Action Plan
The Action Plan details the Territory’s strategy and proposed uses of the $774,188,000 in CDBG-MIT funding allocated in accordance with the USVI Supplemental Notice. It includes the Mitigation Needs Assessment (MNA), which provides an analysis of the specific conditions that are present in USVI and presents weaknesses in the disaster recovery cycle. These mitigation needs are placed in context with Community Lifelines, critical parts of communities, that when damaged present a major obstacle to full recovery. The MNA explains the risks that are present in the Territory, identifies the Community Lifelines, and provides a framework within which the Territory may determine projects that would be most effective in mitigating such risks.
It is required to update the Action Plan to stay aligned with changing priorities of the Territory. These updates initiate a substantial or a non-substantial amendment depending on the changes.
Substantial Amendments
For a Substantial Amendment, changes to the Action Plan meet one of the following criteria:
Benefits or Eligibility Criteria – A change in program benefit or eligibility criteria
Project Activities – Addition or deletion of an activity
Allocation Thresholds – The allocation or re-allocation of monetary thresholds
Covered Projects – Addition of eligible covered projects
VIHFA must amend its Action Plan to:
Update the Mitigation Needs Assessment (MNA)
Modify or create new activities
Reprogram funds
Non-substantial Amendments
A Non-Substantial Amendment is initiated for lesser modifications. These changes include, but are not
limited to:
Minor wording
Edits and clarifications
Project description updates
Smaller changes
What you should know:
Changes to the Action Plan must meet the requirements of CDBG-Mitigation activities
A public participation period includes public hearings and a 30-day comment period
VIHFA incorporates public questions, comments, and concerns into the amendment
Once submitted, the HUD review period is 45-60 days
The HUD-approved amendment supersedes all former Action Plans