Date Published: August 2015
HUD is aware that some States have Annual Action Plan submission dates in early 2016 and would like to include HTF Allocation Plans in citizen participation hearings that they will conduct for their Action Plans. Before deciding to include HTF in Annual Action Plan hearings that take place before HTF allocations are available, States should consider that there are no 2015 baseline figures upon which to estimate 2016 HTF allocations. This may make it difficult to achieve meaningful citizen participation and meet the Consolidated Plan citizen participation requirements established at 24 CFR 91.115. In addition, HUD intends to issue guidance on maximum subsidy limits and operating cost assistance later this year, which may prove useful to States as they develop their program design. Lastly, grantees are required to conduct citizen participation before submitting a substantial amendment to the Annual Action Plan, which may negates any time or cost savings that were achieved by including the HTF Allocation Plan in Annual Action Plan hearings.
HUD encourages States and SDEs to engage with their stakeholders (e.g. community organizations, general public, housing partners, etc.) through informal meetings or planning sessions that make information available, inform design of their HTF program, and otherwise contribute to a meaningful citizen participation process.