastal Resiliency Program, Resilient Home Program, Hazard Mitigation Plans, Resilient Communities Program, State Project Delivery and State Administration.

H-GAC Recommendations

H-GAC staff has reviewed the draft State Action Plan and makes the following recommendations for the Board to forward to GLO as part of the 45-day public comment period.

Plan-Specific Recommendations

• H-GAC supports the wide range of programs to be funded under the draft plan, but we believe the Regional Mitigation Program is underfunded at $500,000,000. H-GAC strongly recommends the funding for the Regional Mitigation Program be increased to $1,000,000,000 for allocation by councils of governments (COG) through the method of distribution process. The method of distribution process allows for maximum flexibility and has the greatest opportunity to fund projects that are truly needed at the local and regional levels.  

• The 2015 Floods State Mitigation, the 2016 Floods State Mitigation, and the Hurricane Harvey State Mitigation competitions listed in the draft State Action Plan allow applicants to submit multiple applications per competition. However, eligible applicants may not receive funding for more than one eligible project until all successful eligible applicants have been awarded funding at least once. H-GAC encourages GLO to award funding for the highest scoring applications in these competitions to allow the best, most viable projects to be implemented to mitigate future natural disasters.  

• We encourage the GLO to give a high priority to multi-jurisdictional collaboration in the competitive funding categories and recommend assigning points in the scoring criteria for such projects.

• We further recommend that a local government’s participation in a joint application should not count toward its maximum number of funded projects. Specifically, the limitation mentioned on pages 202,209, and 216 should be removed to ensure the broadest participation in multijurisdictional projects.

• The draft State Action Plan requires the GLO to spend 50% of the funds in six years and 100% of the funds in 12 years. H-GAC strongly encourages the GLO to not stage the application process for the various programs. Operating from a single timeline that strives to properly deploy funding will be more effective than delaying projects due to staggered application deadlines.

General Comments

1. H-GAC recommends the GLO increase the role of COGs in impacted areas. COG’s are uniquely positioned to serve as an advisory resource and can provide a conduit for impacted jurisdictions a mechanism to provide feedback to senior GLO staff and troubleshoot any problems as the various programs are implemented. 
2. H-GAC recommends the GLO develop a pre-application process, including an application checklist, that is less detailed than the full application. This process may help applicants better prepare their materials for submission and can provide the GLO with larger, more comprehensive list of projects that could be quickly categorized and prioritized for funding based on factors such as beneficiary income requirements. 
3. H-GAC supports the inclusion of COGs as eligible applicants for Regional and State Planning Programs, as stated in the draft State Action Plan. We believe that COG’s are uniquely positioned in the state to bring multiple local governments together not only in developing projects but also in working collaboratively with local governments to ensure that local plans and policies support long-range resiliency goals.   

N/A