Consolidated Plan
A five-year housing and community development plan that states and local governments must submit to HUD to receive CDBG, HOME, ESG, HOPWA, and Housing Trust Fund formula grants.
What Is a Consolidated Plan?
A Consolidated Plan is the strategy a state, city, or urban county submits to HUD to receive its annual formula grants for housing and community development. One plan covers five programs:
- Community Development Block Grant (CDBG)
- HOME Investment Partnerships
- Emergency Solutions Grants (ESG)
- Housing Opportunities for Persons With AIDS (HOPWA)
- The National Housing Trust Fund
HUD’s January 1995 rule created the consolidated submission, replacing separate planning and application documents for each program. The rules are in 24 CFR Part 91. Their stated goal is decent housing, a suitable living environment, and expanded economic opportunity, mainly for low- and moderate-income people.
How It Works
The process has three recurring parts:
| Document | How often | What it contains |
|---|---|---|
| Strategic plan | At least every five years | Housing and homeless needs assessment, housing market analysis, priority needs, and goals |
| Annual action plan | Every year | The specific activities and funding amounts for the coming program year |
| CAPER (Consolidated Annual Performance and Evaluation Report) | Every year, within 90 days after the program year ends | Results, people served, and progress toward goals |
The plan should reach HUD at least 45 days before the jurisdiction’s program year begins. HUD will not accept it later than August 16 of the federal fiscal year. Missing that deadline means automatically losing that year’s CDBG funds.
Public participation is built in. Local governments must adopt a citizen participation plan, hold public hearings, and give residents at least 30 days to comment on a draft plan or a substantial amendment. They must also consult housing agencies, homeless service providers, and other organizations.
The needs assessment estimates housing problems for households at different income levels. Most jurisdictions start from HUD’s CHAS data, which HUD preloads into its online planning tool, the eCon Planning Suite.
Why It Matters for Workforce Housing
The Consolidated Plan decides where a community’s flexible federal housing money goes. Developers seeking HOME or CDBG gap financing usually need to show that their project matches a priority in the plan.
Part 91 uses its own income terms. “Low-income” means up to 50% of area median income and “moderate-income” up to 80%, which differs from the labels used in other HUD programs. The rules also define “middle-income” as 80% to 95%, and the needs assessment must estimate housing needs for that group too. The grants themselves mostly serve households at or below 80%. Even so, the needs assessment can document local need in the lower part of the workforce housing range, and the public comment period gives residents and employers a chance to raise it.
Sources
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