HUD to require consideration of climate change in Consolidated Plans

June 15, 2016

The Housing and Urban Development Department (HUD) is seeking comment on a proposed rule that would, for the first time, ask states and localities to take natural hazards and climate change into account in their long-range plans for affordable housing and community development.  Public comments on the proposed rule are due July 18, 2016.

The proposed rule—part of the department’s broader climate resilience efforts—would require states and communities to include in their Consolidated Plans assessments of the vulnerability of low- and moderate-income housing to natural hazards, “taking care to anticipate how risks will increase due to climate change.”  States and localities receiving funds under programs administered by HUD’s Office of Community Planning and Development must complete a Consolidated Plan every three to five years to outline development priorities and goals based on needs assessments and public outreach. 
Although resilience to natural hazards has figured prominently in HUD’s disaster-recovery programs, the proposed rule is the first major step HUD has taken to incorporate climate resilience into its annual formula grant programs, which include the Community Development Block Grant (CDBG), the HOME Investment Partnerships Program (HOME), Emergency Solutions Grants (ESG) and the Housing with Opportunities for Persons With AIDS (HOPWA) program.  Formula grants award funds yearly to states and localities based on predetermined formulas. 


Under the proposed rule, states and localities developing Consolidated Plans would be asked to:

  • Consult with agencies that manage floodplains, public land or water resources, and emergency response;
  • Provide an assessment of natural hazard risks, including those that will worsen with climate change, to housing for low- and moderate-income residents; and
  • Consider ways “to incorporate appropriate hazard mitigation and resilience into their community planning and development goals.”

The proposed rule wouldn’t require states and localities to take any specific steps to address the climate risks they identify, but HUD believes that these vulnerabilities “must be taken into consideration in a jurisdiction’s planning for its expenditure of HUD funds.”

To reduce the administrative burden of conducting a climate change vulnerability assessment, HUD specified a range of readily available online resources that states and localities can use to determine climate change risks in their state or region. These include:  the National Climate Assessment; the Climate Resiliency Toolkit;  the Impact of Climate Change and Population Growth on the National Flood Insurance Program (FEMA); the Community Resilience Planning Guide from the National Institute of Standards and Technology, or FEMA-approved Hazard Mitigation Plans.  Jurisdictions would also be permitted to use their own climate data sources so long as they cite them in the Consolidated Plan.


The proposed rule, titled “Modernizing HUD’s Consolidate Planning Process to Narrow the Digital Divide and Increase Natural Hazards,” 81 FR 31192, is available at: https://www.federalregister.gov/articles/2016/05/18/2016-11350/modernizing-huds-consolidated-planning-process-to-narrow-the-digital-divide-and-increase-resilience