HomeMy WebLinkAboutResolutions - 2026.05.21 - 42962
AGENDA ITEM: Submission of the Five-Year Consolidated Plan for Program Years 2026–2030 to
the United States Department of Housing and Urban Development
DEPARTMENT: Health & Human Services - Neighborhood and Housing Development
MEETING: Board of Commissioners
DATE: Thursday, May 21, 2026 9:30 AM - Click to View Agenda
ITEM SUMMARY SHEET
COMMITTEE REPORT TO BOARD
Resolution #2026-6573
Motion to approve the submission of the Five-Year Consolidated Plan for Program Years 2026–
2030 to the U.S. Department of Housing and Urban Development.
ITEM CATEGORY SPONSORED BY
Grant Penny Luebs
INTRODUCTION AND BACKGROUND
As an Urban County entitlement jurisdiction, Oakland County’s Neighborhood Housing &
Development (NHD) Division is responsible for preparing and submitting a Consolidated Plan every
five (5) years, along with the first-year Annual Action Plan. This cycle includes the 2026–2030
Five-Year Consolidated Plan and the Program Year (PY) 2026 Annual Action Plan, which will be
submitted to the U.S. Department of Housing and Urban Development (HUD).
These plans were developed during the 2025–2026 planning cycle and must be submitted to HUD
by June 3, 2026, which is 60 days following HUD’s confirmation of grantee entitlement amounts on
April 3, 2026.
Successful submission of the 2026–2030 Five-Year Consolidated Plan enables Oakland County to
access and deploy over $5.9 million in federal funding for Program Year 2026, supporting affordable
housing, homelessness services, public services, and community development initiatives. The
Consolidated Plan also establishes the County’s long-term priorities and strategies for the use of
CDBG, HOME, and ESG funds through 2030.
POLICY ANALYSIS
• NHD held a public hearing on the Consolidated Plan during the April 21, 2026, Citizens
Advisory Council meeting, where all comments were considered and received.
• The department has advised that, after this plan is accepted, amendments will be
forthcoming to update various internal policies that are guided by the Consolidated Plan,
including the Citizen Participation Plan, the Funding Recapture Policy for CVTs, and the
CDBG Allocation Breakdown.
• The 5-year Consolidated Plan does not require Executive Grant Review; a sign-off will not be
attached.
• The grant application for the Program Year 2026 Annual Action Plan was submitted on the
May 12, 2026, PHS agenda for review and recommendation to the Full Board.
• The last 5-year plan was accepted via resolution #21-503, for program years 2021 - 2025.
• As required by HUD, each year Oakland County prepares a detailed Annual Action Plan and
Consolidated Annual Performance and Evaluation Report (CAPER) for its HUD-funded
program. The Annual Action Plan and CAPER are submitted to HUD and posted on the
County's website after review and approval by HUD. The CAPER Evaluation for the period of
July 1, 2023 - June 30, 2024 can be found on pages 7 -8 of the attached document titled,
Oakland County 2026-2030 Con Plan & AAP.
Background and Purpose of the 5-Year Plan:
Every five years, Oakland County must prepare a strategic plan (known as the Consolidated Plan)
which governs the use of federal housing and community development grant funds that it receives
from the United States Department of Housing and Urban Development (HUD). When preparing a
Consolidated Plan, grantees must assess the needs and issues in their jurisdictions as a part of
their preparation of these documents.
Oakland County serves as the lead agency for the HOME Consortium which is comprised of the
Urban County of Oakland, Farmington Hills, Royal Oak, and Southfield; the County additionally
serves as the lead agency for administration of the CDBG and ESG programs on behalf of 52
participating communities including: the Cities of Auburn Hills, Berkley, Birmingham, Bloomfield
Hills, Clarkston, Clawson, Farmington, Ferndale, Hazel Park, Huntington Woods, Keego Harbor,
Lathrup Village, Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge,
Rochester, Rochester Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom, the Townships of
Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon,
Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake and the
Villages of Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford and
Wolverine Lake.
Note: the City of Pontiac now administers its own funding and is no longer a participating community
for Oakland County.
The Consolidated Plan identifies the programmatic goals and activities for the HOME program for
the Oakland County HOME Consortium, the CDBG and ESG goals for Oakland County and its
participating communities, and the CDBG goals for Consortium member communities for the period
of July 1, 2026 - June 30, 2030. Oakland County must also submit to HUD separate Annual Action
Plans for each of the five years during the Consolidated Plan period. The Annual Action Plans serve
as the County’s yearly applications to HUD that are required for the County to receive the annual
allocations from the three grant programs.
The 2026–2030 Consolidated Plan Goals:
• Increase and improve affordable housing options,
• Expand and improve homeless services, shelters, and prevention efforts,
• Create and sustain a suitable living environment through infrastructure and public facility
improvements,
• Provide public services to expand economic opportunity, improve safety, enhance food
access, and provide other assistance for low- and moderate income households, seniors,
people with disabilities, and other eligible groups,
• Administration of funding and projects.
FISCAL IMPACT: No Budget Amendment Needed
Committee members can contact Barbara Winter, Policy and Fiscal Analysis Supervisor at
248.821.3065 or winterb@oakgov.com or the department contact persons listed for additional
information.
CONTACT
Khadija Walker-Fobbs, Officer
ITEM REVIEW TRACKING
Aaron Snover, Board of Commissioners Created/Initiated - 5/21/2026
AGENDA DEADLINE: 05/07/2026 4:30 PM
ATTACHMENTS
1. Oakland County 2026-2030 Con Plan & AAP
2. CPD-26-05 Submitting a con plan (2)
3. Postion Schedule B 2026 AAP (5)
COMMITTEE TRACKING
2026-05-12 Public Health & Safety - Recommend to Board
2026-05-21 Full Board - Adopt
Motioned by: Commissioner Michael Gingell
Seconded by: Commissioner Penny Luebs
Yes: Ann Erickson Gault, Michael Gingell, Marcia Gershenson, Robert Hoffman, Karen Joliat,
Christine Long, Penny Luebs, Gwen Markham, William Miller III, Kristen Nelson, Angela Powell,
Robert Smiley, Yolanda Smith Charles, Michael Spisz, Linnie Taylor, Philip Weipert, David
Woodward (17)
No: Charles Cavell (1)
Abstain: None (0)
Absent: Brendan Johnson (1)
Passed
Consolidated Plan
AND 2026-2027
2026-2030
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CONTENTS
Executive Summary ............................................................................................................................................ 5
ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b) ......................................... 6
The Process ....................................................................................................................................................... 12
PR-05 Lead & Responsible Agencies 24 CFR 91.200(b) .......................................... 13
PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and 91.315(I) 15
PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c) .................... 25
Needs Assessment ............................................................................................................................................ 32
NA-05 Overview ......................................................................................................... 33
NA-10 Housing Needs Assessment - 24 CFR 91.205 (a,b,c) .................................... 34
NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2) ............ 46
NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205 (b)(2) 52
NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2) ...... 58
NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2) ......................... 60
NA-35 Public Housing – 91.205(b) ............................................................................. 62
NA-40 Homeless Needs Assessment – 91.205(c) ..................................................... 69
NA-45 Non-Homeless Special Needs Assessment - 91.205 (b,d) ............................. 72
NA-50 Non-Housing Community Development Needs – 91.215 (f) ........................... 84
Housing Market Analysis ................................................................................................................................ 86
MA-05 Overview ........................................................................................................ 87
MA-10 Number of Housing Units – 91.210(a)&(b)(2) ................................................. 88
MA-15 Housing Market Analysis: Cost of Housing - 91.210(a) .................................. 92
MA-20 Housing Market Analysis: Condition of Housing – 91.210(a) .......................... 97
MA-25 Public and Assisted Housing – 91.210(b) ..................................................... 103
MA-30 Homeless Facilities and Services – 91.210(c) .............................................. 107
MA-35 Special Needs Facilities and Services – 91.210(d) ...................................... 112
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MA-40 Barriers to Affordable Housing – 91.210(e) .................................................. 116
MA-45 Non-Housing Community Development Assets – 91.215 (f) ........................ 119
MA-50 Needs and Market Analysis Discussion ........................................................ 128
MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income ...... 134
Households - 91.210(a)(4), 91.310(a)(2) ................................................................. 134
MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3) ............................................. 140
Strategic Plan ................................................................................................................................................142
SP-05 Overview ....................................................................................................... 143
SP-10 Geographic Priorities – 91.215 (a)(1) ............................................................ 144
SP-25 Priority Needs - 91.215(a)(2) ......................................................................... 147
SP-30 Influence of Market Conditions – 91.215 (b) ................................................. 152
SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2) ................................... 153
SP-40 Institutional Delivery Structure – 91.215(k) ................................................... 158
SP-45 Goals Summary – 91.215(a)(4) ..................................................................... 164
SP-50 Public Housing Accessibility and Involvement – 91.215(c) ........................... 169
SP-55 Barriers to affordable housing – 91.215(h) .................................................... 170
SP-60 Homelessness Strategy – 91.215(d) ............................................................. 172
SP-65 Lead based paint Hazards – 91.215(i) .......................................................... 174
SP-70 Anti-Poverty Strategy – 91.215(j) .................................................................. 175
SP-80 Monitoring – 91.230 ...................................................................................... 176
2026 Annual Action Plan ...............................................................................................................................178
AP-15 Expected Resources – 91.220(c)(1,2)........................................................... 179
Annual Goals and Objectives ........................................................................................................................184
AP-20 Annual Goals and Objectives ........................................................................ 185
Projects: AP-35 Projects – 91.220(d) ....................................................................... 189
AP-38 Project Summary .......................................................................................... 191
AP-50 Geographic Distribution – 91.220(f) .............................................................. 212
Affordable Housing .......................................................................................................................................214
AP-55 Affordable Housing – 91.220(g) .................................................................... 215
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AP-60 Public Housing – 91.220(h) ........................................................................... 216
AP-65 Homeless and Other Special Needs Activities – 91.220(i) ............................ 217
AP-75 Barriers to affordable housing – 91.220(j) ..................................................... 220
AP-85 Other Actions – 91.220(k) ............................................................................. 224
Program Specific Requirements ...................................................................................................................227
AP-90 Program Specific Requirements – 91.220(l)(1,2,4) ....................................... 228
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Executive Summary
2026-2030
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ES-05 EXECUTIVE SUMMARY - 24 CFR 91.200(C), 91.220(B)
Introduction
Every five years, Oakland County must prepare a strategic plan (known as the
Consolidated Plan) which governs the use of federal housing and community
development grant funds that it receives from the United States Department of Housing
and Urban Development (HUD). When preparing a Consolidated Plan, grantees must
assess the needs and issues in their jurisdictions as a part of their preparation of these
documents.
The grant funds received from HUD by Oakland County that are covered in the
Consolidated Plan include:
• Community Development Block Grant (CDBG) Program
• Home Investment Partnerships (HOME) Program
• Emergency Solutions Grant (ESG) Program
Oakland County serves as the lead agency for the HOME Consortium which is
comprised of the Urban County of Oakland, Farmington Hills, Royal Oak, and
Southfield; the County additionally serves as the lead agency for administration of the
CDBG and ESG programs on behalf of 52 participating communities including: the
Cities of Auburn Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson,
Farmington, Ferndale, Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village,
Madison Heights, Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge,
Rochester, Rochester Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom, the
Townships of Addison, Bloomfield, Brandon, Commerce, Groveland, Highland, Holly,
Independence, Lyon, Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield,
West Bloomfield, White Lake and the Villages of Beverly Hills, Franklin, Holly, Lake
Orion, Leonard, Milford, Ortonville, Oxford and Wolverine Lake. Note: the City of
Pontiac now administers its own funding and is no longer a participating community for
Oakland County.
The Consolidated Plan identifies the programmatic goals and activities for the HOME
program for the Oakland County HOME Consortium, the CDBG and ESG goals for
Oakland County and its participating communities and the CDBG goals for Consortium
member communities for the period of July 1, 2026 - June 30, 2030.
Oakland County must also submit to HUD separate Annual Action Plans for each of the
five years during the Consolidated Plan period. The Annual Action Plans serve as the
County’s yearly applications to HUD that are required for the County to receive the
annual allocations from the three grant programs. These grants from HUD are known as
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Entitlement Grant Programs because communities receive the funds every year if they
meet program requirements and criteria associated with each of the three grants.
Summary of the objectives and outcomes identified in the Plan Needs
Assessment Overview
When preparing a Consolidated Plan, grantees must assess the needs in their
jurisdictions as a key part of the process. To inform development of priorities and goals
over the next five years, the Consolidated Plan’s Needs Assessment discusses
housing, community development, and economic development needs in the county. The
Needs Assessment relies on data from the US Census, 2019-2023 5-Year American
Community Survey (ACS), and a special tabulation of ACS data known as
Comprehensive Housing Affordability Strategy (CHAS) data that estimates the number
of households with one or more housing needs. Local data regarding homelessness
and assisted living is included. Finally, public input gathered through interviews, focus
groups, meetings, and the community survey are coupled with data analysis to identify
priority needs related to affordable housing, homelessness, assisted housing,
community development, and economic development in Oakland County.
Priority Objectives
Priorities identified during the development of Oakland County’s 2026-2030 Five-Year
Plan include:
• Increase and improve affordable housing options
• Increase and improve homeless service, shelter, and prevention efforts
• Create and sustain a suitable living environment through infrastructure and public
facility improvements
• Provide public services to expand economic opportunity, improve safety,
enhance food access, and provide other assistance for low- and moderate-
income households, seniors, people with disabilities, and other eligible groups
• Administration of funding and projects
Evaluation of past performance
As required by HUD, each year Oakland County prepares a detailed Annual Action Plan
and Consolidated Annual Performance and Evaluation Report (CAPER) for its HUD-
funded program. The Annual Action Plan and CAPER are submitted to HUD and posted
on the City’s website after review and approval by HUD. The County’s most recent
CAPER shows that Oakland County met or exceeded its program goals with the
following programs:
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• Construction of new affordable rental units: goal – 4 units constructed; actual – 4
units constructed
• Community engagement of low/mod income households: goal – 75 households
engaged; actual – 75 households engaged
• Homelessness prevention: goal – 20 persons assisted; actual – 88 persons
assisted
• Housing code enforcement and foreclosed property care for the purpose of
community engagement: goal – 300 housing units; actual – 360 housing units
• Anti-discrimination services for low/mod income households: goal – 700
households assisted; actual – 983 households assisted
• Public facility or infrastructure activities for low/moderate income housing benefit:
goal – 2000 persons assisted; actual – 20,122 persons assisted
• Homeless overnight shelter: goal – 280 persons assisted; actual – 1583 persons
assisted
Oakland County did not meet its goals with the following programs:
• Rental unit rehabilitation: goal – 125 units rehabilitated; actual – 0 units
rehabilitated (units currently under construction)
• Homeowner housing rehabilitation: goal – 225 units rehabilitated; actual – 161
units rehabilitated
• Public facility/infrastructure activities other than for low/mod income housing
benefits: goal – 300,000 persons assisted; actual – 238,113 persons assisted
• Homelessness prevention: goal – 100 persons assisted; actual – 99 persons
assisted
• Building demolition: goal – 12 units demolished; actual – 9 units demolished
• Housing code enforcement and foreclosed property care for the purpose of public
facilities and services: goal – 36,000 housing units; actual – 9,701 housing units
Summary of citizen participation process and consultation process
An important component of the research process for the Consolidated Plan involved
gathering input regarding fair and affordable housing conditions and needs in Oakland
County. The County used a variety of public engagement approaches with residents
and other stakeholders, including public meetings, focus groups, stakeholder interviews
and a community survey.
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Public Meetings
Oakland County collaborated with Mosaic Community Planning to host a total of three
(3) open community meetings on the evenings of December 9, 10, and 11, 2025.
Meetings included a presentation of the Consolidated Plan goals and an overview of the
planning process and discussion of housing and community needs. A total of 9
community members attended a meeting.
Pop-up events
Mosaic Community Planning also held four (4) informal pop-up events in Oakland
County during the week of December 8-12. These events included engaging passersby
on the Consolidated Planning process, brief discussion prompts, and an invitation to
complete the survey. A total of 43 community members were engaged at pop-up
events.
Focus Groups
Three (3) focus groups were held in December 2025 and January 2026 – one with staff
from the Community Housing Network, one with staff from the Oakland County Harm
Reduction Office, and one with the Oakland County Citizen Advisory Committee. All
groups indicated major homelessness and service needs within the County, which was
previously identified by stakeholders as a major area of concern.
Community Insight Interviews
One-on-one community insight interviews were conducted by phone during November
and December 2025. Stakeholders and service providers with important perspectives
were selected by the County and invited to participate in 30-minute phone interviews
about housing and community needs within Oakland County. A total of 15 stakeholders
provided input via phone interview.
Technical Consultations
In addition to broad stakeholder interviews, one-on-one technical consultations were
also conducted via phone in order to fulfill specific HUD consultation requirements. A
total of six (6) technical consultations were completed in the areas of: Public Land and
Water, Climate Resiliency, Continuum of Care/PHA, Housing Developers, School
District, and Workforce Development. Additionally, the Michigan High Speed Internet
Office provided information via email in the areas of Broadband Providers and
Organizations Providing Internet/Technology Access. Finally, the Oakland County Office
of Emergency Management was invited to participate in a technical consultation but did
not respond; however, the department’s current Hazard Mitigation Plan was consulted
for information in this area.
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Community Survey
Oakland County conducted an extensive public housing and community needs survey in
summer 2025. Respondents were asked for their feedback on various housing, public
facility, and public service, and homelessness needs. Over 1,500 community members
provided feedback via this survey.
Summary of public comments
Oakland County held a 30-day comment period and 2 public hearings to receive input
from residents and stakeholders on the draft Consolidated Plan prior to approval by the
Board of Commissioners and submission to HUD.
Below is a list of feedback received from members of the Board of Commissioners
appointed Citizen Advisory Council:
1. Funding Stability: Mr. Gray noted that despite early legislative concerns about the
"HOME" program, federal funding remains level for the upcoming cycle.
2. Fiduciary Roles: A distinction was made regarding the City of Southfield; while it
manages its own CDBG funds, Oakland County acts as the fiduciary pass-
through for Southfield's "HOME" funds.
3. Infrastructure Metrics: Member Henry questioned the high number of residents
served (30,000) relative to the budget.
4. Oakland County Consultant, Mr. Gray explained that infrastructure impact is
measured by the total population within the census block of a project (e.g., a new
sidewalk).
5. Member Henry- questioned if there is flexibility in administrative fees 20%
6. Oakland County Consultant, Mr. Gray advised the administrative fee of 20% is a
fixed amount of the allocation
7. Member Henry- Questioned how program income comes back to the county
8. Khadija Walker- Fobbs- Program income comes back to the county by way of
Home Improvement Program homes that sell. The amount of the Home
Improvement Loan is paid back.
Summary of comments or views not accepted and the reasons for not
accepting them
All public comments were accepted and taken into consideration in preparing the
Consolidated Plan.
Summary
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During the development of the Consolidated Plan, a set of priority needs were identified.
These priorities include:
• Increase and improve affordable housing options
• Increase and improve homeless service, shelter, and prevention efforts
• Create and sustain a suitable living environment through infrastructure and public
facility improvements
• Provide public services to expand economic opportunity, improve safety,
enhance food access, and provide other assistance for low- and moderate-
income households, seniors, people with disabilities, and other eligible groups
• Administration of funding and projects
The Consolidated Plan also contains goals, measurable objectives, and implementation
actions for each of the plan’s elements. Priority needs, goals, objectives, and
implementation actions were all derived from a combination of public input and data
analysis, as described in the following sections.
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2026-2030
The Process
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PR-05 LEAD & RESPONSIBLE AGENCIES 24 CFR 91.200(B)
Describe agency/entity responsible for preparing the Consolidated
Plan and those responsible for administration of each grant program
and funding source
The following are the agencies/entities responsible for preparing the Consolidated Plan
and those responsible for administration of each grant program and funding source.
TABLE 1 – RESPONSIBLE AGENCIES
Agency Role Name Department/Agency
CDBG Administrator OAKLAND COUNTY
HHS/Neighborhood &
Housing Development
Division
HOME Administrator OAKLAND COUNTY
HHS/Neighborhood &
Housing Development
Division
ESG Administrator OAKLAND COUNTY
HHS/Neighborhood &
Housing Development
Division
Narrative
The Oakland County Board of Commissioners (BOC) designated the Department of
Health and Human Services Oakland County Neighborhood & Housing Development
Division as the lead agency responsible for administering its CDBG, HOME and ESG
programs including the development of the Con Plan, Annual Action Plan and the
Consolidated Annual Performance and Evaluation Report. The Division serves as the
lead agency for administration of the CDBG and ESG programs on behalf of 52
participating communities including: the Cities of Auburn Hills, Berkley, Birmingham,
Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale, Hazel Park, Huntington
Woods, Keego Harbor, Lathrup Village, Madison Heights, Northville, Novi, Oak Park,
Orchard Lake Village, Pleasant Ridge, Rochester, Rochester Hills, South Lyon, Sylvan
Lake, Troy, Walled Lake, Wixom, the Townships of Addison, Bloomfield, Brandon,
Commerce, Groveland, Highland, Holly, Independence, Lyon, Milford, Oakland, Orion,
Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White Lake and the Villages of
Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville, Oxford and
Wolverine Lake.
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The Neighborhood & Housing Development Division has a long and successful history
in federal program administration, works with various partners and has the capacity to
serve as the lead agency for the Oakland County HOME Consortium. The Consortium
member communities include Oakland County, Farmington Hills, Royal Oak, and
Southfield. All the municipalities are eligible to receive and administer HUD funds and
have established housing and community development programs. All members work in
concert and with partners to extend program efficiency, scope and reach. Partnerships
include housing developers, public housing commissions, service providers, homeless
advocates and for profit and non-profit institutions.
Consolidated Plan Public Contact Information
Curtis Smith, Chief of Oakland County Neighborhood & Housing Development Division
1200 N. Telegraph Rd. 34E, Pontiac, MI 48341
(248) 858-5303
smithcud@oakgov.com
PR-10 CONSULTATION – 91.100, 91.110, 91.200(B), 91.300(B),
91.215(I) AND 91.315(I)
Introduction
Oakland County conducted an array of both virtual and in-person public engagement
opportunities to inform the Consolidated Plan’s goals and priorities. In November and
December 2025, the County partnered with Mosaic Community Planning to conduct
one-on-one community insight interviews with service providers and stakeholders, as
well as technical consultations with specific providers who held relevant insight to
specific areas of the Consolidated Plan. In December 2025, Mosaic held three in-person
public community meetings and four informal informational pop-up events, engaging a
total of 52 community members. Additionally, three virtual focus groups were held in
December 2025 and January 2026 with health homeless service providers and with the
County’s Citizen Advisory Committee to better understand needs in the County. Finally,
the County held a public community survey in summer 2025 in order to assess housing
and community needs, which received nearly 1,600 responses.
On March 17, 2026, Oakland County along with the Citizen’s Advisory Council held a
public hearing at 4:00 p.m. to hear public comments on and approve the draft
Consolidated Plan prior to approval by the Board of Commissioners and submission to
HUD. The comment period ran from March 17 to April 21, 2026. The County received
no written comments on the plan.
Provide a concise summary of the jurisdiction’s activities to enhance
coordination between public and assisted housing providers and
private and governmental health, mental health and service agencies
(91.215(I)).
The Alliance for Housing, which serves as Oakland County’s Continuum of Care (CoC),
plays a crucial role in enhancing coordination between public and private providers and
agencies. The Alliance currently maintains a roster of 37 different organizations and
service providers who participate in a jurisdiction-wide coordinated services agreement,
including public and assisted housing providers and public and private health, mental
health, and other service agencies.
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Describe coordination with the Continuum of Care and efforts to
address the needs of homeless persons (particularly chronically
homeless individuals and families, families with children, veterans,
and unaccompanied youth) and persons at risk of homelessness
Two focus groups were held with service providers in Oakland County in order to
assess and address the needs of homeless persons – one with Oakland County Harm
Reduction staff and one with Community Housing network staff. Additionally, the
Continuum of Care (Alliance for Housing) was directly involved and referenced via a
one-on-one phone interview with their executive director and the inclusion of their
annually published report data in relevant sections of the Consolidated Plan. Other
organizations interviewed with important perspectives on homelessness included South
Oakland Citizens for the Homeless (Welcome Inn), Lighthouse, Ferncare Free Clinic,
and the Affirmations Community Center.
Describe consultation with the Continuum(s) of Care that serves the
jurisdiction's area in determining how to allocate ESG funds, develop
performance standards and evaluate outcomes, and develop funding,
policies and procedures for the administration of HMIS
Oakland County consulted and directly involved the Continuum of Care, Alliance for
Housing, by conducting a one-on-one interview with the Alliance’s executive director in
order to better understand needs. Additionally, data from the Alliance’s annual report is
included in relevant sections of this Consolidated Plan.
Describe Agencies, groups, organizations and others who participated in the process and
describe the jurisdictions consultations with housing, social service agencies and other entities
TABLE 2 – AGENCIES, GROUPS, ORGANIZATIONS WHO PARTICIPATED
Agency/Group/Organization Agency/Group/
Organization Type
What section of the Plan was
addressed by Consultation?
How was the
Agency/Group/Organization
consulted and what are the
anticipated outcomes of the
consultation or areas for
improved coordination?
Affirmations Community
Center
Services – Health
Services – Mental
Health
Services –
Narrowing the
Digital Divide
Non-Homeless Special Needs
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Alliance for Housing CoC Homeless Needs Assessment
Executive director of agency
was interviewed via phone;
data from agency’s annual
report is presented below.
Oakland County will continue
to coordinate with the Alliance
for Housing as the
jurisdiction’s CoC.
Centro Multicultural La Services – Health Housing Needs Assessment Phone interview; Oakland
County will continue to invite
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Familia Services – Mental
Health
Services –
Education
Services – Victims
of Domestic
Violence
Anti-Poverty Strategy in consultation opportunities.
Farmington Hills Planning
and Community Development
Other Government -
Local
Housing Needs Assessment
Market Analysis
Phone interview; Oakland
County will continue to invite
the City to participate in
consultation opportunities.
Gary Bernstein Community
Health Clinic Services – Health Non-Homeless Special Needs
Anti-Poverty Strategy
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Lighthouse
Services –
Homeless
Services - Housing
Homeless Needs Assessment
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Micah 6 Community
Services – Children
Services –
Education
Housing Needs Assessment
Non-Homeless Special Needs
Anti-Poverty Strategy
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Michigan High Speed Internet Other Government – Non-Homeless Special Needs Email consultation; Oakland
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Office State
Services –
Broadband
Services –
Narrowing the
Digital Divide
Anti-Poverty Strategy consult on relevant issues.
Oakland County Citizen
Advisory Committee
Services –
Employment
Services –
Education
Services – Children
Services - Health
Housing Needs Assessment
Non-Homeless Special Needs
Economic Development
Anti-Poverty Strategy
Focus group; Oakland County
will continue to invite the
organization to participate in
consultation opportunities.
Oakland County Emergency
Management
Other Government –
County
Agency –
Emergency
Management
Non-Homeless Special Needs
Invited to participate in phone
interview; Oakland County
will continue to invite the
organization to participate in
consultation opportunities.
Oakland County Land Bank
Authority
Other Government –
County
Agency – Public
Land Management
Housing Need Assessment
Market Analysis
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Oakland County
Neighborhood and Housing
Other Government –
County Housing Need Assessment Lead agency
20
Development Department Homeless Needs Assessment
Market Analysis
Economic Development
Anti-Poverty Strategy
Oakland County Office of
Sustainability
Other Government –
County
Agency – Climate
Resiliency
Hazard Mitigation
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Oakland County Planning
Department
Other Government –
County
Agency – Planning
Housing Need Assessment
Homeless Needs Assessment
Market Analysis
Economic Development
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Oakland County Transit Other Government –
County
Non-Homeless Special Needs
Anti-Poverty Strategy
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Oakland County Workforce
Development
Other Government –
County
Agency – Workforce
Development
Market Analysis
Anti-Poverty Strategy
Economic Development
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
21
Oakland Livingston Human
Service Agency (OLHSA)
Services –
Employment
Services –
Education
Services – Health
Services –
Homeless
Services - Housing
Housing Need Assessment
Homeless Needs Assessment
Non-Homeless Special Needs
Anti-Poverty Strategy
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Oakland Schools
Services – Children
Services –
Education
Non-Homeless Special Needs
Anti-Poverty Strategy
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
Rochester Housing Solutions Services – Housing
Housing Need Assessment
Non-Homeless Special Needs
Anti-Poverty Strategy
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
South Oakland Citizens for
the Homeless (SOCH) Services - Homeless Homeless Needs Assessment
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
We Preserve Michigan Services - Housing Housing Need Assessment
Market Analysis
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
22
Welcome Oakland Other Government –
County
Non-Homeless Special Needs
Phone interview; Oakland
County will continue to invite
the organization to participate
in consultation opportunities.
23
Identify any Agency Types not consulted and provide rationale for not
consulting
Extensive efforts were made to consult a wide variety of community stakeholders,
service providers, and organizations throughout Oakland County. Engagement methods
are detailed above. No agency types were excluded from outreach efforts.
Other local/regional/state/federal planning efforts considered when preparing the
Plan
TABLE 3 – OTHER LOCAL / REGIONAL / FEDERAL PLANNING EFFORTS
Describe cooperation and coordination with other public entities,
including the State and any adjacent units of general local
government, in the implementation of the Consolidated Plan
(91.215(l))
Oakland County serves as the lead agency for both the CDBG participating
communities and the HOME consortium. Member communities were invited to
participate in the community feedback process and are eligible to apply for project
funding via CDBG and HOME grant funding. Implementation of the Consolidated Plan
Name of Plan Lead Organization
How do the goals of your
Strategic Plan overlap
with the goals of each
plan?
Oakland County Analysis
of Impediments to Fair
Housing Choice (2020)
Oakland County Expanding affordable
housing access
Oakland County Hazard
Mitigation Plan (2023) Oakland County Hazard mitigation
Oakland County Citizen
Participation Plan Oakland County
Expanding citizen
participation, community
engagement, and outreach
efforts
Alliance for Housing
Annual Report (2025) Alliance for Housing (CoC)
Homeless needs
assessment and service
provision
24
will primarily happen through projects from these participating communities, as well as
countywide projects from Oakland County as a whole.
25
PR-15 CITIZEN PARTICIPATION – 91.105, 91.115, 91.200(C) AND
91.300(C)
Summary of citizen participation process/Efforts made to broaden
citizen participation
An important component of the research process for the Consolidated Plan involved
gathering input regarding fair and affordable housing conditions and needs in Oakland
County. The County used a variety of public engagement approaches with residents
and other stakeholders, including public meetings, focus groups, stakeholder interviews
and a community survey. Input from these efforts is incorporated throughout the
Consolidated Plan and was used to inform its priorities and goals.
Public Meetings
Oakland County collaborated with Mosaic Community Planning to host a total of three
(3) open community meetings on the evenings of December 9, 10, and 11, 2025.
Meetings included a presentation of the Consolidated Plan goals and an overview of the
planning process and discussion of housing and community needs. A total of 9
community members attended a meeting.
Pop-up events
Mosaic Community Planning also held four (4) informal pop-up events in Oakland
County during the week of December 8-12. These events included engaging passersby
on the Consolidated Planning process, brief discussion prompts, and an invitation to
complete the survey. A total of 43 community members were engaged at pop-up
events.
Focus Groups
Three (3) focus groups were held in December 2025 and January 2026 – one with staff
from the Community Housing Network, one with staff from the Oakland County Harm
Reduction Office, and one with the Oakland County Citizen Advisory Committee. All
groups indicated major homelessness and service needs within the County, which was
previously identified by stakeholders as a major area of concern.
Community Insight Interviews
One-on-one community insight interviews were conducted by phone during November
and December 2025. Stakeholders and service providers with important perspectives
were selected by the County and invited to participate in 30-minute phone interviews
26
about housing and community needs within Oakland County. A total of 15 stakeholders
provided input via phone interview.
Technical Consultations
In addition to broad stakeholder interviews, one-on-one technical consultations were
also conducted via phone in order to fulfill specific HUD consultation requirements. A
total of six (6) technical consultations were completed in the areas of: Public Land and
Water, Climate Resiliency, Continuum of Care/PHA, Housing Developers, School
District, and Workforce Development. Additionally, the Michigan High Speed Internet
Office provided information via email in the areas of Broadband Providers and
Organizations Providing Internet/Technology Access. Finally, the Oakland County Office
of Emergency Management was invited to participate in a technical consultation but did
not respond; however, the department’s current Hazard Mitigation Plan was consulted
for information in this area.
Community Survey
Oakland County conducted an extensive public housing and community needs survey in
summer 2025. Respondents were asked for their feedback on various housing, public
facility, and public service, and homelessness needs. Over 1,500 community members
provided feedback via this survey.
27
Citizen Participation Outreach
TABLE 4 – CITIZEN PARTICIPATION OUTREACH
Sort Order Mode of Outreach Target of Outreach Summary of
response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
1 Public Meetings Non-targeted/
broad community 9 participants
• Specific housing needs vary
significantly throughout the County,
but affordability is a major concern
throughout
• Many residents are unclear on how
to access resources and services,
especially in rural areas
• Transit needs exist throughout the
County but are exacerbated in rural
areas
None
2 Pop-up Events Non-targeted/
broad community 43 participants
• Residents are concerned with new
initiatives staying true to the existing
character of a neighborhood
• Housing prices are significantly
outpacing wages
None
3 Focus Groups Other – Service
Providers 33 participants
• There is a significant lack of
emergency and warming shelters –
service providers have experienced
clients freezing to death.
• Lack of internet and device access is
a major barrier for homeless
residents trying to access services.
• The only available street outreach
services target very specific
None
28
populations, leaving many people
out.
• Transportation is a significant issue
for residents experiencing
homelessness.
• The ending of homelessness
prevention programs and fundings
that were created during COVID is a
major issue.
• There is a substantial need for all
types of anti-displacement initiatives
– eviction prevention, aging in place,
accessibility modifications, etc.
4 Community Insight
Interviews
Non-English
speaking: Spanish
Minorities
Other – Service
Providers
15 participants
• Affordable housing is the County’s
largest single issue
• There is a significant lack of basic
resources available in Spanish,
creating barriers to home ownership
especially
• Most resources are located in the
southern portion of the County near
Pontiac, exacerbating transit issues
especially for homeless residents
• Some areas of the County are food
deserts, which especially impacts
people without cars
• Significant need for senior home
rehab and aging in place initiatives
None
5 Technical
Consultations
Other – Technical
Experts 7 participants
• The Land Bank is doing important
work that needs to be expanded
• Climate resiliency is a growing
concern in the County; the County is
None
29
in the process of developing a
climate vulnerability assessment
template
• A lack of transportation is a major
barrier to resource access
• There were many more
homelessness prevention initiatives
in the 2010s, but the funding has
dried up
• The end of ARPA funding is causing
significant issues in homeless
services
• Housing vouchers are not keeping up
with housing costs
• Critical emergency repair needs are
common for low-income residents
who may not know how to get help
• There has been a reduction in
state/federal workforce funding that
is harmful
• Oakland County presents very
unique needs and concerns due to
its very large size, large number of
communities, and large amount of
rural land
6 Community Survey Non-targeted/
broad community 1,576 responses
• There is a large need for additional
parks, recreation, and childcare
facilities, as well as senior centers
and day centers for disabled adults
• There is a large need for street,
sidewalk, and drain improvement
• A lack of affordable housing is a
major issue
None
30
• Aging in place, homeless services
and prevention, and resources for
low-income disabled residents are
the top three concerns
• The top three housing focuses
should be homeless services and
resources, emergency and essential
rehab/repair, and affordable home
ownership opportunities
• Over one-quarter of respondents did
not know about the services and
resources offered by the County
7 Public Comment
Period
Non-targeted/
broad community
A public hearing was
held on March 17,
2026 (27 individuals
present) with a 30 day
comment period
through April 17, 2026
A second hearing was
held on April 21,
2026 (19 individuals
present)
• It was noted that federal HOME
funding is expected to remain
stable for the upcoming program
cycle, despite earlier concerns
about potential reductions.
• A clarification was made
regarding fiduciary
responsibilities: although one
community administers its own
CDBG funds, the County serves
as the pass through entity for its
HOME allocation.
• Questions were raised about
infrastructure reporting metrics,
specifically why the number of
residents served appears high
relative to project budgets.
• It was explained that
infrastructure impact is
calculated based on the total
population within the census
block where the improvement
None
31
of individuals directly receiving a
service.
• A question was raised about
whether there is flexibility in the
20% administrative cap. It was
clarified that the 20%
administrative allowance is fixed
and cannot be adjusted.
• Additional clarification was
requested regarding how
program income is returned
to the County. It was noted
that program income is
generated primarily through
the Home Improvement
Program when assisted
homes are sold and the
loan amount is repaid.
32
2026-2030
Needs Assessment
33
NA-05 OVERVIEW
Needs Assessment Overview
To inform development of priorities and goals over the next five years, this section of the
Consolidated Plan discusses housing, community development, and economic
development needs in Oakland County. It relies on data from the U.S. Census, the
2016-2020 5-Year American Community Survey (ACS), and a special tabulation of ACS
data known as Comprehensive Housing Affordability Strategy (CHAS) data that
estimates the number of households with one or more housing needs. Local data
regarding homelessness and assisted housing is included. Finally, public input gathered
through stakeholder interviews, focus groups, meetings, and the community survey are
coupled with data analysis to identify priority needs related to affordable housing,
homelessness, assisted housing, community development, and economic development
in Oakland County.
Key Findings
• Cost burden is the most common housing problem among all Oakland County
households
• Renter households are disproportionately impacted by housing problems
• Extremely low income Black households exhibit disproportionately high rates of
severe housing problems
34
FIGURE 1. RATES OF HOUSING PROBLEMS BY TENURE, OAKLAND COUNTY, 2010 TO 2020
30%
23%
19%
45%44%
41%
34%
29%
25%
0%
10%
20%
30%
40%
50%
2010 2015 2020
Owner Renter Total
35
NA-10 HOUSING NEEDS ASSESSMENT - 24 CFR 91.205 (A,B,C)
Summary of Housing Needs
According to the 2016-2020 5-Year American Community Survey, the population in the
Oakland County entitlement jurisdiction is comprised of 907,575 residents and 358,825
households. Oakland County’s population increased by 4% between 2009 and 2020.
The number of households also increased by 6% during this period, from 339,290 to
358,825. Median household income in Oakland County increased by 21% between
2009 and 2020 from an estimated $67,465 to $81,587.
Table 6 segments households by income and household type, including small families
(2-4 members), large families (5 or more members), households with seniors, and
households with young children. As shown, 103,243 households in Oakland County
have low or moderate incomes (under 80% of HUD Adjusted Median Family Income
(HAMFI)) and together constitute more than a quarter (29%) of all households in the
county. Households with seniors aged 62-74 comprise the largest portion (27%) of
households with low or moderate incomes followed by small family households (25%)
and households with seniors 75 or older (21%). Large family households have the
smallest proportion of low- or moderate-income households (4%), followed by those
with young children age 6 or under (9%).
For many low- and moderate-income households in Oakland County, finding and
maintaining suitable housing at an affordable cost is a challenge. Table 7 through Table
12 identify housing needs by tenure based on Comprehensive Housing Affordability
Strategy (CHAS) data. CHAS data is a special tabulation of the U.S. Census Bureau’s
American Community Survey (ACS) that is largely not available through standard
Census products. This special dataset provides counts of the number of households
that fit certain combinations of HUD-specified housing needs, HUD-defined income
limits (primarily 30, 50, and 80% of HAMFI), and household types of particular interest
to planners and policy makers.
To assess affordability and other types of housing needs, HUD defines four housing
problems:
• Cost burden: A household has a cost burden if its monthly housing costs
(including mortgage payments, property taxes, insurance, and utilities for owners
and rent and utilities for renters) exceed 30% of monthly income.
• Overcrowding: A household is overcrowded if there is more than 1 person per
room, not including kitchens and bathrooms.
36
• Lack of complete kitchen facilities: A household lacks complete kitchen facilities if
it lacks one or more of the following: cooking facilities, refrigerator, or a sink with
piped water.
• Lack of complete plumbing facilities: A household lacks complete plumbing
facilities if it lacks one or more of the following: hot and cold piped water, a flush
toilet, or a bathtub or shower.
HUD also defines four severe housing problems, including a severe cost burden (more
than 50% of monthly household income is spent on housing costs), severe
overcrowding (more than 1.5 people per room, not including kitchens or bathrooms),
lack of complete kitchen facilities (as described above), and lack of complete
plumbing facilities (as described above).
Table 7 indicates a total of 71,023 households, approximately 20% of all households in
Oakland County, experience one of the listed housing problems. Data for households
experiencing severe housing problems provided in Table 8 shows that approximately
10% of all households (34,934 households) experience one or more severe housing
problems listed.
Overall, the most common housing problem in Oakland County is cost burden,
regardless of tenure type. Nearly two-thirds (64%) of all households with incomes under
80% HAMFI (HUD adjusted median family income) in the county experience cost
burdens. Severe cost burdens affect 17,353 owners and 14,664 renters in total,
comprising almost half (49%) of all cost burdened households in Oakland County. For
the lowest income households (those with incomes under 30% HAMFI), severe cost
burdens are most common, impacting 87% of all households at that income level.
While the primary housing issue facing low- and moderate-income residents is related
to affordability, there are other housing needs in the county. Less than 2% of all
households experience overcrowding (or are doubled up); reside in substandard
housing or lack complete plumbing and kitchen facilities; or have zero or negative (no)
income.
The remainder of this section characterizes local housing needs in more detail. The
Market Analysis component of the Consolidated Plan identifies resources available to
respond to these needs (public housing, tax credit and other subsidized properties,
housing and services for the homeless, and others).
37
TABLE 5 - HOUSING NEEDS ASSESSMENT DEMOGRAPHICS
Demographics Base Year: 2009 Most Recent Year: 2020 %
Change
Population 869,135 907,575 4%
Households 339,290 358,825 6%
Median Income $67,465.00 $81,587.00 21%
DATA SOURCE: 2000 CENSUS (BASE YEAR), 2016-2020 ACS (MOST RECENT YEAR)
Number of Households Table
TABLE 6 - TOTAL HOUSEHOLDS TABLE
DATA SOURCE: 2016-2020 CHAS
0-30%
HAMFI
>30-
50%
HAMFI
>50-
80%
HAMFI
>80-
100%
HAMFI
>100%
HAMFI
Total Households 26,839 28,709 47,695 29,935 225,675
Small Family Households 5,640 7,103 13,450 10,136 119,960
Large Family Households 929 1,101 2,393 1,892 18,290
Household contains at least one
person 62-74 years of age 7,231 7,707 13,453 8,076 48,547
Household contains at least one
person age 75 or older 5,247 6,829 9,565 3,951 17,161
Households with one or more
children 6 years old or younger 1,933 2,466 5,350 3,541 21,485
38
Housing Needs Summary Tables
1. Housing Problems (Households with one of the listed needs)
TABLE 7 – HOUSING PROBLEMS TABLE
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100
%
AMI
Total
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100
%
AMI
Total
NUMBER OF HOUSEHOLDS
Substandard
Housing -
Lacking
complete
plumbing or
kitchen
facilities
273 330 270 85 958 107 14 74 32 227
Severely
Overcrowded -
With >1.51
people per
room (and
complete
kitchen and
plumbing)
105 50 100 49 304 0 4 49 10 63
Overcrowded -
With 1.01-1.5
people per
room (and
none of the
above
problems)
139 256 242 128 765 42 155 236 164 597
Housing cost
burden greater
than 50% of
income (and
none of the
above
problems)
8,978 4,162 1,330 194 14,664 8,291 4,833 3,251 978 17,353
39
DATA SOURCE: 2016-2020 CHAS
2. Housing Problems 2 (Households with one or more Severe Housing Problems:
Lacks kitchen or complete plumbing, severe overcrowding, severe cost burden)
TABLE 8 – HOUSING PROBLEMS 2
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100
%
AMI
Total
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100
%
AMI
Total
Housing cost
burden greater
than 30% of
income (and
none of the
above
problems)
1,607 5,024 5,798 1,245 13,674 1,841 5,606 8,093 4,338 19,878
Zero/negative
Income (and
none of the
above
problems)
1,056 0 0 0 1,056 1,484 0 0 0 1,484
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100
%
AMI
Total
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
NUMBER OF HOUSEHOLDS
Having
1 or
more of
four
housing
problem
s
9,502 4,797 1,930 452 16,681 8,437 5,013 3,627 1,176 18,253
40
DATA SOURCE: 2016-2020 CHAS
3. Cost Burden > 30%
TABLE 9 – COST BURDEN > 30%
DATA SOURCE: 2016-2020 CHAS
Having
none of
four
housing
problem
s
4,726 6,713 13,587 8,163 33,189 4,158 12,173 28,540 20,120 64,991
Househ
old has
negative
income,
but
none of
the
other
housing
problem
s
0 0 0 0 0 0 0 0 0 0
Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
NUMBER OF HOUSEHOLDS
Small Related 2,516 2,495 2,123 7,134 2,323 2,659 3,333 8,315
Large Related 368 263 153 784 438 447 606 1,491
Elderly 3,958 3,176 2,213 9,347 5,286 5,500 5,652 16,438
Other 4,151 3,715 2,747 10,613 2,167 1,919 1,854 5,940
Total need by
income 10,993 9,649 7,236 27,878 10,214 10,525 11,445 32,184
41
4. Cost Burden > 50%
TABLE 10 – COST BURDEN > 50%
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
NUMBER OF HOUSEHOLDS
Small Related 0 0 987 987 2,096 1,464 0 3,560
Large Related 0 0 54 54 379 277 213 869
Elderly 2,986 2,021 708 5,715 4,092 2,334 1,670 8,096
Other 0 3,743 1,387 5,130 1,841 0 0 1,841
Total need by
income 2,986 5,764 3,136 11,886 8,408 4,075 1,883 14,366
DATA SOURCE: 2016-2020 CHAS
5. Crowding (More than one person per room)
TABLE 11 – CROWDING INFORMATION – 1/2
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
NUMBER OF HOUSEHOLDS
Single family
households 219 292 300 109 920 18 110 217 128 473
Multiple,
unrelated
family
households
25 0 35 37 97 24 45 77 49 195
42
Other, non-
family
households
10 14 8 30 62 0 4 0 0 4
Total need by
income 254 306 343 176 1,079 42 159 294 177 672
DATA SOURCE: 2016-2020 CHAS
TABLE 12 – CROWDING INFORMATION – 2/2
Describe the number and type of single person households in need of
housing assistance.
Estimates of the number of non-elderly single person households in need of housing
assistance are included in the “other, non-family” category of Table 9 and in Table 10.
This category includes multi-person households whose members are unrelated (e.g.,
roommates, un-married partners, etc.). There are an estimated 16,553 single-person or
multi-person unrelated households with low or moderate incomes who spend more than
30% of their income on housing. Single-person or multi-person unrelated households
comprise 28% of all households experiencing cost burdens. Renters comprise a
majority (64%) of this subgroup while the remaining 36% are owners.
For renter households, over one-third (38%) of single person households experiencing
cost burdens have very low incomes (0-30% HAMFI), 35% have low incomes (>30-50%
HAMFI), and 26% have moderate incomes (>50-80% AMI). The breakdown is similar for
owner households with cost burdens. However, moderate-income owner households
with cost burdens (31%) comprise a slightly larger share compared to moderate-income
renter households with cost burdens (26%).
Approximately forty-two percent (6,971 households) of single-person, non-family
households with cost burdens have housing costs that exceed 50% of their income.
Single person, non-family renters and owners with severe housing cost burdens
Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
Households
with Children
Present
43
comprise 43% and 13% of all households with severe housing cost burdens,
respectively. Approximately 26% of single person households experiencing severe cost
burdens are households with incomes under 30% HAMFI. The proportion increases to
80% when including the number of single person households with incomes under 50%
HAMFI.
Table 11 provides data for single-person, non-family households that indicate a total of
66 households experience overcrowding, comprising 4% of all households that
experience problems with overcrowding.
Estimate the number and type of families in need of housing
assistance who are disabled or victims of domestic violence, dating
violence, sexual assault and stalking.
Data gathered from the 2016-2020 ACS estimates 145,790 disabled persons residing in
Oakland County, approximately 12% of the county’s total population. Using 2016-2020
CHAS data, there are approximately 83,130 households with at least one of the four
housing problems that have a member with a disability.
The Michigan State Police publishes statistics on services provided to domestic
violence victims by county through the Michigan Incident Crime Reporting (MICR) crime
dashboard. During 2024, approximately 5,144 victims were served across Oakland
County. 79% of the victims were provided with emergency shelter and 37% of victims
were provided with transitional or other housing programs. The survey also identified
62% of unmet requests were related to housing. There is no data to indicate the
availability of shelter services for victims of domestic violence specifically in Oakland
County, however, HAVEN Oakland assists domestic violence victims in finding housing
or shelter.
What are the most common housing problems?
CHAS data indicates the most common housing problems in Oakland County
regardless of tenure type are unaffordable housing costs. Nearly one-fifth of all
households in Oakland County experience housing cost burdens, of which 92% are low-
to moderate-income households. The proportion of low- to moderate-income
households increases to 96% among households experiencing severe housing cost
burdens. Examining extremely low-income households in particular shows that 64% of
all households with incomes under 30% HAMFI experience severe cost burdens.
In addition to CHAS data on housing cost burdens, housing affordability problems in
Oakland County are implied by homelessness data published by the regions Continuum
of Care (CoC), the Alliance for Housing. According to their Community Dashboard, the
Alliance for Housing served 2,553 people during 2025, 932 of which were people
experiencing homelessness.
44
Are any populations/household types more affected than others by
these problems?
According to Table 8, renter households are disproportionately affected by severe
housing problems than owner households. Approximately one-third (33%) of all renter
households in Oakland County experience one or more severe housing problems
compared to 22% of owner households. Table 8 also indicates renters with income less
than 30% HAMFI comprise more than half (52%) of all households experiencing one or
more severe housing problems. The proportion balloons to 78% when including the
number of renter households with incomes under 50% HAMFI. Table 7 shows both
renter and owner households with incomes less than 30% HAMFI comprise the largest
percentage (34%) of households that experience one of the listed housing problems.
The number of renter households (1,069) that experience overcrowding is larger than
the number of owner households (660) with the same problem. Ninety percent (90%) of
all cost burdened households are comprised of households with very low to moderate
income.
Describe the characteristics and needs of Low-income individuals
and families with children (especially extremely low-income) who are
currently housed but are at imminent risk of either residing in shelters
or becoming unsheltered 91.205(c)/91.305(c)). Also discuss the needs
of formerly homeless families and individuals who are receiving rapid
re-housing assistance and are nearing the termination of that
assistance
According to the 2016-2020 5-Year ACS data, 7.8% of residents in Oakland County are
living at or below the poverty level. Proportionately, Black (14%), unemployed (24%),
children under the age of 18 (9%), and people who have not graduated high school
(20%) are more likely to live at or below poverty level. Twenty-three percent (23%) of all
families that have a female householder with children and no spouse are below poverty
level, significantly higher than the proportion of married couple families with children
below poverty (3%).
Low wages, rising rental costs, and the scarcity of affordable housing for low- and
extremely low-income households place vulnerable households at even greater risk for
eviction or homelessness. Individuals and families at imminent risk and those who have
experienced homelessness and are receiving rapid re-housing assistance often face a
myriad of barriers including prior histories of homelessness or eviction, chronic physical
or mental disabilities, poor credit, criminal histories, and limited access to additional
education or job skills training. The greatest need of formerly homeless families and
45
individuals receiving rapid re-housing assistance is the availability of standard housing
that is affordable to households at or below 50% AMI.
For formerly homeless families and individuals nearing the termination of assistance,
the top needs are for increased, sustainable income (earned and unearned); access to
Social Security disability and other mainstream benefits; linkages to health, mental
health, and legal services; access to affordable transportation and childcare; access to
transitional and supportive housing programs; and ongoing case management and
supportive services.
If a jurisdiction provides estimates of the at-risk population(s), it
should also include a description of the operational definition of the
at-risk group and the methodology used to generate the estimates:
The Community Housing Network (CHN) provides homelessness prevention services to
households at imminent risk of homelessness through short-term financial assistance
and housing case management services. According to their 2024 Annual Report, they
served 106 individuals through this program between 2023 and 2024. The CHN uses
HUD’s Category 2 – Imminent Risk of Homelessness definition to determine eligibility
for this program, which defines households that will imminently lose their primary
nighttime residence, provided that “residence will be lost within 14 days of the date of
application for assistance; no subsequent residence has been identified; and the
households lacks resources or support networks needed to obtain other permanent
housing”. Applicants must also be a resident of Oakland County and have an annual
gross income below 30% Area Median Income (AMI).
Specify particular housing characteristics that have been linked with
instability and an increased risk of homelessness
The most fundamental risk factor for homelessness is extreme poverty, leading to
unaffordable rents or homeowner costs. Renters with incomes under 30% HAMFI and
housing cost burdens over 50% are at risk of homelessness, especially if they
experience a destabilizing event such as a job loss, reduction in work hours, or medical
emergency/condition. Such factors may also put low-income homeowners at risk of
foreclosure and subsequent homelessness.
46
NA-15 DISPROPORTIONATELY GREATER NEED: HOUSING
PROBLEMS – 91.205 (B)(2)
Assess the need of any racial or ethnic group that has disproportionately greater need
in comparison to the needs of that category of need as a whole.
Introduction
This section assesses the housing needs of racial and ethnic groups at various income
levels in comparison to needs at that income level as a whole to identify any
disproportionately greater needs. According to HUD, a disproportionately greater need
exists when members of a racial or ethnic group at a given income level experience
housing problems at a greater rate (10 percentage points or more) than the income
level as a whole. Table 13 through Table 16 identify the number of households
experiencing one or more of the four housing problems by householder race, ethnicity,
and income level. The four housing problems include: (1) cost burdens (paying more
than 30% of income for housing costs); (2) overcrowding (more than 1 person per
room); (3) lacking complete kitchen facilities; and (4) lacking complete plumbing
facilities.
Income classifications include:
• Extremely low income – up to 30% of area median income (AMI) or $32,150 for a
family of four;
• Very low income – 30 to 50% AMI or $32,151 to $50,500 for a family of four;
• Low income – 50 to 80% AMI or $50,501 to $80,800 for a family of four; and
• Moderate income – 80 to 100% AMI or $80,801 to $101,000 for a family of four.
47
0%-30% of Area Median Income
TABLE 13 - DISPROPORTIONALLY GREATER NEED 0 - 30% AMI
DATA SOURCE: 2016-2020 CHAS
*The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete
plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
Housing Problems
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 20,854 2,667 2,187
White 16,932 2,337 1,658
Black / African American 2,334 119 188
Asian 824 120 209
American Indian, Alaska
Native 65 18 0
Pacific Islander 15 0 0
Hispanic 493 70 70
48
30%-50% of Area Median Income
TABLE 14 - DISPROPORTIONALLY GREATER NEED 30 - 50% AMI
DATA SOURCE: 2016-2020 CHAS
*The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete
plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
Housing Problems
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 19,492 6,666 0
White 16,431 5,886 0
Black / African American 1,408 273 0
Asian 660 95 0
American Indian, Alaska
Native 39 59 0
Pacific Islander 65 0 0
Hispanic 739 258 0
49
50%-80% of Area Median Income
TABLE 15 - DISPROPORTIONALLY GREATER NEED 50 - 80% AMI
DATA SOURCE: 2016-2020 CHAS
*The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete
plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
Housing Problems
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 22,245 22,130 0
White 19,199 19,495 0
Black / African American 1,875 1,355 0
Asian 580 553 0
American Indian, Alaska
Native 25 134 0
Pacific Islander 0 0 0
Hispanic 448 310 0
50
80%-100% of Area Median Income
TABLE 16 - DISPROPORTIONALLY GREATER NEED 80 - 100% AMI
DATA SOURCE: 2016-2020 CHAS
*The four housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks complete
plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
Discussion
Housing needs are most likely to impact the lowest income households. For households
with incomes under 30% AMI, more than four-fifths (81%) of households have a housing
problem. Three-fourths (75%) of very low-income households (30 to 50% AMI) have a
housing problem, as do half (50%) of low-income households (50 to 80% AMI). Among
moderate income households (80 to 100% AMI), about 37% of households have a
housing problem. Disproportionate needs impact several racial and ethnic groups, as
described below.
Extremely Low Incomes (< 30% AMI)
Overall, 81% of extremely low-income households have a housing problem. Though
overall numbers are low, Pacific Islander households have disproportionate need: 100%
Housing Problems
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 10,709 18,306 0
White 9,069 16,198 0
Black / African American 831 1,036 0
Asian 519 572 0
American Indian, Alaska
Native 10 0 0
Pacific Islander 0 0 0
Hispanic 167 282 0
51
of the fifteen (15) Pacific Islander households in this income band have a housing
problem.
Very Low Incomes (30-50% AMI)
Overall, 75% of very low-income households have a housing problem. Again, Pacific
Islander households have disproportionate need: 100% of the 65 Pacific Islander
households in this income band have a housing problem. Very low-income Asian
households also exhibit disproportionate need, with 87% having a housing problem.
Additionally, very low-income Black and African American households also exhibit high
rates of housing problems (84%), just one percentage point difference away from
meeting HUD’s definition of disproportionate need.
Low Incomes (50-80% AMI)
Overall, 50% of low-income households have a housing problem. There are no groups
with disproportionate need. However, 59% of low-income Hispanic households have a
housing problem along with 58% of low-income Black households. These groups are
only a 1 and 2 percentage point difference away from meeting HUD’s definition of
disproportionate need, respectively.
Moderate Incomes (80-100% AMI)
Overall, 37% of moderate-income households have a housing problem. In this income
bracket, Asian households exhibit disproportionate need, with 48% having a housing
problem. Additionally, 100% of the ten (10) moderate-income American Indian/Alaska
Native households have a housing problem, exhibiting disproportionate need. Again, the
rate of housing problems among moderate-income Black households is higher (45%),
but not considered disproportionate in comparison to the overall income category.
52
NA-20 DISPROPORTIONATELY GREATER NEED: SEVERE HOUSING
PROBLEMS – 91.205 (B)(2)
Assess the need of any racial or ethnic group that has disproportionately greater need
in comparison to the needs of that category of need as a whole.
Introduction
This section assesses the severe housing needs of racial and ethnic groups at various
income levels in comparison to severe needs at that income level as a whole to identify
any disproportionately greater needs. Like the preceding analysis, this section uses
HUD’s definition of disproportionately greater need, which occurs when one racial or
ethnic group at a given income level experiences housing problems at a rate that is at
least 10 percentage points greater than the income level as a whole.
Table 17 through Table 20 identify the number of households with one or more of the
severe housing needs by householder race and ethnicity. The four severe housing
problems include: (1) severe cost burden (paying more than 50% of income for housing
and utilities); (2) severe crowding (more than 1.5 people per room); (3) lack of complete
kitchen facilities; and (4) lack of complete plumbing facilities.
Income classifications include:
• Extremely low income – up to 30% of area median income (AMI) or $32,150 for a
family of four;
• Very low income – 30 to 50% AMI or $32,151 to $50,500 for a family of four;
• Low income – 50 to 80% AMI or $50,501 to $80,800 for a family of four; and
• Moderate income – 80 to 100% AMI or $80,801 to $101,000 for a family of four.
53
0%-30% of Area Median Income
TABLE 17 – SEVERE HOUSING PROBLEMS 0 - 30% AMI
DATA SOURCE: 2016-2020 CHAS
*The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks
complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over
50%
Severe Housing Problems*
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 17,664 5,862 2,187
White 14,097 5,158 1,658
Black / African American 2,109 334 188
Asian 774 170 209
American Indian, Alaska
Native 61 22 0
Pacific Islander 0 15 0
Hispanic 438 125 70
54
30%-50% of Area Median Income
TABLE 18 – SEVERE HOUSING PROBLEMS 30 - 50% AMI
DATA SOURCE: 2016-2020 CHAS
*The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks
complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over
50%
Severe Housing Problems*
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 10,715 15,500 0
White 9,235 13,135 0
Black / African American 602 1,079 0
Asian 379 395 0
American Indian, Alaska
Native 8 89 0
Pacific Islander 65 0 0
Hispanic 335 648 0
55
50%-80% of Area Median Income
TABLE 19 – SEVERE HOUSING PROBLEMS 50 - 80% AMI
DATA SOURCE: 2016-2020 CHAS
*The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks
complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over
50%
Severe Housing Problems*
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 8,568 35,792 0
White 7,388 31,332 0
Black / African American 644 2,590 0
Asian 270 868 0
American Indian, Alaska
Native 15 144 0
Pacific Islander 0 0 0
Hispanic 218 545 0
56
80%-100% of Area Median Income
TABLE 20 – SEVERE HOUSING PROBLEMS 80 - 100% AMI
DATA SOURCE: 2016-2020 CHAS
*The four severe housing problems are: 1. Lacks complete kitchen facilities, 2. Lacks
complete plumbing facilities, 3. More than 1.5 persons per room, 4. Cost Burden over
50%
Discussion
Severe housing needs are most likely to impact the lowest income households. For
households with incomes under 30% AMI, about 69% of households have a severe
housing problem. Forty-one percent (41%) of very low-income households (30 to 50%
AMI) have a severe housing problem, as do 19% of low-income households (50 to 80%
AMI). For the moderate income band (80 to 100% AMI), only 11% of households have a
severe housing problem. Disproportionate needs impact several racial/ethnic groups at
different income levels, as described below.
Extremely Low Incomes (< 30% AMI)
Overall, 69% of extremely low-income households have a severe housing problem.
Black and African American households are the only racial/ethnic group to exhibit
Severe Housing Problems*
Has one or
more of four
housing
problems
Has none of
the four
housing
problems
Household has
no/negative
income, but
none of the
other housing
problems
Jurisdiction as a whole 3,101 25,876 0
White 2,632 22,625 0
Black / African American 157 1,720 0
Asian 219 878 0
American Indian, Alaska
Native 0 10 0
Pacific Islander 0 0 0
Hispanic 80 370 0
57
disproportionate need at this income level, with 80% experiencing a severe housing
problem.
Very Low Incomes (30-50% AMI)
Overall, 41% of very low-income households have a severe housing problem. Pacific
Islander households have disproportionate need: 100% of the 65 Pacific Islander
households in this income band have a severe housing problem. Additionally, very low-
income Black and African American households also exhibit high rates of severe
housing problems (49%), just a two percentage point difference away from meeting
HUD’s definition of disproportionate need.
Low Incomes (50-80% AMI)
Overall, 19% of low-income households have a severe housing problem. There are no
groups with disproportionate need. However, 29% of low-income Hispanic households
have a severe housing problem, a 1 percentage point difference away from meeting
HUD’s definition of disproportionate need.
Moderate Incomes (80-100% AMI)
Overall, 11% of moderate-income households have a severe housing problem. There
are no groups with disproportionate need. However, 20% of moderate-income Asian
households have a severe housing problem, a 1 percentage point difference away from
meeting HUD’s definition of disproportionate need.
58
NA-25 DISPROPORTIONATELY GREATER NEED: HOUSING COST
BURDENS – 91.205 (B)(2)
Assess the need of any racial or ethnic group that has disproportionately greater need
in comparison to the needs of that category of need as a whole.
Introduction:
This section assesses the need of any racial or ethnic group that has disproportionately
greater need in comparison to the needs of that category of need as a whole. While the
preceding sections assessed all housing and severe housing problems, Table 21
focuses only on what share of their income households spend on housing. Data is
broken down into groups spending less than 30% of income on housing costs, those
paying between 30 and 50% (i.e., with a cost burden), and those paying over 50% (i.e.,
with a severe cost burden). The final column, “no/negative income,” identifies
households without an income, for whom housing as a share of income was not
calculated.
Housing Cost Burden
TABLE 21 – GREATER NEED: HOUSING COST BURDENS AMI
DATA SOURCE: 2016-2020 CHAS
Housing Cost
Burden <=30% 30-50% >50%
No / negative
income (not
computed)
Jurisdiction as a
whole 228,637 58,702 41,444 2,271
White 198,848 49,652 34,984 1,703
Black / African
American 10,936 4,352 3,572 188
Asian 12,733 2,838 1,551 249
American Indian,
Alaska Native 453 76 65 4
Pacific Islander 10 30 65 0
Hispanic 3,678 1,159 947 70
59
Discussion:
Table 21 shows that approximately 30% of all households in Oakland County are
considered cost burdened or severely cost burdened. American Indian/Alaska Native
households are the least likely to spend more than 30% of income on housing costs
(24% of white households are cost burdened or severely cost burdened), compared to
42% of Black/African American households and 90% of Pacific Islander households.
Both groups have a disproportionate need relative to the jurisdiction as a whole.
Looking at severe cost burdens (i.e., households spending more than 50% of income on
housing), 13% of all households in Oakland County are impacted. Pacific Islander
households are the only racial/ethnic group to exhibit disproportionate rates of severe
cost burden (62%).
60
NA-30 DISPROPORTIONATELY GREATER NEED: DISCUSSION –
91.205(B)(2)
Are there any Income categories in which a racial or ethnic group has
disproportionately greater need than the needs of that income
category as a whole?
There are several income categories in which a racial or ethnic group has a
disproportionately greater need than the needs of the income category as a whole,
summarized below.
Extremely Low Incomes (Under 30% AMI)
• At extremely low incomes, 81% of all households in the county have a housing
problem and 69% have a severe housing problem.
• Pacific Islander households have disproportionate need: 100% of the fifteen (15)
Pacific Islander households in this income band have a housing problem.
• Black and African American households have disproportionate rates of severe
housing needs at this income level, with 80% experiencing a severe housing
problem.
Very Low incomes (30 to 50% AMI)
• At low incomes, 75% of all households have a housing problem and 41% have a
severe housing problem.
• Pacific Islander households have disproportionate need: 100% of the 65 Pacific
Islander households in this income band have a severe housing problem.
Low Incomes (50 to 80% AMI)
• At low incomes, half (50%) of all households have a housing problem and 19%
have a severe housing problem.
• There are no racial or ethnic groups that exhibit disproportionate need in this
income category.
Moderate Incomes (80 to 100%)
At moderate incomes, 37% of all households have a housing problem and 11% have a
severe housing problem. Asian households exhibit disproportionate need, with 48%
having a housing problem.
61
If they have needs not identified above, what are those needs?
Input collected during the community engagement process identified housing
affordability for low- and moderate-income households as the priority housing need in
Oakland County. Community members also discussed a need for senior housing,
housing rehabilitation/repair programs, and homelessness prevention services in the
county.
In addition to housing needs, stakeholders identified the following needs experienced by
low- and moderate-income households in Oakland County: high speed internet and
computers, affordable childcare, access to transportation options, and mental health
services.
Are any of those racial or ethnic groups located in specific areas or
neighborhoods in your community?
The map in MA-50 shows the population distribution for residents in Oakland County by
race and ethnicity. Most of the Black and Asian populations are concentrated in similar
clusters the north, east, and west segments of the county.
62
NA-35 PUBLIC HOUSING – 91.205(B)
Introduction
Public housing within Oakland County is provided through nine different Housing
Authorities under the jurisdictions of its various member communities. This data is
aggregated by HUD and provided to entitlement communities for use in the
Consolidated Planning Process. For Oakland County’s 2026-2030 Consolidated Plan,
HUD aggregated data from the following Housing Authorities:
• Pontiac Housing Commission
• South Lyon Housing Commission
• Royal Oak Township Housing Commission
• Plymouth Housing Commission
• Ferndale Housing Commission
• Southfield Housing Commission
• Royal Oak Housing Commission
• Madison Heights Housing Commission
• Michigan State Housing Development Authority
Note that there may not be a 1:1 overlap between relevant housing authorities and the
Oakland County entitlement area – for example, the City of Pontiac manages its own
grant funding, but data from its housing authority was included by HUD as voucher
holders live within the greater Oakland County area.
The sum total of units and vouchers in use within Oakland County are depicted below
this HUD comprehensive database.
Note: The tables within this section contain data provided by HUD that represents
combined statistics for the Ferndale Housing Commission, Madison Heights Housing
Commission, Michigan State Housing Development Authority, Plymouth Housing
Commission, Pontiac Housing Commission, Royal Oak Housing Commission, Royal
Oak Township Housing Commission, South Lyon Housing Commission, and Southfield
Housing Commission. Oakland County is presenting the data as provided by HUD;
however, the County acknowledges that it may include data on housing and/or residents
outside the County’s entitlement jurisdiction.
63
Totals in Use
TABLE 22 - PUBLIC HOUSING BY PROGRAM TYPE
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units
vouchers in use 0 344 803 26,987 898 25,389 318 52 252
DATA SOURCE: PIC (PIH INFORMATION CENTER)
*Includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
64
Characteristics of Residents
TABLE 23 – CHARACTERISTICS OF PUBLIC HOUSING RESIDENTS BY PROGRAM TYPE
DATA SOURCE: PIC (PIH INFORMATION CENTER)
*Includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose
Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
# Homeless at admission 0 0 3 113 30 30 53 0
# of Elderly Program
Participants (>62) 0 52 210 3,948 168 3,658 29 3
# of Disabled Families 0 209 244 9,191 317 8,571 85 16
# of Families requesting
accessibility features 0 344 803 26,987 898 25,389 318 52
# of HIV/AIDS program
participants 0 0 0 0 0 0 0 0
# of DV victims 0 0 0 0 0 0 0 0
65
Race of Residents
TABLE 24 – RACE OF PUBLIC HOUSING RESIDENTS BY PROGRAM TYPE
DATA SOURCE: PIC (PIH INFORMATION CENTER)
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
Program Type
Race Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
White 0 182 224 12,450 444 11,699 91 9 156
Black/African
American 0 159 574 14,109 420 13,301 226 42 95
Asian 0 0 2 110 4 106 0 0 0
American
Indian/Alaska
Native
0 3 0 282 25 252 1 1 1
Pacific Islander 0 0 3 36 5 31 0 0 0
Other 0 0 0 0 0 0 0 0 0
66
Ethnicity of Residents
TABLE 25 – ETHNICITY OF PUBLIC HOUSING RESIDENTS BY PROGRAM TYPE
DATA SOURCE: PIC (PIH INFORMATION CENTER)
Program Type
Ethnicity Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
Hispanic 0 18 11 727 37 677 6 0 1
Not Hispanic 0 326 792 26,260 861 24,712 312 52 251
67
Section 504 Needs Assessment: Describe the needs of public housing
tenants and applicants on the waiting list for accessible units:
Based on 2019 research conducted by the Joint Center for Housing Studies of Harvard
University, the needs for accessible units most often include entrance requirements
(ground floor entry or wider entryways) and bathroom accommodations. Composite data
on average wait times for units or vouchers of all housing authorities throughout the
Oakland County consortium is unavailable; however, APSH data indicates that within
Oakland County proper, the average wait time is 19 months (1.6 years) for a Housing
Choice Voucher and 88 months (7.3 years) for a Publicly Supported Housing unit.
Most immediate needs of residents of Public Housing and Housing
Choice voucher holders
Consolidated Plan community engagement efforts highlighted that public housing
residents and HCV holders are in immediate need of safe, affordable housing in good
condition. For HCV holders, finding property owners that accept tenants on voucher
assistance is a common challenge.
Residents receiving housing assistance often need additional supportive services that
include mental health services, food, legal services, childcare, and healthcare. General
opportunities to attain a level of financial stability and professional skills as well as
resources in areas such as job training and employment assistance are also needed.
Many of these are provided through supplemental programs throughout the County;
however, community feedback indicated that residents are sometimes unaware of what
resources exist or how to access them. Because of this, increased communication and
collaboration efforts to form a centralized resource hub would be extremely beneficial to
publicly supported housing residents as well as the low- to moderate-income population
as a whole.
How do these needs compare to the housing needs of the population
at large?
The needs of public housing residents and voucher holders are different from those of
the County’s overall low- and moderate-income population primarily in that these
residents are stably housed in housing they can afford. With this need met, residents
can work on other needs that low- to moderate-income families typically face in addition
to housing insecurity.
Discussion
Comparing the characteristics of publicly supported housing residents in an area to the
characteristics of that area’s overall population can highlight disparities within
disadvantaged groups. Table 25 shows that among Oakland County residents of
68
publicly supported housing, 53% are Black, 46% are white, 1% are Native American,
0.4% are Asian, and 0.1% are of other races (Hispanic or Latino residents of publicly
supported housing were not reported). In contrast, the County’s overall population is
69% white, 13% Black, 8% Asian, 0.1% Native American, and 4.8% other or multiple
races 1. This comparison shows that Black and Native American residents are
significantly overrepresented in publicly supported housing in comparison to their overall
population share, indicating that residents of these races are significantly more likely to
need housing assistance than residents of other races. This, in turn, indicates that
Black and Native American residents of Oakland County face more barriers in housing
access and affordability than residents of other races.
Additionally, Table 23 shows that 34% of publicly supported households in Oakland
County have at least one member with a disability. In contrast, only 11.4% of the
County’s overall population has a disability. This indicates that disabled residents are
significantly more likely to need housing assistance than residents without disabilities,
which in turn indicates that residents of Oakland County with disabilities face more
barriers in housing access and affordability than residents without disabilities.
1 2019-2023 American Community Survey, Table DP05
69
NA-40 HOMELESS NEEDS ASSESSMENT – 91.205(C)
Introduction:
This section provides an assessment of Oakland County’s homeless population and its
needs. The Alliance for Housing of Oakland County, formerly the Oakland County
Taskforce on Homelessness and Affordable Housing (OCTHAH), is the Continuum of
Care (CoC) for Oakland County. In the HUD database, the Continuum of Care is known
as MI-504: Pontiac, Royal Oak/Oakland County CoC. This section will discuss official
Point-In-Time Count data reported to HUD through the MI-504 CoC, as well as
additional, more detailed data reported independently through the Alliance for Housing.
As of the date of this publication, the most recently available official data is for the year
2024. Small amounts of unofficial supplemental data may be available in some areas,
as noted below.
If data is not available for the categories "number of persons
becoming and exiting homelessness each year," and "number of days
that persons experience homelessness," describe these categories
for each homeless population type (including chronically homeless
individuals and families, families with children, veterans and their
families, and unaccompanied youth):
The tables below depict homelessness as assessed by the 2024 Point-In-Time count for
the MI-504 CoC, which assesses homelessness as persons experiencing
homelessness on one given night in January. This data is considered official and is
standard to include in the Consolidated Plan; however, service providers interviewed as
part of the community engagement process consistently reported that in Oakland
County the PIT count is unusually inaccurate in capturing the actual nature extent of
homelessness. Because of this, PIT data is included below and followed with additional
data provided by the Alliance for Housing, which serves as the CoC for the area.
According to the PIT count there were 357 people experiencing homelessness in the
Continuum of Care in 2024, representing a decrease of 7.5% from the previous year
and 16% over 5 years. (Unofficial 2026 PIT data from the CoC reflects similar numbers,
with 331 sheltered and 36 unsheltered individuals). Of the homeless persons identified
in Oakland County, 37, or 9.5%, were considered chronically homeless. HUD defines
chronic homelessness in the following way:
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• A homeless individual with a disability as defined in section 401(9) of the
McKinney-Vento Assistance Act (42 U.S.C. 11360(9)), who:
o Lives in a place not meant for human habitation, a safe haven, or in an
emergency shelter, and
o Has been homeless and living as described for at least 12 months* or on at
least 4 separate occasions in the last 3 years, as long as the combined
occasions equal at least 12 months and each break in homelessness
separating the occasions included at least 7 consecutive nights of not living
as described, or
• An individual who has been residing in an institutional care facility for less,
including jail, substance abuse or mental health treatment facility, hospital, or other
similar facility, for fewer than 90 days and met all of the criteria of this definition
before entering that facility**: or
• A family with an adult head of household (or, if there is no adult in the family, a
minor head of household) who meets all of the criteria of this definition, including
a family whose composition has fluctuated while the head of household has been
homeless.
The count also identified 117 accompanied and 7 unaccompanied children under 18
who were homeless; 22 transitional-aged youth (age 18-24), 17 homeless seniors (aged
65 or older), 35 homeless survivors of domestic violence; 15 homeless veterans; one
homeless person with HIV/AIDS; 51 homeless people with a severe mental illness; and
9 people with chronic substance use disorder. (Note that some people may be counted
in multiple categories – for example, a person may fall into both the severe mental
illness and chronic substance abuse categories). Data on the average number of days
people experienced homelessness was not available.
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TABLE 26 – 2024 POINT IN TIME COUNT DATA
Sub-Group
Number of people experiencing
homelessness on a given night
Sheltered Unsheltered Total
Households with adults & children 50 0 50
Households with adults only 141 29 170
Households with children only 7 0 7
Total Homeless Households 198 29 227
Chronically Homeless 24 10 34
Substance Use Disorder 4 5 9
Serious Mental Illness 33 18 51
Domestic Violence Survivor 25 10 35
HIV/AIDS 1 0 1
Accompanied minors 117 0 117
Unaccompanied minors 7 0 7
Veterans 14 1 15
Transitional Aged Youth (18-24) 21 1 22
Seniors (65+) 14 3 17
Total Homeless Persons 327 30 357
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Nature and Extent of Homelessness
TABLE 27 – HOMELESSNESS BY RACE AND ETHNICITY
Race/ethnicity # Sheltered # Unsheltered % Unsheltered Total
Black 238 22 8.5% 260
White 118 18 13.2% 136
Hispanic/Latino 1 11 8.3% 12
Asian/Pacific
Islander 3 0 0.0% 3
Native American 0 0 0 0
Other/multiple 23 3 11.5% 26
The table above depicts homelessness by race and ethnicity within Oakland County.
Black residents make up two-thirds of the homeless population, despite making up only
13% of Oakland County’s overall population, meaning that Black residents are
drastically more likely to become homeless than residents of other races. However,
Black residents who were homeless were less likely to be unsheltered than white
residents and residents of other or multiple races, while white residents were most likely
to be unsheltered. These discrepancies may indicate that Black residents face more
socioeconomic barriers or adversities leading to homelessness than other racial or
ethnic groups, while white residents may face more barriers in accessing resources
than other groups once homeless.
Sheltered and Unsheltered Homelessness
The 2024 PIT count showed that 30 out of 357 people experiencing homelessness in
January 2024, or 8.4%, were unsheltered. However, service providers consistently
noted that this is inaccurate and that there is an urgent need in Oakland County for
additional emergency shelter and warming options, with some providers reporting that
they had personally experienced clients freezing to death due to a lack of shelter beds.
Notably, homeless survivors of domestic violence had an unusually high rate of
unsheltered homelessness, with nearly one-third being unsheltered. This may indicate
a need for additional resources and shelter options for people fleeing domestic violence
in Oakland County.
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Other groups who were disproportionately more likely to be unsheltered include people
with serious mental illnesses, people with chronic substance use disorders, and people
who are chronically homeless.
Veterans and Families with Children
Only 15 homeless veterans were found in the 2024 PIT count, and of these, only one
was unsheltered. The 2024 PIT count also recorded 50 homeless households with
accompanied children, making up 117 children experiencing homelessness, as well as
7 children who were homeless and did not have a parent or guardian present. No
families with children, whether accompanied or unaccompanied, were found to be
unsheltered. However, once again, it is relevant to note that service providers in the
area consistently reported that the PIT count is inaccurate in its assessment of
unsheltered homelessness, and that there is an urgent need for additional emergency
shelter beds.
Discussion
In addition to official data reported to HUD by the MI-504 CoC, the Alliance for Housing
publishes yearly homelessness reports containing more detailed information on some
subsets of the population. While Point-In-Time data provides a snapshot of
homelessness as it exists on one night, the Alliance for Housing reports comprehensive
homelessness data for the entire year using the HMIS database.
The Alliance for Housing found that in 2024 in Oakland County, 1,289 different people in
878 different households experienced “literal” homelessness, which excludes situations
such as doubling up, couch surfing, or moving in with friends and family due to financial
hardship. In contrast to the HUD PIT count, which showed a 7.5% decrease in
homelessness since the previous year, the AFH report constitutes a 7.9% increase in
homelessness in 2024 vs 2023.
Notably, this increase was comprised entirely of children who were homeless – in 2023,
851 adults and 344 children were homeless, while in 2024, 845 adults and 443 children
were homeless. This represents a concerning increase of nearly 30% of children
experiencing homelessness. The chart below, provided by the Alliance for
Homelessness, depicts the number of homeless persons in varying age groups in 2024
vs 2023, showing that the largest age group of homeless children is children aged 5 to
10, followed by children from newborn to age 4. The largest increases in homelessness
among all age groups, child or adult, between 2023 and 2024 were seen among
children aged 5-14.
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Source: Alliance for Housing Annual Report 2025, accessed via https://5ca7cb57-9e51-4bb0-9fe5-
db52afb1eae4.filesusr.com/ugd/eb1e0d_0da59e1eaa8e4f42b3f2d614e1bb8f51.pdf
The AFH also assesses disability among homeless residents in Oakland County and
published the following chart for varying disability rates in 2024 vs 2023:
75
Source: Alliance for Housing Annual Report 2025, accessed via https://5ca7cb57-9e51-4bb0-9fe5-
db52afb1eae4.filesusr.com/ugd/eb1e0d_0da59e1eaa8e4f42b3f2d614e1bb8f51.pdf
This data shows that in 2024, nearly 32% of Oakland County residents who
experienced homelessness had one or more disabilities – nearly three times the overall
Oakland County disability rate of 11.4%. The most common disabilities experienced by
homeless residents were mental health disorders, developmental disabilities, and
physical disabilities. This disproportionate presence of disability among Oakland
County’s homeless population indicates a substantial need for increased resources,
services, and affordable, accessible housing for the County’s disabled populations in
order to prevent homelessness.
In 2024, 330 people, or 25.6% of those who experienced homelessness, reported to the
AFH that they had experienced domestic violence. This is a substantially higher rate
than found in the 2024 PIT count, which reported only 7% of the homeless population
having experienced domestic violence. In combination with PIT count data which
shows an unusually high rate of unsheltered homelessness among domestic violence
survivors, the AFH data on very high rates of domestic violence survivors among the
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homeless population indicates an extremely pressing need for increased services for
survivors of domestic violence within Oakland County.
The AFH also collects and reports data on chronic homelessness, and found that in
2024, 230 of the 1,289 people who experienced homelessness in Oakland County were
chronically homeless. Of these, nearly half had entered and exited homelessness four
or more times in 2024, and 71% had been homeless for more than 12 months. In
contrast, among the entire homeless population in 2024, only 15% had been homeless
four or more times and only 4% had been homeless for longer than 12 months. This
shows that chronically homeless residents of Oakland County are returning to
homelessness at high rates after initially accessing housing, which indicates a
significant need for expanded wraparound and supportive services to support these
individuals once they are housed. This conclusion was echoed by homeless service
providers consulted for the Consolidated Planning process, who reported that they see
clients return to homelessness at high rates due to a lack of long-term supportive
wraparound services. Service providers also noted that a key factor in chronically
homeless clients returning to homelessness was a felt lack of community – such clients
were often separated from the communities they had formed while experiencing
homelessness and housed in developments where other residents had never
experienced homelessness, leading the clients to feel unwelcome and unsupported.
The charts below show that in 2024 36 residents who had been housed in permanent
housing returned to homelessness, and 110 residents who had been housed in
emergency housing returned to homelessness. In total, 889 clients exited
homelessness in Oakland County in 2024, for a rate of 16% of people returning to
homelessness. Clients who were housed in permanent housing most often returned to
homelessness between three and twelve months after being housed, while clients who
exited emergency housing most often returned to homelessness less than one month
after exiting. Clients who were able to remain housed for one year showed the lowest
rates of returning to homelessness, underlining the importance of long-term or
permanent wraparound supportive services.
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78
NA-45 NON-HOMELESS SPECIAL NEEDS ASSESSMENT - 91.205
(B,D)
Introduction:
This section discusses the characteristics and needs of people in various
subpopulations in Oakland County who may require supportive services, including
people with HIV/AIDS, seniors, people with disabilities (mental, physical, or
developmental), people with alcohol or drug addiction, and survivors of domestic
violence. The chart below depicts the approximate percentage of Oakland County
residents in each subpopulation.
Describe the characteristics of special needs populations in your
community:
ALICE (asset-limited, income-constrained, yet employed)
In order to better understand the needs of low- to moderate-income residents, Oakland
County designates a population known as Asset-Limited, Income-Constrained, yet
Employed, or ALICE, to designate a population who may be above the poverty line and
yet still unable to meet their basic needs. The current ALICE threshold for Oakland
County is an annual household income of $47,800 per year or less, and the Oakland-
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Livingston Human Service Agency (OLSHA) reports that approximately 125,247
households, or 24% of all households, fall into this category 2.
Elderly and frail elderly
According to 2019-2023 American Community Survey estimates, about 19.1% of
Oakland County’s population is elderly (age 65 and over) and about 7.9% of the
population is considered frail elderly (age 75 and over). About 19.7% of Oakland County
residents aged 65-74 and over and 45.0% of residents aged 75 and over have one or
more disabilities.
People with disabilities
An estimated 11.4% of Oakland County residents had at least one disability as of 2023.
People with disabilities may require specialized housing with accessibility modifications
such as wheelchair ramps, visual rather than auditory fire alarms, and more.
People with HIV/AIDS and their families
According to AIDSVu, an interactive mapping tool from Emory University’s Rollins
School of Public Health, an estimated 210 out of every 100,000 people in Michigan
were living with HIV as of 2023 3, and 8 out of every 100,000 people were diagnosed
with HIV in 2023. When considering Oakland County’s population, this equates to about
2,160 people living with HIV and 102 people newly diagnosed with HIV per year.
Persons with alcohol or drug addiction
The region of Michigan including Oakland County had an estimated 4.2% rate of alcohol
use disorder in the past year for individuals ages 12 and older, according to 2016-2018
data from the U.S. Substance Abuse & Mental Health Data Archive (SAMHDA)4. About
1.9% of the region’s population was estimated to have used cocaine and 0.2% to have
used heroin in the past year, per the 2016-2018 data. Accounting for 2023 population
estimates, this equates to approximately 57,250 people with alcohol use disorder,
24,175 people using cocaine, and 2,545 people using heroin within Oakland County.
Survivors of domestic violence
The Michigan State Police Department maintains data on domestic violence reporting
and shows that in 2024, 17,830 women, 7,703 men, and 11 people of unreported
genders experienced domestic violence, for a total of 25,544 people (roughly 70%
2 https://www.olhsa.org/Portals/0/files/OLHSA_CNA_Final%20(2).pdf
3 https://map.aidsvu.org/profiles/county/orange-county-ca-california/overview
4 https://datatools.samhsa.gov/saes/substate
80
women and 30% men)5. This means that in 2024, roughly 2% of Oakland County’s
population (2.8% of women and 1.2% of men) experienced a domestic violence event
that they reported to the police. However, this data only includes incidents that were
reported to the police – Emory University reports that as few as 20% of domestic
violence incidents are reported, and that only 1 in 5 people who are injured by domestic
violence seek medical attention.
The National Intimate Partner and Sexual Violence Survey 2016-2017 report, conducted
and published by the CDC, states that 39.5% of women and 44.3% of men in Michigan
will experience physical violence by an intimate partner in their lifetimes6. When applied
to the population of Oakland County, this means that more than 255,000 women and
280,000 men have or will experience intimate partner violence.
What are the housing and supportive service needs of these
populations and how are these needs determined?
The primary housing and supportive service needs of these subpopulations (the elderly,
persons with disabilities, persons with HIV/AIDS and their families, persons with alcohol
or drug addiction, survivors of domestic violence, and reentry populations) were
determined by input from housing and service providers and the public through public
meetings and stakeholder interviews, as well as through a review of research on
housing and service needs of specific populations.
Housing that is affordable, accessible, safe, and low-barrier
Residents with special needs often live at or below the federal poverty level. High
housing costs make it difficult for these populations to afford housing. Low incomes
force many residents to live in congregate care, have roommates, or live with family.
The OLHSA 2024-2027 Needs Assessment reports a widespread need for affordable
rental housing, especially for seniors, disabled residents, and low-income families.
There is a need to increase the availability of affordable housing for populations with
special needs. This could include options such as smaller housing units; multifamily
‘missing middle’ housing, including duplexes, triplexes, quadraplexes, and other small
housing types that support increased levels of affordability.
Housing may be inaccessible to populations with special needs for a variety of reasons.
Persons with disabilities may find that their housing options are not ADA compliant or
are outside the service range for public transportation. As discussed in previous
sections, Oakland County residents with disabilities are disproportionately more likely to
be homeless or residents of publicly supported housing than residents without
5 https://www.michigan.gov/msp/divisions/cjic/dashboard-portal/crime-dashboard
6 https://www.cdc.gov/nisvs/documentation/NISVS-2016-2017-State-Report-508.pdf
81
disabilities, indicating that significant barriers to affordable, accessible housing exist for
this group.
People living with HIV/AIDS, immigrants and refugees, people with criminal histories,
and other populations with special needs are often discriminated against in housing
application processes. People living with HIV/AIDS have a particular need for low-
barrier housing that is free from requirements surrounding drug testing, sobriety,
criminal background, and medical appointments. For these reasons, there is a need to
ensure that accessible, low-barrier housing is available and to take actions to reduce
discrimination, such as providing fair housing services.
The elderly, people with disabilities, and others who may not have access to vehicles
often need housing that is disability-accessible and near to transportation, recreation,
and employment. In general, special needs populations require housing options that are
intentionally integrated into the community to provide access to needed services and to
reduce social isolation. Like other populations with special needs, people living with
HIV/AIDS also need housing that provides easy access to health services, resources,
and employment.
Finally, housing that is safe and clean is of special concern for people with special
needs. Units that are not clean or have other unhealthy conditions can worsen health
issues for people who are already vulnerable. The OLHSA 2024-2027 Needs
Assessment Report notes needs related to requirements for landlords to better maintain
properties and needs for repairs on aging units, particularly among low-income
homeowners.
Transportation
Access to transportation is an important concern for people with special needs. Seniors
and people with disabilities and others who may not have access to vehicles need
housing close to transportation services to access employment, health services, and
recreation opportunities – the OLHSA 2024-2027 Needs Assessment found that a lack
of transportation access prevented many residents from being able to work or access
appointments or supportive services, as well as preventing them from being able to
carry out basic daily tasks. Youth, seniors, and residents in rural areas were noted as
groups of special concern.
Specialized housing and services
Specialized housing addresses the needs of specific populations. People with physical,
intellectual, or developmental disabilities; people living with HIV/AIDS; and people with
alcohol or drug addiction have specific housing needs that may be addressed through
housing with wraparound services, such as case management, life skills programming,
and health services. The Housing First model, which is recommended by HUD,
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emphasizes that supportive services should not be required for people to access
housing.
The OLHSA 2024-2027 Needs Assessment found a specific need for easily accessible
mental health services as well as for increased coordination between public service
providers, noting that a current lack or organization surrounding service coordination
and outreach makes it difficult for residents to navigate the various available resources.
Workforce development and employment services
Special needs populations may also need workforce development and employment
services. These programs may include employment navigation, job training, education,
transportation services, and case management focused on employment, among others.
The OLA 2024-2027 Needs Assessment noted a specific need for financial literacy and
credit improvement education in order to help residents achieve upward mobility.
Physical and mental healthcare access
Access to healthcare is a need for special needs populations, as they are more likely to
experience barriers such as economic disadvantage; medical issues and disability;
language and literacy age; and cultural, geographic, or social isolation. To increase
access to healthcare, it is important for local governments and stakeholders to take
steps to define, locate, and reach at-risk populations. This need overlaps significantly
with the need for transportation, as the OLSHA report noted that a lack of transportation
frequently causes elderly, youth, and rural residents to miss or be unable to schedule
appointments.
Technology access
The OLSHA 2024-2027 Needs Assessment noted that a lack internet access and digital
literacy were frequently cited as barriers that prevented residents from accessing
existing services. Service providers who were consulted during the Consolidated
Planning Process also reported this barrier, noting that residents experiencing
homelessness especially faced significant barriers in accessing and remaining in
supportive services due to a lack of consistent internet or electronic device access.
Education and combating stigmas
Combating stigmas is an important concern for people with special needs. For adults
with criminal histories and people living with HIV/AIDS, discrimination may make
accessing adequate housing difficult. Additionally, a lack of understanding regarding the
transmission of HIV may cause people to lose housing or employment, thus increasing
the risk of homelessness.
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Outreach
Outreach to special needs populations to ensure they are aware of available services is
another need. Clarity in marketing and in public buildings about what services are
available is important in supporting awareness of available services among vulnerable
populations. Outreach also includes the development of relationships and trust so that
people feel comfortable seeking out needed services. The OLSHA report noted a
specific need for increased outreach collaboration among service providers in order to
bring services to more residents.
Discuss the size and characteristics of the population with HIV/AIDS
and their families within the Eligible Metropolitan Statistical Area:
Data for HIV/AIDS cases specific to Oakland County is unavailable. Because of this, it
may be useful to examine State level data. According to AIDSVu, an interactive
mapping tool from Emory University’s Rollins School of Public Health, an estimated 210
out of every 100,000 people in Michigan were living with HIV as of 2023 7, and 8 out of
every 100,000 people were diagnosed with HIV in 2023. When considering Oakland
County’s population, this equates to about 2,160 people living with HIV and 102 people
newly diagnosed with HIV per year.
If the PJ will establish a preference for a HOME TBRA activity for
persons with a specific category of disabilities (e.g., persons with
HIV/AIDS or chronic mental illness), describe their unmet need for
housing and services needed to narrow the gap in benefits and
services received by such persons. (See 24 CFR 92.209(c)(2) (ii))
N/A
7 https://map.aidsvu.org/profiles/county/orange-county-ca-california/overview
84
NA-50 NON-HOUSING COMMUNITY DEVELOPMENT NEEDS – 91.215
(F)
Describe the jurisdiction’s need for Public Facilities:
Buildings open to the general public or for use by target special needs populations,
whether owned by the government or by nonprofit organizations, may be considered
public facilities under the CDBG program. Community survey participants were asked to
rank the need for public facilities within Oakland County on a scale from no need to
critical need, and the following public facilities were identified as the top three with the
highest level of need: (1) parks and recreational facilities; (2) childcare or disabled
adult care centers; and (3) senior or community centers.
Input from community meetings, focus groups, and interview participants supported
survey findings. One common theme described by stakeholders consulted was that
parks and recreation facilities with Oakland County are unequally distributed and kept,
and that some are unsafe to use.
How were these needs determined?
These public facility needs were determined based on input from stakeholders gathered
through research, interviews, focus groups, public meetings, and a community survey.
Needs were also determined through a review of other local plans and studies. For a list
of stakeholders and organizations that participated in this Consolidated Plan process,
see Table 2.
Describe the jurisdiction’s need for Public Improvements:
Community survey participants were asked to rank the need for public infrastructure
improvements within Oakland County on a scale from no need to critical need, and the
following improvements were identified as the top three with the highest level of need:
(1) street improvements; (2) flood or drain improvements; and (3) sidewalk
improvements.
Input from community meetings, focus groups, and interview participants supported
survey findings. One common theme described by stakeholders consulted was that
infrastructure investments seem unequally distributed in some areas of the County.
How were these needs determined?
These public improvement needs were determined based on input from stakeholders
gathered through research, interviews, focus groups, public meetings, and a community
survey. Needs were also determined through a review of other local plans and studies.
85
For a list of stakeholders and organizations that participated in this Consolidated Plan
process, see Table 2.
Describe the jurisdiction’s need for Public Services:
Community survey participants were asked to rank public services by importance, and
the following services were identified as the top three with the highest level of
importance: (1) homeless services; (2) home repair or improvement assistance;
and (3) homebuyer assistance.
Input from community meetings, focus groups, and interview participants supported
survey findings. Common needs identified by stakeholders included:
• There is a substantial need both for more emergency home repair resources for
low-income residents and for better advertising of existing resources.
• There is substantial need for increased wraparound and other supportive services
for people experiencing homelessness in Oakland County.
• Low-income homebuyers and homebuyers who do not speak English fluently
frequently face high barriers in the homebuying process, and there is a significant
need for more homebuyer assistance programs.
How were these needs determined?
These public service needs were determined based on input from stakeholders
gathered through research, interviews, focus groups, public meetings, and a community
survey. Needs were also determined through a review of other local plans and studies.
For a list of stakeholders and organizations that participated in this Consolidated Plan
process, see Table 2.
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2026-2030
Housing Market Analysis
87
MA-05 OVERVIEW
Housing Market Analysis Overview:
While housing choices can be fundamentally limited by household income and
purchasing power, the lack of affordable housing can be a significant hardship for low-
and moderate-income households, preventing them from meeting other basic needs.
Stakeholders and residents reported that affordable housing for families and individuals
is a severe issue in Oakland County, with housing prices increasing significantly over
the last several years.
In addition to reviewing the current housing market conditions, this section analyzes the
availability of assisted and public housing and facilities to serve homeless individuals
and families. It also analyzes local economic conditions and summarizes existing
economic development resources and programs that may be used to address
community and economic development needs identified in the Needs Assessment.
Key Findings
• A large percentage of housing units in the county were built prior to 1980,
indicating an aging housing stock that may be in need of repair and rehabilitation
• Renter-occupied housing units are more likely than owner-occupied units to
exhibit two or more housing problems, indicating greater need among renters
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MA-10 NUMBER OF HOUSING UNITS – 91.210(A)&(B)(2)
Introduction
An estimated 379,151 housing units are located in Oakland County, according to the
2016-2020 five-year American Community Survey (see Table 28). The largest share of
units are single-family detached structures (72%), followed by units in small multifamily
buildings of 5 to 19 units (9%). About 15% of the county’s units are in large multifamily
buildings (20 or more units); duplexes, triplexes, and fourplexes; and single-unit
attached units. Mobile homes, RVs, and vans make up 4% of residences in the county.
An estimated 76% of the county’s units are owner-occupied, and 24% are renter-
occupied (see Table 29). Almost all owner-occupied housing in the county has at least
two bedrooms: 14% of units have two bedrooms, and 85% have three or more
bedrooms. Rental units tend to be smaller: 3% of units are studios, and 26% are one-
bedroom units. The most common rental unit contains two bedrooms (44%), while
slightly more than one-quarter (27%) of renters live in units with three or more
bedrooms.
All residential properties by number of units
TABLE 28 – RESIDENTIAL PROPERTIES BY UNIT NUMBER
Property Type Number %
1-unit detached structure 272,165 72%
1-unit, attached structure 24,738 7%
2-4 units 14,424 4%
5-19 units 34,417 9%
20 or more units 19,109 5%
Mobile Home, boat, RV, van, etc 14,298 4%
Total 379,151 100%
DATA SOURCE: 2016-2020 ACS
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Unit Size by Tenure
TABLE 29 – UNIT SIZE BY TENURE
DATA SOURCE: 2016-2020 ACS
Describe the number and targeting (income level/type of family
served) of units assisted with federal, state, and local programs.
The Ferndale Housing Commission serves low-income individuals and families through
its Housing Choice Voucher program, which distributes an estimated 984 vouchers in
the county. Additional HCVs are also distributed through the Michigan State Housing
Development Authority (MSHDA).
The HUD LIHTC database also indicates that there are approximately 4,417 LIHTC
units in the county’s entitlement jurisdiction, 3,950 of which are set aside for low-income
households.
Public Housing
The Ferndale Housing Commission owns and manages two properties that provide
public housing for low- and moderate-income households: Autumn House and
Withington West.
Autumn House is a 55-unit multifamily development located at 500 East Nine Mile Road
that is primarily comprised of one-bedroom units. There are five (5) two-bedroom units.
The development was constructed in 1974.
Withington West is a 68-unit multifamily development located at 415 Withington St
constructed in 1982. All of its units are one-bedroom units. This development houses
the Ferndale Housing Commission’s main business office.
Owners Renters
Number % Number %
No bedroom 311 0% 2,665 3%
1 bedroom 2,401 1% 22,530 26%
2 bedrooms 37,420 14% 37,068 44%
3 or more bedrooms 233,464 85% 22,960 27%
Total 273,596 100% 85,223 100%
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Low Income Housing Tax Credit Properties
Additional assisted housing in Oakland County includes several Low Income Housing
Tax Credit (LIHTC) properties. According to HUD’s LIHTC database, there are a total of
29 properties providing 4,417 housing units within the county, typically targeting
households with incomes of 50 to 60% AMI or below, adjusted by family size. LIHTC
developments include a mix of family and senior projects, and may include additional
funding sources, such as Project-Based Section 8 subsidies.
Housing Choice Vouchers
According to HUD’s A Picture of Subsidized Households (APSH) data, there are about
4,072 voucher holders in use in Oakland County. Housing Choice Vouchers are
targeted to households with incomes at or below 50% AMI, adjusted by family size, with
an emphasis on serving households within incomes under 30% AMI. They are
distributed statewide by MSHDA, along with several local public housing agencies that
serve cities or townships.
Oakland County Home Improvement Program
The County has a Housing Improvement Program that is available to anyone with
income limits at or below 80 percent of the AMI. The Water Resources Commissioner
office also offers a Hardship Assistance Program for residents who may need
assistance paying water or sewer bills or needed plumbing repairs.
Provide an assessment of units expected to be lost from the
affordable housing inventory for any reason, such as expiration of
Section 8 contracts.
Several trends exist that, absent policies focused on preserving the county’s existing
affordable housing stock and developing diverse new housing options, indicate that
Oakland County will continue to experience a loss of affordable housing inventory.
Trends include high levels of demand for housing due to population growth in the
county; increasing home values and median rents over the past 10 years; a shortage in
the supply of rental and homeowner housing units affordable to households with
incomes below 50% HAMFI; and aging housing stock in need of rehabilitation. MSHDA
and local public housing authorities will continue to administer Housing Choice
Vouchers in Oakland County.
Federal law requires any LIHTC properties awarded credits after 1989 to maintain
affordability for 30 years, although after the first 15 years, owners can leave the
program through a relief process. After 30 years (or 15 years if owners are granted
regulatory relief), properties can be converted to market-rate units. During the 2026-
2030 Five-Year Consolidated Plan, four (4) LIHTC properties in Oakland County are
expected to age out of the 30-year affordability period: Pebble Creek Place, Meadows
91
of Auburn Hills, Pine Lake Apartments, and American House Troy. Together, these
properties offer 528 units of low-income housing. As LIHTC units age past their required
30-year affordability period, the County and its partners may want to consider potential
approaches to retain these properties as income-restricted housing.
Additionally, fourteen (14) properties with Section 8 project-based vouchers will face the
end of their 20-year contract during the 2026 to 2030 period but are eligible for renewal
by HUD. These developments include: Independent Supportive Housing Oakland I-III,
Pontiac Plains Apartments, Detroit Baptist Manor, Springhill II and III, Pontiac Village
Estates, Village of Holly Woodlands II, Meadow Creek Village, McDonald Senior
Apartments, Devon Square, and Highland Meadowview I. Together, these properties
offer a total of 661 units of affordable housing.
Does the availability of housing units meet the needs of the
population?
Cost burden data shows that housing affordability needs are particularly severe for
renters with incomes under 80% of HUD Area Median Family Income (HAMFI), and in
particular for those with incomes under 30% HAMFI. An estimated 27,878 renter
households with incomes below 80% HAMFI are housing cost burdened, spending
more than 30% of income on housing (see Table 9). Renters with incomes of 50%
HAMFI and below make up 74% of these cost-burdened renter households.
On the ownership side, income and home value data indicate that starter home prices in
the county are out of reach for many moderate- and middle- income households. Based
on American Community Survey 5-Year Estimates for 2019-2023, the median home
value of owner-occupied units in Oakland County is $320,400, up 27% from the 2016-
2020 median of $252,800, and up 49% from the 2005-2009 median of $214,600.
Affordability data in the Needs Assessment also shows affordability challenges, with
cost burdens impacting households with incomes up to 100% HAMFI. Stakeholders
interviewed during this planning process also described an increasingly tight housing
market due to high demand for housing and insufficient new housing under
development, noting the need to increase the supply of housing for both rental and
homeownership units to support housing affordability in the county. In addition to the
need to increase housing supply, stakeholders noted the need to assist property owners
in making needed repairs to housing units to support housing affordability and quality.
Describe the need for specific types of housing:
Data discussed in the Housing Need Assessment and in this section indicate a
particular need for rental and for-sale housing that is affordable to low- and moderate-
income households. Housing types that allow for increased affordability of both rental
and homeownership units might include options such as smaller housing units;
multifamily ‘missing middle housing, including duplexes, triplexes, quadruplexes, and
92
other small multifamily units; accessory dwelling units; cohousing with shared services;
or tiny homes. Rehabbing units that are aging, dilapidated, or that have poor energy
efficiency can also increase the number of high-quality affordable units.
MA-15 HOUSING MARKET ANALYSIS: COST OF HOUSING -
91.210(A)
Introduction
This section reviews housing costs and affordability in Oakland County. The median
home value in the county was estimated at $252,800 as of the 2016-2020 American
Community Survey 5-year estimates (see Table 30), representing a 41% increase over
the 2009 median value of $178,900. More recent 2019-2023 ACS 5-Year estimates
show that the median value of owner-occupied units in the county stands at $320,400, a
27% increase from 2016-2020 estimates. This data indicates steep increases in home
prices in recent years and barriers to homeownership for lower-income residents. As
home values and interest rates have increased, renting is generally more accessible to
low-to-moderate income families in Oakland County than homeownership.
The median contract rent in the county was $951 at the time of the 2016-2020 ACS
estimates, a 20% increase since 2009. As of the 2019-2023 ACS, the median contract
rent was $1,157, indicating a 22% increase since the 2016-2020 ACS. This data
indicates that rents have increased dramatically within the past few years as well,
creating additional housing barriers for lower-income residents.
The need for the preservation of existing affordable housing and the development of
new affordable units was one of the most commonly identified housing issues in the
county, with data and local perceptions both indicating affordability issues, particularly
for households with incomes below 80% of the area median income. Data from Table 6
and Table 9 indicates that more than half of all Oakland County households earning
80% or below the area median income experience cost burdens (60,062 out of 103,243
total households, or 58%). Ability to afford housing is tied to other needs identified in the
county, including homelessness, housing and services for people with disabilities,
senior housing, and availability of housing for people re-entering the community from
long-term care facilities or other institutions.
93
Cost of Housing
TABLE 30 – COST OF HOUSING
Base Year: 2009 Most Recent Year:
2020 % Change
Median Home Value 178,900 252,800 41%
Median Contract Rent 795 951 20%
DATA SOURCE: 2000 CENSUS (BASE YEAR), 2016-2020 ACS (MOST RECENT YEAR)
TABLE 31 - RENT PAID
DATA SOURCE: 2016-2020 ACS
Rent Paid Number %
Less than $500 8,657 10.2%
$500-999 36,439 42.8%
$1,000-1,499 25,871 30.4%
$1,500-1,999 7,903 9.3%
$2,000 or more 6,304 7.4%
Total 85,174 100.0%
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Housing Affordability
TABLE 32 – HOUSING AFFORDABILITY
Number of Units affordable
to Households earning Renter Owner
30% HAMFI 3,931 No Data
50% HAMFI 12,981 11,756
80% HAMFI 37,485 41,082
100% HAMFI No Data 64,396
Total 54,397 117,234
DATA SOURCE: 2016-2020 CHAS
Monthly Rent
TABLE 33 – MONTHLY RENT
DATA SOURCE: 2020 HUD FMR AND HOME RENTS
Is there sufficient housing for households at all income levels?
Table 32 estimates the number of units in the county that are affordable to renters and
owners at a variety of income levels, which can be compared to the number of
households at each income level, as provided in Table 8 of the Needs Assessment.
According to CHAS estimates, there are 14,228 renters with incomes under 30%
HAMFI, but only 3,931 rental units affordable at that income level are reported in Table
32. Thus, there is insufficient rental housing for households with extremely low incomes.
At other income levels, there appears to be a sufficient number of renter units affordable
to renter households at that income level. However, these figures do not take into
account unit condition or size; nor do they reflect the possibility that a unit that would be
Monthly Rent ($) Efficiency (no
bedroom)
1
Bedroom
2
Bedroom
3
Bedroom
4
Bedroom
Fair Market Rent $639 $764 $977 $1,266 $1,376
High HOME Rent $639 $764 $977 $1,266 $1,376
Low HOME Rent $639 $736 $883 $1,020 $1,138
95
affordable to a low- or moderate-income household may be unavailable to them
because it is occupied by a higher income household. Community engagement
indicated a need for additional affordable rental housing units at a variety of price points,
especially those affordable to extremely low-income households, low- and moderate-
income households. Input from young professionals with incomes above 80% AMI
indicating a lack of affordable housing, even at income levels beyond those addressed
through HUD grant funds.
Turning to owners, there are an estimated 17,186 owner households with incomes at or
below 50% HAMFI in the county, but Table 32 reports only 11,756 owner-occupied
housing units affordable at that income level. This leaves a deficit of 5,430 affordable
owner-occupied units. At the next income levels there appear to be adequate affordable
units. As with rental housing, these figures do not take into account housing size or
condition, or the possibility that higher or lower income households are occupying units
within this cost range.
The National Low Income Housing Coalition’s Out of Reach data examines rental
housing rates relative to income levels for counties and metro areas throughout the U.S.
To afford a two-bedroom rental unit at the Oakland County Fair Market Rent (FMR) of
$1,378 without being cost burdened would require an annual wage of $55,120. This
amount translates to a 40-hour work week at an hourly wage of $26.50 or 2.1 full-time
minimum wage jobs. At the county’s average renter wage of $22.78, one would need to
work about 47 hours a week to afford a two-bedroom apartment at Fair Market Rent.
How is affordability of housing likely to change considering changes
to home values and/or rents?
Data from the American Community Survey and stakeholder input both indicate that
housing values and rents have increased sharply in recent years. Affordability has, in
turn, decreased for both renters and owners. High demand for housing, development of
new housing that has not kept up with high demand, and a lack of rental and for-sale
housing affordable to residents with incomes less than 30% to 50% AMI all indicate that
housing affordability is likely to continue as a pressing issue in Oakland County.
How do HOME rents / Fair Market Rent compare to Area Median Rent?
How might this impact your strategy to produce or preserve
affordable housing?
Table 33 shows HUD’s Fair Market Rents and HOME rents for Oakland County. The
county’s median contract rent of $951 falls below the FMR and high HOME rents for
two-, three-, and four-bedroom units.
As of the 2016-2020 ACS data, about 53% of rental units in Oakland County have rents
under $1,000, which falls under the FMR and HOME rents for units with two bedrooms
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or less. As noted in the previous section, about 70% of rental units have 2 bedrooms or
more. Combined, these figures suggest that housing choice voucher holders would be
able to access a variety of units, given the share of housing renting for less than FMRs.
Note that this data does not reflect housing conditions, which are an important
consideration. While the rent may be affordable, substandard housing conditions may
make a unit unsafe or lead to exceptionally high utility costs, negating any savings in
rent as compared to a more expensive unit. Additionally, housing choice voucher
holders may have difficulty finding units that will accept vouchers or difficulty qualifying
for leases due to past evictions or credit history.
Discussion
FIGURE 2. MEDIAN HOME VALUE AND MEDIAN HOUSEHOLD INCOME IN OAKLAND COUNTY, 2010 TO 2020
$204,300
$178,900
$252,800
$66,390 $67,465 $81,587
$0
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
2010 2015 2020
Median Home Value Median Household Income
97
MA-20 HOUSING MARKET ANALYSIS: CONDITION OF HOUSING –
91.210(A)
Introduction
This section examines the condition of housing in Oakland County, including the
presence of selected housing conditions: 1) lack of complete plumbing facilities, (2) lack
of complete kitchen facilities, (3) more than one person per room, and (4) cost burden
greater than 30%. This section also examines the age of housing stock, vacancy rate
and suitability of vacant housing for rehabilitation, and the risk of lead-based paint
hazards.
Renters in Oakland County are more likely than owners to experience one or more of
the selected housing conditions. About 38% of renter-occupied units and 18% of owner-
occupied units have at least one of the conditions described above (see Table 34).
CHAS data discussed in the Needs Assessment indicates that cost burdens are by far
the most common housing condition. About 18% of owner-occupied units in the county
have one selected condition (48,550 units), and about 0.1% have two or more selected
conditions (433 units). In contrast, 38% of renter-occupied units have one selected
condition (32,020 units), and 1.5% have two or more selected conditions (1294 units).
These figures indicate that rental units are more likely to be physically substandard (i.e.,
lack a complete kitchen or plumbing).
Age of housing reflects periods of development in Oakland County. The area contains a
significant supply of housing built prior to 1980, of which 151,206 units are owner-
occupied (55% of owner-occupied units) and 47,920 are rental units (56% of rental
units) (see Table 35). Owner-occupied units are more likely than rental units to have
been built in 2000 or later (16% and 13%, respectively), while renters are more likely
than owners to occupy housing built from 1950 to 1979. While some older units may be
well-maintained, the considerable share of housing built prior to 1980 indicates potential
need for rehabilitation assistance.
Describe the jurisdiction's definition of "standard condition" and
"substandard condition but suitable for rehabilitation":
For the purpose of this Consolidated Plan, Oakland County defines units to be in
“standard condition” if they meet HUD Section 8 housing quality standards. A unit is
defined as “substandard” if it lacks complete plumbing, a complete kitchen, or heating
fuel (or uses heating fuel that is wood, kerosene, or coal). A unit is “substandard but
suitable for rehabilitation” if it lacks complete plumbing, a complete kitchen or a reliable
98
and safe heating system but has some limited infrastructure that can be improved upon.
These units are likely to have deferred maintenance and may have some structural
damage such as leaking roofs, deteriorated interior surfaces, and inadequate insulation.
They may not be part of public water or sewer systems but will have sufficient systems
to allow for clean water and adequate waste disposal.
There are an estimated 12,898 housing units in Oakland County (2.4% of all units) that
are vacant for reasons other than being for rent; rented but not occupied; for sale; sold
but not occupied; for seasonal, recreational, or occasional use; or for migrant workers,
according to 2016-2020 ACS data. The county does not have counts of units that are
substandard, substandard but suitable for rehabilitation, abandoned, or real estate
owned (REO properties), as this would require evaluating units on a house-by-house
basis. In general, however, units with more than one substandard condition and older
units are more difficult to rehabilitate. A rough assessment of conditions can be made
by considering housing age and absence of basic amenities.
Condition of Units
TABLE 34 - CONDITION OF UNITS
DATA SOURCE: 2016-2020 ACS
Condition of Units
Owner-Occupied Renter-Occupied
Number % Number %
With one selected Condition 48,550 18% 32,020 38%
With two selected Conditions 384 0% 1,189 1%
With three selected
Conditions 45 0% 105 0%
With four selected Conditions 4 0% 0 0%
No selected Conditions 224,660 82% 51,909 61%
Total 273,643 100% 85,223 100%
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Year Unit Built
TABLE 35 – YEAR UNIT BUILT
DATA SOURCE: 2016-2020 CHAS
Risk of Lead-Based Paint Hazard
TABLE 36 – RISK OF LEAD-BASED PAINT
DATA SOURCE: 2016-2020 ACS (TOTAL UNITS) 2016-2020 CHAS (UNITS WITH CHILDREN
PRESENT)
Year Unit Built
Owner-Occupied Renter-Occupied
Number % Number %
2000 or later 42,582 16% 11,125 13%
1980-1999 79,856 29% 26,190 31%
1950-1979 116,507 43% 39,904 47%
Before 1950 34,699 13% 8,016 9%
Total 273,644 101% 85,235 100%
Risk of Lead-Based Paint Hazard
Owner-
Occupied
Renter-
Occupied
Number % Number %
Total Number of Units Built Before 1980 151,206 55% 47,920 56%
Housing Units build before 1980 with children
present 22,624 8% 17,862 21%
100
Vacant Units
TABLE 37 - VACANT UNITS
TABLE 38 - VACANT UNITS (ALTERNATE)
DATA SOURCE: 2016-2020 ACS
Need for Owner and Rental Rehabilitation
An assessment of the region’s housing conditions can provide a basis for developing
policies and programs to maintain and preserve the quality of the housing stock. The
age of housing can have a substantial impact on housing conditions and costs. As
Suitable for
Rehabilitation
Not Suitable for
Rehabilitation Total
Vacant Units
Abandoned Vacant Units
REO Properties
Abandoned REO Properties
Number Percent of Total
Housing Units
For rent 8,664 1.6%
Rented, not occupied 1,315 0.2%
For sale only 3,328 0.6%
Sold, not occupied 1,969 0.4%
For seasonal, recreational, or
occasional use
4,331 0.8%
For migrant workers 0 0.0%
Other vacant 12,898 2.4%
Total Vacant Units 32,505 6.0%
101
housing ages, maintenance costs rise, which can present significant affordability issues
for low- and moderate-income homeowners. Aging rental stock can lead to rental rate
increases to address physical issues or deteriorating conditions if building owners defer
or ignore maintenance needs. Deteriorating housing can also depress neighboring
property values, discourage reinvestment, and eventually impact the quality of life in a
neighborhood. Homes built prior to 1950 have a high likelihood of containing lead-based
paint. However, the use of lead-based paint did not end until 1978 and may affect an
even larger number of households.
Development of new market-rate and subsidized housing units can support housing
affordability and reduce displacement of lower-income residents. In contrast, areas with
growing populations in which few new housing units are built tend to experience
housing shortages and reduced affordability. Subsidized units, such as those built with
low-income housing tax credits and other federal and state subsidies, have been found
to be particularly protective in reducing displacement.
Data on age of housing in Oakland County points to a large share of older housing
stock and a decline in construction of new units since 2000 (Table 35). An estimated
55% of units in the county are in structures built prior to 1980. The older housing stock
in the county may pose both economic and public health challenges, particularly for
individuals and families living in older housing units.
Data regarding housing conditions indicates that 433 owner-occupied units (less than
1% of total owner-occupied units) in the county have at least two housing conditions,
which are likely to include cost burdens and one other condition (overcrowding, lack of
complete kitchen, or lack of complete plumbing). Additionally, 34,699 owner-occupied
housing units (13% of total owner-occupied units) in the county were built before 1950,
indicating the highest risk for deferred maintenance and rehabilitation need. A total of
116,507 units of owner-occupied housing (43% of total owner-occupied units) in the
county were built between 1950 and 1980, and as this housing ages, maintenance
needs will continue to grow.
Owners are less likely to lack complete kitchens or plumbing and therefore are less
likely to live in substandard housing. However, housing age indicates that some owner-
occupied units are at risk of deferred maintenance and may currently or in the near
future be in need of some rehabilitation, given that 151,206 units (55% of total owner-
occupied units) were built prior to 1980. Additionally, seniors living on Social Security or
retirement income who have paid off their mortgages may now be unable to afford
necessary repairs and maintenance as their homes age.
A total of 8,016 rental housing units in the county (9% of total rental units) were built
before 1950, and 39,904 units were built between 1950 and 1980 (47% of total rental
units). Further, a greater number of rental units (1,294) than owner units (433) have at
least two housing conditions, likely including cost burdens and at least one other
102
housing condition. Combined, these factors indicate that while there is a high level of
need for rehabilitation of both renter- and owner-occupied housing, renters in Oakland
County experience the highest levels of need.
Estimated Number of Housing Units Occupied by Low- or Moderate-
Income Families with LBP Hazards
Exposure to lead-based paint represents one of the most significant environmental
threats from a housing perspective. Housing conditions can significantly affect public
health, and exposure to lead may cause a range of health problems for adults and
children. The major source of lead exposure comes from lead-contaminated dust found
in deteriorating buildings, including residential properties built before 1978 that contain
lead-based paint.
Unfortunately, measuring the exact number of housing units with lead-based paint
hazards is difficult. However, risk factors for exposure to lead include housing old
enough to have been initially painted with lead-based paint (i.e., pre-1978), households
that include young children, and households in poverty. Table 36 identifies the total
number of housing units in Oakland County built before 1980 and the total number of
renter and owner units built before 1980 that house children under age 6. This includes
22,624 owner-occupied units (8% of all owner-occupied housing units) and 17,862
renter-occupied units (21% of total renter-occupied housing units) with at least two risk
factors for exposure to lead-based paint (built before 1980 and housing young children).
103
MA-25 PUBLIC AND ASSISTED HOUSING – 91.210(B)
Introduction
Public housing within the Oakland County consortium is provided through nine different Housing Commissions under the
jurisdictions of its various member communities. The sum total of units and vouchers available within Oakland County are
depicted below via HUD’s comprehensive database.
Note: The tables within this section contain data provided by HUD that represents combined statistics for the Ferndale
Housing Commission, Madison Heights Housing Commission, Michigan State Housing Development Authority, Plymouth
Housing Commission, Pontiac Housing Commission, Royal Oak Housing Commission, Royal Oak Township Housing
Commission, South Lyon Housing Commission, and Southfield Housing Commission. Oakland County is presenting the
data as provided by HUD; however, the County acknowledges that it may include data on housing and/or residents
outside the County’s entitlement jurisdiction.
104
Totals Number of Units
TABLE 39 – TOTAL NUMBER OF UNITS BY PROGRAM TYPE
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project
-based
Tenant
-based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units vouchers
available 0 333 861 28,371 847 24,532 2,313 1,190 2,397
# of accessible units
DATA SOURCE: PIC (PIH INFORMATION CENTER)
*Includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition
105
Describe the supply of public housing developments:
Oakland County does not administer a Public Housing Authority; however, several
communities within the County operate participating PHAs. As shown above there are a
total of 861 public housing units available throughout the jurisdiction, in addition to
approximately 28,371 voucher-based units and 333 mod-rehab units.
Describe the number and physical condition of public housing units
in the jurisdiction, including those that are participating in an
approved Public Housing Agency Plan:
HUD's Real Estate Assessment Center (REAC) conducts physical property inspections
of properties that are owned, insured, or subsidized by HUD, including public housing
and multifamily assisted housing. About 20,000 such inspections are conducted each
year to ensure that assisted families have housing that is decent, safe, sanitary, and in
good repair. Inspections are scored using a scale of 1 to 100. A passing score for a
REAC Physical Inspection is 60 or above.
There are three letters (A-C) that may follow the score, as well as an asterisk (*). Their
meaning is as follows:
· A: No health and safety deficiencies noted
· B: Non-life-threatening health and safety deficiencies noted
· C: At least one life-threatening health and safety deficiency noted
* At least one inoperable smoke detector noted
Although data provided by HUD depicts a total of 861 public housing units available
within Oakland County, HUD REAC scores indicate only two public housing
developments inspected within Oakland County. The names and inspection scores of
these units are depicted below:
Public Housing Condition
TABLE 40 - PUBLIC HOUSING CONDITION
Public Housing
Development Inspection Score Inspection date
Autumn House 72 10/5/2022
Unnamed Development
(10149 Pasadena Ave) 59 9/13/2023
106
No letter scores were provided in the REAC report. Scores indicate that Autumn
House, run by the Ferndale Housing Commission, received a passing score while and
unnamed development, run by the Royal Oak Township Housing Commission, received
a failing score.
Describe the restoration and revitalization needs of public housing
units in the jurisdiction:
An unnamed development located at 10149 Pasadena Avenue in Ferndale received a
failing inspection score in 2023; however, no reason or additional information was given
on deficiencies present in the development.
Describe the public housing agency's strategy for improving the
living environment of low- and moderate-income families residing in
public housing:
Oakland County’s participating housing authorities will continue to seek funding from a
variety of sources in order to improve the living environment of public housing residents,
increase assisted housing choices, and expand housing opportunities.
107
MA-30 HOMELESS FACILITIES AND SERVICES – 91.210(C)
Introduction
A range of facilities provide housing and services to support people experiencing
homelessness in Oakland County, including emergency, transitional, and permanent
supportive housing. This section provides an overview of shelter facilities, housing, and
mainstream and other services that aim to meet the needs of people experiencing
homelessness in Oakland County based on HUD Housing Inventory Count data for the
Pontiac, Royal Oak/Oakland County CoC, supplemental data available from the Alliance
for Housing, service provider input, stakeholder feedback, and other data when
available.
Note: The Alliance for Housing functions as the Continuum of Care for Oakland County;
however, for the purpose of annual Point-in-Time (PIT) and Housing Inventory Count
(HIC) reports, the Oakland County Continuum of Care is known as MI-504: the Pontiac,
Royal Oak/Oakland County CoC. Annual Housing Inventory Count data presented in
the table below comes from this group.
108
Facilities and Housing Targeted to Homeless Households
TABLE 41 - FACILITIES AND HOUSING TARGETED TO HOMELESS HOUSEHOLDS
Source: HUD 2024 Continuum of Care Homeless Assistance Programs Housing Inventory Count Report, MI-504
Emergency Shelter Beds
Transitional
Housing
Beds
Permanent Supportive
Housing Beds
Year-Round
Beds (Current &
New)
Voucher /
Seasonal /
Overflow Beds
Current &
New
Current &
New
Under
Development
Households with Adult(s) and
Child(ren) 155 N/A 61 704 N/A
Households with Only Adults 87 42 12 440 N/A
Chronically Homeless
Households N/A N/A N/A 212 N/A
Veterans N/A N/A N/A 111 N/A
Unaccompanied Youth 7 N/A 19 0 N/A
TOTAL 249 42 78 1,144 N/A
109
Describe mainstream services, such as health, mental health, and
employment services to the extent those services are use to
complement services targeted to homeless persons
Oakland County has a variety of mainstream services that are used to complement
targeted services for people experiencing homelessness. The Continuum of Care
focuses on supporting coordination and collaboration among these systems so that
people experiencing homelessness can access mainstream resources to assist them in
transitioning to and remaining stable in permanent housing. In 2023, McLaren Physician
Partners compiled a comprehensive list of mainstream services available in the County
in the following categories:
• Abuse & Protective Services
• Adult Aging Services
• Disability & Special Needs Resources
• Emergency & Disaster Services
• Financial Assistance
• Food Pantries, Clothing & Household
• Healthcare Services
• Housing Assistance
• Legal Assistance
• Libraries
• Parenting & Pregnancy Resources
• Prescription Assistance
• Support Groups
• Transportation
• Tribal Services
• Veterans Affairs
The comprehensive resource guide with information for each category may be viewed
here:
https://www.mclaren.org/Uploads/Public/Documents/MPHO/documents/community-
linkage/2023/2023%20Oakland%20County%20Community%20Resource.pdf
110
List and describe services and facilities that meet the needs of
homeless persons, particularly chronically homeless individuals and
families, families with children, veterans and their families, and
unaccompanied youth. If the services and facilities are listed on
screen SP-40 Institutional Delivery Structure or screen MA-35 Special
Needs Facilities and Services, describe how these facilities and
services specifically address the needs of these populations.
The Alliance for Housing provides the following information about emergency shelter
facilities within Oakland County:
111
In addition, Oakland County newly maintains both a website and a mobile phone app
known as Shelter Oakland, through which anyone seeking services may search for
emergency, transitional, or permanent housing openings. The website depicts the
locations of facilities on a map and provides a current list of bed openings and may be
viewed at the following link: https://shelteroakland.com/
The Oakland County Emergency Management Department maintains a visual map and
list of warming and cooling centers. Residents can click on a center’s icon on the map to
find out more information on each facility. This website may be viewed at the following
link:https://www.oakgov.com/community/emergency-management/need-to-
know/safety/warming-and-cooling-centers
In addition to these facilities and services, the following were mentioned by stakeholders
and service providers who were interviewed during the community engagement
process:
• The Baldwin Center: offers laundry facilities, shower and hygiene products, a
family soup kitchen, food donations, winter hats and gloves, and a program
called Wellness Wednesdays which features a weekly rotation of services such
as housing resources, career and employment support, community navigation,
legal aid, Secretary of State services, and medical care.
• Julie’s List: a comprehensive searchable online database maintained by St.
Joseph’s Helpers which lists education, employment, financial, food, goods,
health, housing, legal, transportation, and other supportive resources nationwide,
including Oakland County.
• Welcome Inn Day Center: a low-barrier day center offering resources such as
food, clothing, and hygiene items, as well as limited night shelter in the winter
months.
• PantryNet: a searchable online database of food pantries and soup kitchens
nationwide, including Oakland County.
112
MA-35 SPECIAL NEEDS FACILITIES AND SERVICES – 91.210(D)
Introduction
This section discusses the characteristics and needs of people in various subpopulation
in Oakland County who may require supportive services, including people with
HIV/AIDS, seniors, people with disabilities (mental, physical, or developmental), people
with alcohol or drug addiction, and survivors of domestic violence. For a more complete
description of these populations, see NA-45.
Including the elderly, frail elderly, persons with disabilities (mental,
physical, developmental), persons with alcohol or other drug
addictions, persons with HIV/AIDS and their families, public housing
residents and any other categories the jurisdiction may specify, and
describe their supportive housing needs
Housing
The OLHSA 2024-2027 Needs Assessment found a specific need for easily accessible
mental health services as well as for increased coordination between public service
providers, noting that a current lack or organization surrounding service coordination
and outreach makes it difficult for residents to navigate the various available resources.
Workforce development and employment services
Special needs populations may also need workforce development and employment
services. These programs may include employment navigation, job training, education,
transportation services, and case management focused on employment, among others.
The OLA 2024-2027 Needs Assessment noted a specific need for financial literacy and
credit improvement education in order to help residents achieve upward mobility.
Physical and mental healthcare access
Access to healthcare is a need for special needs populations, as they are more likely to
experience barriers such as economic disadvantage; medical issues and disability;
language and literacy age; and cultural, geographic, or social isolation. To increase
access to healthcare, it is important for local governments and stakeholders to take
steps to define, locate, and reach at-risk populations. This need overlaps significantly
with the need for transportation, as the OLSHA report noted that a lack of transportation
frequently causes elderly, youth, and rural residents to miss or be unable to schedule
appointments.
Technology access
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The OLSHA 2024-2027 Needs Assessment noted that a lack internet access and digital
literacy were frequently cited as barriers that prevented residents from accessing
existing services. Service providers who were consulted during the Consolidated
Planning Process also reported this barrier, noting that residents experiencing
homelessness especially faced significant barriers in accessing and remaining in
supportive services due to a lack of consistent internet or electronic device access.
Education and combating stigmas
Combating stigmas is an important concern for people with special needs. For adults
with criminal histories and people living with HIV/AIDS, discrimination may make
accessing adequate housing difficult. Additionally, a lack of understanding regarding the
transmission of HIV may cause people to lose housing or employment, thus increasing
the risk of homelessness.
Outreach
Outreach to special needs populations to ensure they are aware of available services is
another need. Clarity in marketing and in public buildings about what services are
available is important in supporting awareness of available services among vulnerable
populations. Outreach also includes the development of relationships and trust so that
people feel comfortable seeking out needed services. The OLSHA report noted a
specific need for increased outreach collaboration among service providers in order to
bring services to more residents.
Describe programs for ensuring that persons returning from mental
and physical health institutions receive appropriate supportive
housing
Hope Recuperative Shelter, located in Pontiac, provides a “discharge to home” option
for patients being discharged from a hospital into homelessness. This center is staffed
by nurses who provide patient monitoring and education and provides patients with
case management services in order to ensure that they have housing, legal resources,
and vital documents such as an ID or birth certificate.
Service providers consulted during the Consolidated Planning process noted that Hope
Recuperative Shelter has intake criteria including independence in daily living activities,
but that the majority of hospital referrals received are for patients who do not meet these
criteria. Providers noted that only 11 out of the last 60 referrals received by Hope
Recuperative Shelter were for appropriate patients and that the shelter has experienced
instances of nursing homes attempting to dump patients. Providers also noted that
stigma against nursing homes constitutes a significant barrier to care – many individuals
require more intensive care than Hope Shelter can provide and should be discharged
into a nursing home, but are unwilling to go.
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Specify the activities that the jurisdiction plans to undertake during
the next year to address the housing and supportive services needs
identified in accordance with 91.215(e) with respect to persons who
are not homeless but have other special needs. Link to one-year
goals. 91.315(e)
During the upcoming 2026 program year, Oakland County will continue expanding its
housing and supportive service to meet the needs of residents who are not homeless,
but who have other special needs. Beginning with the competition of Shepherd House,
a 53-unit permanent supportive housing development in Ferndale funded in part with
HOME resources. This project provides long term, service-enriched housing for
individuals with disabilities and other special needs who require ongoing support to
maintain stability.
In addition, the County has an additional 166 units of affordable housing currently under
construction, with anticipated completion in PY2026 or early the following program year.
These developments include:
• Two communities in Pontiac, serving low income households, seniors, and
persons with disabilities
• One community in Southfield, designed to expand accessible and service
linked housing options
Link One Year Goal: These efforts support our one-year goal 1 to increase the supply
of affordable and supportive housing by advancing construction on 166 units and fully
leasing Shepherd House to eligible special needs households.
Through a Cross-County effort in conjunction with NHD, Oakland Connects, a free
program that helps guide residents through services in the county. A team of certified
Community Health Workers are committed to connecting Oakland County residents to
programs that support health in all ways including Non-Housing Community
Development that expand economic opportunity, improve safety, enhance food access,
employment opportunities and provide other assistance.
Oakland Connects is available to anyone who lives or works in Oakland County will
provide
• Navigation assistance for residents with disabilities, chronic illnesses, or age-
related needs
• Referrals to rental assistance, utility support, transportation, and health services
• Case management to help residents maintain stable housing and avoid entering
the homelessness system
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One Year Goal Link: NHD in partnership with Oakland Connects supports Non-
Housing Community Development efforts by providing coordinated service navigation to
at least 1000 special needs households.
In December of 2024 NHD and the Oakland County Health & Human Services (HHS)
launched Wellness Wednesdays to further our shared mission of connecting community
and health care organizations to coordinate resources for people experiencing
homelessness or in need of assistance. Wellness Wednesdays occurs every
Wednesday from 10:30 a.m. to 12:30 p.m. in partnership with the Baldwin Center
located at 212 Baldwin Ave in Pontiac alongside several community organizations.
Oakland County residents in need of health, housing, employment and community
resources are invited to enjoy a meal while connecting with services.
Since the program’s inception on April 2025, Oakland County has provided
2,759 individuals with comprehensive wrap around services through Wellness
Wednesdays. These services include 596 guests accessing shower facilities with 538
loads of laundry completed, helping individuals maintain dignity and personal wellbeing.
Through on-site partnerships, 141 guests received medical support from Honor Health,
while 173 residents were connected to resources through Oakland Connects. Housing
stability efforts remain central to the program, with 228 individuals receiving housing
counseling and 69 guests assisted by Community Housing Network. Additionally, 40
residents received targeted support from Lighthouse. Collectively, these services
demonstrate the County’s commitment to providing coordinated, person-centered
assistance that addresses the diverse needs of residents and strengthens pathways to
long term stability. These programs help stabilize residents who may be at risk of
homelessness.
In January of 2026 the County expanded these efforts with the addition of Friendship
Fridays, an extension of Wellenses Wednesdays increasing support service access to
Southern Oakland County residents in Royal Oak, Michigan. To date we have provided
90 clients with wrap around services through Friendship Fridays.
One Year Goal Link: NHD in partnership with Oakland Connects & the HHS supports
Goal 2 by improving Homeless Services and Preventions efforts. These activities also
support Goal 4 by delivering basic needs, public & supportive services to at least 1,000
residents.
Oakland County will work closely with community partners to prevent housing instability
among residents with special needs, including older adults, persons with disabilities,
individuals with chronic health conditions, and survivors of domestic violence. The
County’s efforts will focus on early identification, targeted intervention, and coordinated
service delivery.
Action to address this include:
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• Identifying residents at risk of losing housing due to disability, aging, health
needs, or economic hardship
• Connecting individuals to housing/rental counseling, legal aid, and emergency
financial assistance to stabilize their housing situation
• Ensuring residents are aligned with assistance programs
• Strengthening partnerships with disability service agencies, senior service
organizations, behavioral health providers, domestic violence service providers,
and faith based and nonprofit organizations
• Improving cross agency communication and referrals to ensure residents receive
comprehensive, wrap around support tailored to their needs
One-Year Goal Link: Prevent housing loss and increase prevention efforts through
Goal 2.
For entitlement/consortia grantees: Specify the activities that the
jurisdiction plans to undertake during the next year to address the
housing and supportive services needs identified in accordance with
91.215(e) with respect to persons who are not homeless but have
other special needs. Link to one-year goals. (91.220(2))
During the next program year, the 52 participating communities within the Oakland
County HOME Consortium will undertake a broad array of projects and services to
support residents who are not homeless but who have other special needs. These
include seniors, persons with disabilities, survivors of domestic violence, youth, and
low‑income households requiring assistance to maintain safe, stable housing and
access essential services.
Activities include, but are not limited to; Minor / Mobile Home Repair Programs, Parks &
Recreation upgrades, Removal of Architectural Barriers (ADA ramps, bathroom
modifications, accessibility retrofits), Code Enforcement to maintain safe, healthy living
environments, Senior Centers, Domestic Violence and Crisis Intervention Services, Fire
Station Equipment and Public Services such as Senior Services, Transportation
Services, Yard Services to support safety and accessibility around the home, Youth
Assistance Programs, Emergency Services & Meals on Wheels.
MA-40 BARRIERS TO AFFORDABLE HOUSING – 91.210(E)
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Negative Effects of Public Policies on Affordable Housing and
Residential Investment
Oakland County’s 2020 Analysis of Impediments to Fair Housing Choice (AI) identifies
several challenges related to housing affordability and access as county’s barriers to fair
housing choice. The AI also includes a review of the county’s existing zoning code and
identifies policies that may limit the development of affordable housing in the region.
Housing problems and limited access to homeownership disproportionately
impact protected classes
Analysis of 2008-2017 homeownership data from the Housing Mortgage Disclosure Act
(HMDA) showed that the mortgage denial rate in Oakland County is disproportionately
among Black and African American households, who had an average denial rate of
29%. This denial rate was significantly higher than the county’s overall average of 15%.
Comparatively, White households had the county’s lowest average denial rate at 13%.
Additionally, Comprehensive Housing Affordability Strategy (CHAS) data analysis on
housing needs performed in this Consolidated Plan revealed that Black households
exhibited disproportionately high rates of housing problems compared to the county as
a whole.
Disparate patterns in lending, moderate to high levels of segregation, insufficient
affordable housing in a range of unit sizes, racial minority households with
disproportionate rates of housing problems, insufficient accessible affordable housing,
and discrimination on the basis of disability were all identified as high priority
contributing factors that impacted fair housing choice in the county’s latest AI.
Zoning, Affordability, and Housing Choice
Although zoning ordinances and land use codes play an important role in regulating the
health and safety of the built environment, overly restrictive codes can negatively impact
housing affordability and fair housing choice within a jurisdiction. A Land Use Planner
Survey of jurisdictions’ zoning codes and land use regulations was conducted to identify
any barriers that might impede access to housing. This survey found that most
jurisdictions define the word “family” as related by blood, marriage, or adoption or
"related" in any other traditional sense, which may limit access to housing choice. In
addition, few jurisdictions actively encourage affordable housing development or
inclusionary policies.
Barriers to housing access in the private market
In addition to these public-sector barriers, the private market can also create barriers.
Some landlords may refuse to rent units to households receiving other forms of housing
assistance. This practice, known as source of income discrimination, reduces the
affordability of existing units in the private housing stock and creates barriers to
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obtaining affordable housing. While source of income discrimination is illegal in the state
of Michigan, many residents still struggle to find landlords willing to accept Section 8 or
Housing Choice Vouchers for reasons ranging from stigma and discrimination to
landlord concern about the potential for added cost. Housing Choice Vouchers make up
a significant portion of publicly supported housing within Oakland County and are a key
element in providing affordable housing to the county’s most vulnerable populations.
Because of this, landlord reluctance presents a significant barrier to affordable housing.
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MA-45 NON-HOUSING COMMUNITY DEVELOPMENT ASSETS – 91.215 (F)
Introduction
This section outlines employment, labor force, and educational attainment data that informs the Consolidated Plan’s
priorities and goals.
Economic Development Market Analysis
Business Activity
TABLE 42 - BUSINESS ACTIVITY
Business by Sector
Number
of
Workers
Number
of Jobs
Share of
Workers
%
Share of
Jobs
%
Jobs less
workers
%
Agriculture, Mining, Oil & Gas Extraction 782 954 0 0 0
Arts, Entertainment, Accommodations 40,470 53,645 10 11 1
Construction 15,025 19,713 4 4 0
Education and Health Care Services 71,647 73,171 17 15 -2
Finance, Insurance, and Real Estate 29,270 31,814 7 7 -1
Information 8,651 7,935 2 2 0
Manufacturing 49,839 56,536 12 12 0
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DATA SOURCE: 2016-2020 ACS (WORKERS), 2020 LONGITUDINAL EMPLOYER-HOUSEHOLD DYNAMICS (JOBS)
TABLE 43 - BUSINESS ACTIVITY (ALTERNATE DATA)
Business by Sector
Number
of
Workers
Number
of Jobs
Share of
Workers
%
Share of
Jobs
%
Jobs less
workers
%
Other Services 13,476 15,851 3 3 0
Professional, Scientific, Management Services 73,419 86,925 18 18 0
Public Administration 0 0 0 0 0
Retail Trade 45,273 62,536 11 13 2
Transportation and Warehousing 9,614 8,019 2 2 -1
Wholesale Trade 22,734 33,021 6 7 1
Total 380,200 450,120 -- -- --
Business by Sector
Number
of
Workers
Number
of Jobs
Share of
Workers
%
Share of
Jobs
%
Jobs less
workers
%
Agriculture, Mining, Oil & Gas Extraction 1,742 911 0 0 0
Arts, Entertainment, Accommodations 51,257 38,027 8 7 -1
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DATA SOURCE: 2016-2020 ACS (WORKERS), 2020 LONGITUDINAL EMPLOYER-HOUSEHOLD DYNAMICS (JOBS)
Business by Sector
Number
of
Workers
Number
of Jobs
Share of
Workers
%
Share of
Jobs
%
Jobs less
workers
%
Construction 29,043 18,742 4 4 0
Education and Health Care Services 137,277 125,541 21 25 4
Finance, Insurance, and Real Estate 50,355 41,919 8 8 0
Information 11,183 11,327 2 2 0
Manufacturing 128,219 60,064 20 12 -8
Other Services 27,179 14,484 4 3 -1
Professional, Scientific, Management Services 94,915 93,999 15 18 3
Public Administration 17,471 11,983 3 2 -1
Retail Trade 62,926 53,224 10 10 0
Transportation and Warehousing 19,643 13,513 3 3 0
Wholesale Trade 15,497 27,023 2 5 3
Total 646,707 450,120 -- -- --
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Labor Force
TABLE 44 - LABOR FORCE
DATA SOURCE: 2016-2020 ACS
TABLE 45 – OCCUPATIONS BY SECTOR
DATA SOURCE: 2016-2020 ACS
Total Population in the Civilian Labor Force 489,218
Civilian Employed Population 16 years and
over 468,480
Unemployment Rate 4.23
Unemployment Rate for Ages 16-24 13.95
Unemployment Rate for Ages 25-65 2.62
Occupations by Sector Number of People
Management, business and financial 177,984
Farming, fisheries and forestry occupations 12,186
Service 35,894
Sales and office 96,519
Construction, extraction, maintenance and
repair 22,209
Production, transportation and material
moving 17,048
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Travel Time
TABLE 46 - TRAVEL TIME
DATA SOURCE: 2016-2020 ACS
Education:
Educational Attainment by Employment Status (Population 16 and
Older)
TABLE 47 - EDUCATIONAL ATTAINMENT BY EMPLOYMENT STATUS
DATA SOURCE: 2016-2020 ACS
Travel Time Number Percentage
< 30 Minutes 240,084 57%
30-59 Minutes 149,208 35%
60 or More Minutes 31,218 7%
Total 420,510 100%
Educational Attainment
In Labor Force
Civilian
Employed Unemployed
Not in
Labor
Force
Less than high school graduate 9,628 777 7,287
High school graduate (includes
equivalency) 49,950 2,778 19,959
Some college or Associate's degree 102,440 4,026 25,924
Bachelor's degree or higher 223,300 5,226 37,820
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Educational Attainment by Age
TABLE 48 - EDUCATIONAL ATTAINMENT BY AGE
DATA SOURCE: 2016-2020 ACS
Educational Attainment – Median Earnings in the Past 12 Months
TABLE 49 – MEDIAN EARNINGS IN THE PAST 12 MONTHS
DATA SOURCE: 2016-2020 ACS
Age
18–24
yrs
25–34
yrs
35–44
yrs
45–65
yrs 65+ yrs
Less than 9th grade 482 974 1,172 3,045 5,409
9th to 12th grade, no diploma 6,522 2,328 3,343 6,868 6,657
High school graduate, GED, or
alternative 20,664 14,371 13,564 44,770 37,541
Some college, no degree 27,119 22,145 19,049 49,379 31,010
Associate's degree 2,993 8,654 9,274 23,946 11,352
Bachelor's degree 11,940 39,318 37,400 77,009 30,132
Graduate or professional degree 873 22,717 32,157 57,949 29,242
Educational Attainment Median Earnings in the Past 12
Months
Less than high school graduate 1,021,880
High school graduate (includes
equivalency) 1,776,862
Some college or Associate's degree 2,171,375
Bachelor's degree 3,591,465
Graduate or professional degree 4,498,802
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Based on the Business Activity table above, what are the major
employment sectors within your jurisdiction?
The employment sectors in Oakland County with the largest numbers of jobs are
professional, scientific, and management services (86,925 jobs or 18% of all jobs);
education and health care services (73,171 jobs or 15%); and retail trade (62,536 jobs
or 13%). The largest shares of Oakland County residents are employed in professional,
scientific, and management services (73,419 workers or 18% of all workers); education
and health care services (71,647 workers or 17%); and manufacturing (49,839 workers
or 12%). The jobs in which the most county residents are employed reflect the major
employment sectors with the exception of manufacturing, where numbers suggest a
notable number of Oakland County residents travel outside the county for their work in
this sector.
Describe the workforce and infrastructure needs of the business
community:
Oakland County is a part of the seven counties that make up the Southeast Michigan
Council of Governments (SEMCOG), which is currently in the process of its five year
update to its current 2021 Comprehensive Economic Development Strategy (CEDS),
Increasing Shared Prosperity for a Resilient Economy: Comprehensive Economic
Development Strategy for Southeast Michigan. According to this plan’s SWOT analysis
of the region’s strengths, weaknesses, opportunities, and threats (SWOT), the business
community’s most pressing needs include a need for infrastructure updates to the
region’s roads, bridges, and streets, transit network, and broadband internet.
Additionally, there is a growing deficiency between the skills of the workforce and those
needed by employers, further exacerbated by mass retirements of an aging baby
boomer population and a lack of career pathways for in-demand occupations due to the
growing costs and barriers associated with higher education.
Describe any major changes that may have an economic impact, such
as planned local or regional public or private sector investments or
initiatives that have affected or may affect job and business growth
opportunities during the planning period. Describe any needs for
workforce development, business support or infrastructure these
changes may create.
Several factors shape economic development in Oakland County and the region. The
SEMCOG’s CEDS details six (6) economic development strategies and policies that will
help the region meet its current and future needs:
• Creating and marketing quality places
126
• Anticipating demands for land use
• Investing in critical infrastructure
• Fostering a competitive business climate
• Advancing technology, innovation, and entrepreneurship
• Preparing and connecting talent with jobs
Investments in workforce development, education, and entrepreneurship are already
occurring in Oakland County through organizations such as Oakland County Michigan
Works!, which provides workforce development services for job seekers, employers,
and youth across the county. With six (6) offices throughout the county in Novi, Oak
Park, Pontiac, Southfield, Troy, and Waterford, Oakland County residents can get
connected with business apprenticeships, paid internships, professional development
workshops, certification classes, and more.
Additionally, Oakland County has several economic development programs meant to
support non-profit organizations, businesses, corporations, and investors. These include
the Apprenticeships Funding Program, Property Assessed Clean Energy (PACE)
Financing, SBA 504 Loan Program, CEED Lending, and the Oakland County Economic
Development Corporation (EDC).
How do the skills and education of the current workforce correspond
to employment opportunities in the jurisdiction?
About 24% of the county’s population aged 18 and over have a high school education or
less, while 48% have a bachelor’s degree or higher, according to American Community
Survey data for 2016-2020 (Table 48).
The SEMCOG’s latest 2021 CEDS noted a growing deficiency between the skills of the
workforce and those needed by employers, further exacerbated by mass retirements of
an aging baby boomer population and a lack of career pathways for in-demand
occupations due to the growing costs and barriers associated with higher education. As
more desirable, high paying jobs require levels of education above a high school
diploma, there is a need to continue to focus on connecting residents with opportunities
to pursue higher education.
Describe any current workforce training initiatives, including those
supported by Workforce Investment Boards, community colleges and
other organizations. Describe how these efforts will support the
jurisdiction's Consolidated Plan.
127
Workforce development programs in Oakland County focus on training workers in high-
demand, well-paying industries and connecting job seekers with regional employers in
these sectors.
Organizations such as Oakland County Michigan Works! provides a variety of
employment and workforce training opportunities through partnerships with local
businesses and schools. Oakland Community College’s Department of Economic and
Workforce Development also offers a wide range of programs and training opportunities
for students, residents, and businesses, including employee training courses,
apprenticeships, certifications, and online personal development courses.
Does your jurisdiction participate in a Comprehensive Economic
Development Strategy (CEDS)? If so, what economic development
initiatives are you undertaking that may be coordinated with the
Consolidated Plan? If not, describe other local/regional plans or
initiatives that impact economic growth.
Yes, Oakland County participated in the development of Increasing Shared Prosperity
for a Resilient Economy: Comprehensive Economic Development Strategy for
Southeast Michigan (2021) prepared by Southeast Michigan Council of Governments
(SEMCOG). The strategy serves as the Comprehensive Economic Development
Strategy (CEDS) in accordance with the U.S. Economic Development Administration’s
requirements, and as a guide for policies, programs, and investments to support
economic development in the region.
Activities that the County anticipates undertaking over the next five years will support
several of the strategies listed in the CEDS, including investment in workforce and
economic development, public facilities, and infrastructure improvements. In particular,
one of the goals of the CEDS is to support the region’s human capital development by
accessing resources for a well-prepared, skilled professional and technical workforce.
The County will continue to invest in human capital and workforce development through
programs such as Oakland County Michigan Works!, which supports residents in
gaining training and certifications in industries that provide living-wage jobs. Oakland
County will also continue to work with local and regional stakeholders, such as
SEMCOG and the Oakland County Economic Development Department to continue
planning for and investing in critical workforce and economic development programs.
128
MA-50 NEEDS AND MARKET ANALYSIS DISCUSSION
Are there areas where households with multiple housing problems
are concentrated? (include a definition of "concentration")
HUD defines four types of housing problems: (1) cost burden of more than 30%, (2)
more than 1 person per room, (3) lack of complete kitchen facilities, and (4) lack of
complete plumbing facilities. The map below of housing needs in Oakland County
shows the share of households within each census tract that have least one of these
housing problems.
A concentration of households with housing needs is defined as a census tract where
more than 40% of households have at least one housing need. Using this definition,
there are thirty three (33) census tracts within the county that have a concentration of
housing problems. Ten (10) of these tracts have rates of housing problems that are 50%
or more. They are located in Oak Park, Southfield, and Pontiac, indicated by yellow in
Figure 3 below. Census tracts where more than 40% of households have a housing
need are generally located in areas of the county that are populated predominantly by
Black/African American residents.
129
FIGURE 3. PERCENT OF HOUSEHOLDS WITH HOUSING PROBLEMS
130
Are there any areas in the jurisdiction where racial or ethnic
minorities or low-income families are concentrated? (include a
definition of "concentration")
According to the latest ACS data, White and Black/African American residents comprise
the two largest racial and ethnic population groups in Oakland County, making up 69%
and 13% of the county’s population, respectively. There is some clustering of Black
residents in the city of Pontiac and southern Oakland County, including the cities of
Southfield and Oak Park (see Figure 4). There is also some clustering of Asian/Pacific
Islander residents around the cities of Novi and Troy.
One census tract in the county, tract 9813, has a poverty rate of 100%, though the total
population of 11 is quite low. This tract encompasses Oakland University, located in
Auburn Hills and Rochester, and may explain the unusually high tract poverty rate.
Disregarding this tract, there are four (4) other census tracts in the county with poverty
rates above 40%, all located in the city of Pontiac (see Figure 5). They are tracts 1412,
1421, 1422, and 1423, with poverty rates ranging from 46.9% to 55.3%.
In its fair housing planning guidance, HUD defines racially or ethnically concentrated
areas of poverty (R/ECAPs) as areas where more than one-half of the population is not
White, and the individual poverty rate is over 40% or more than three times the poverty
rate of the MSA, whichever threshold is lower. Based on the most recent 2019-2023
ACS data, the four census tracts mentioned above are all considered R/ECAPs.
131
FIGURE 4. RACE AND ETHNICITY IN OAKLAND COUNTY
132
FIGURE 5. POVERTY RATES IN OAKLAND COUNTY
133
What are the characteristics of the market in these
areas/neighborhoods?
Single-family homes are the predominant housing type in tracts 1412, 1421, and 1423
(comprising 23%, 43%, and 34% of all housing units in each tract, respectively). Large
multifamily apartment complexes of 50 units or more are the predominant housing type
in tract 1422, comprising 37% of the tract’s housing stock, compared to single-family
homes, which make up 32%. Households living in these census tracts are also more
likely to be renters than owners.
Households in these census tracts have significantly lower median household income
($22,114) and homeownership rate (22%) relative to the county as a whole. Despite
these challenges, the area is home to several community resources and is located next
to many of the county’s civic, cultural, and educational resources.
Are there any community assets in these areas/neighborhoods?
The county’s R/ECAPs are located in close proximity to several community assets,
including downtown Pontiac, which is home to many schools, an office of the Michigan
Department of Health and Human Services (MDHHS), the social services organization
Lighthouse, the Pontiac Creative Arts Center, the Pontiac School District Office, and the
City of Pontiac’s city hall.
Are there other strategic opportunities in any of these areas?
Though the city of Pontiac is not part of Oakland County’s CDBG entitlement
jurisdiction, it is home to many social services organizations and institutional offices that
connect county residents with the resources, programs, and services needed to thrive.
The downtown region of Pontiac is supported by the non-profit economic development
group Main Street Pontiac, which is focused on reinvestment in the area, establishing a
diverse, resilient local economy, and preserving the area’s historic character. The city of
Pontiac is also classified as a Qualified Opportunity Zone and a Historically
Underutilized Business Zones (HUBZone), which offers benefits to businesses and
investors.
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MA-60 BROADBAND NEEDS OF HOUSING OCCUPIED BY LOW- AND
MODERATE-INCOME HOUSEHOLDS - 91.210(A)(4), 91.310(A)(2)
Describe the need for broadband wiring and connections for
households, including low- and moderate-income households and
neighborhoods.
Broadband connectivity is a vital community resource that offers citizens access to
employment, education, and other personal enrichment opportunities found through the
internet. In 2015, the FCC defined broadband as internet access with download speeds
of 25 Megabits per second (Mbps) and upload speeds of 3 Mbps (otherwise noted as
25/3). With broadband access, internet users can partake in file downloading, video
streaming, email, and other critical features necessary for online communication.
Disparities in broadband access – particularly for low-to-moderate households – can
create a “digital divide” that limits users’ personal and professional opportunities. The
FCC reports that “Internet adoption appears to have an even stronger correlation to
health outcomes, even after controlling statistically for other potentially confounding
factors, such as education, income, and rurality”8, meaning that a lack of internet access
disproportionately impacts health and possibly even lifespan of low- and moderate-
income communities. In addition, a lack of internet access can intensify other barriers
to upward mobility, such as education, employment, and general access to information
and resources.
A 2024 study from the Pew Research Center found that only 57% of very low-income
households and 76% of low- to moderate-income households reported having high-
speed internet access at home, in comparison to 95% of households in the highest
income bracket9. This is especially troubling in a post COVID era – A 2021 report from
the Pew Research Center noted that 90% of American adults viewed internet access as
important or essential in completing daily tasks post COVID10, while another 2021 Pew
report found that as many as 30% of US students and 10% of teachers lacked adequate
internet access to transfer to online learning during the COVID-19 pandemic 11. Finally,
a 2024 report from the National Bureau of Economic Research found that increased
high-speed internet access resulted in a reduction in mental and physical health
8 https://www.fcc.gov/health/sdoh/studies-and-data-analytics
9 https://www.pewresearch.org/internet/2024/01/31/americans-use-of-mobile-technology-and-home-broadband/
10 https://www.pewresearch.org/internet/2021/09/01/the-internet-and-the-pandemic/
11https://www.edweek.org/technology/acting-fcc-chair-the-homework-gap-is-an-especially-cruel-reality-during-
the-pandemic/2021/03
135
conditions as well as a reduction in deaths from suicide by increasing economic
conditions as “zip codes that gain access to broadband internet see increases in the
numbers of employees and establishments “12.
In Michigan, the State High-Speed Internet Office found the following 13:
• Students with high-speed, home internet access have an overall grade point
average of 3.18. This is significantly higher than the average 2.81 GPA for
students with no home access and 2.75 average for student with only cell phone
access.
• Increased access to the internet can help address issues of isolation among
older adults. Studies have shown that isolation is associated with worse health
outcomes and even premature death among adults age 50 and over.
• Effective use of telemedicine can reduce hospitalizations of nursing home
patients and reduce health care costs.
• Small businesses that have websites have higher annual revenues and are
more likely to have recently hired one or more employees than similar businesses
that aren't online. Those that use social media weekly are three times more likely
to have hired recently than those that don't.
• A study of manufacturers found that 40% said they were able to add new
customers and 57% said they saved money because of their high-speed
internet connection.
• Farmers who gain high-speed internet access experience an average 6%
increase in farm revenue.
• Having a home broadband connection gives households an estimated economic
impact of $1,850 per year.
With these facts in mind, broadband access is an important factor in building and
promoting equity and accessibility among low- and moderate-income residents.
There are three considerations to be taken into account in assessing internet access:
(1) need for broadband wiring and for connections to broadband service; (2) competitive
pricing and service resulting from having more than one internet service provider within
an area; and (3) affordability of broadband service for low- and moderate-income
households. In order to meet growing broadband needs, the State of Michigan
established the Michigan Broadband Internet Office in June 2021. This office is tasked
to pursue the following goals:
12 https://www.nber.org/papers/w32517
13 https://www.michigan.gov/leo/bureaus-agencies/mihi
136
• Ensure that high-speed internet access is available to every home, business,
institution, and community
• Ensure that 95% of Michigan households adopt a permanent home internet
connection
In order to meet these goals, the MBIO implemented the Broadband Equity, Access,
and Deployment (BEAD) Program through a 5-year Action Plan. This plan reports that
within the Detroit Metro area, defined within the plan as Macomb, Oakland, and Wayne
Counties, approximately 12% of households have no internet connection and another
11% of households have internet connection only through a cellular data plan.
Additionally, nearly 7% of households in this area have no electronic devices with which
to access the internet.
Source: https://www.michigan.gov/leo/-/media/Project/Websites/leo/Documents/MIHI/BEAD/MIHI-BEAD-Five-
Year-Plan.pdf?rev=e917202c68cb4bbf8b2437c524d53345&hash=ED2C11D76DE816FB1D7839BEE194CCA7
Marginalized and/or minority households are generally disproportionately represented
among low-to-moderate income households and therefore may be disproportionately
impacted by a lack of internet access. The website BroadbandNow, which exists to help
people discover internet options in their area, conducts research into broadband
availability and user demographics by state and provides data on Michigan households
without internet access. This data shows that 34% of extremely low-income households
and 16% of low-to-moderate income households in Michigan are without internet; that
Black, Native American, and Hispanic residents are substantially more likely than
residents of other races to be without internet access; and that seniors are more likely
than other residents to be without internet access:
137
TABLE 50 – HOUSEHOLD BROADBAND ACCESS
Percent of Residents without Internet Access by Age
Under 18 5%
18-64 6%
65+ 8%
Percent of Homes without Internet Access by Income
Under $20,000 34%
$20,000-$74,999 16%
$75,000+ 4%
Percent of Residents without Internet Access by Race/Ethnicity
Black 10%
White 5%
Hispanic/Latino 7%
Asian/Pacific Islander 3%
Native American 8%
Mixed Race 5%
Source: https://broadbandnow.com/Michigan
Describe the need for increased competition by having more than one
broadband Internet service provider serve the jurisdiction.
Competition generated through having more than one broadband internet service
provider serves to ensure that providers keep pricing and service quality competitive,
which is especially important for low- and moderate-income residents. A lack of
competition among providers may result in higher prices and unserved areas. Despite
new initiatives through the Michigan Broadband Internet Office, the 2019-2023
American Community Survey reports that 6.3% of Oakland County residents do not
have any type of internet service subscription at home. For very low-income residents
earning $20,000 or less per year this number jumps to 21.5%. 10.2% of residents
138
earning $20,000-$75,000 per year have no internet access, while just 2.1% of residents
earning over $75,000 per year are without internet access, highlighting the significance
of affordability in internet access 14.
One source of data on broadband access comes from the website BroadbandNow,
which exists to help people discover broadband options in every area. The map below
depicts internet affordability in the area: green indicates lower minimum prices, while
red indicates higher minimum prices. Number of providers follows a similar pattern, with
areas with lower minimum prices reporting more providers and areas with higher
minimum prices reporting fewer providers.
Source: https://broadbandnow.com/research/national-broadband-map
14 2019-2023 American Community Survey, table S2801
139
Another source of coverage data is the FCC’s National Broadband Map, which shows
that the entirety of Oakland County has access to both fixed and mobile broadband
services:
Source: https://broadbandmap.fcc.gov/area-
summary/combined?version=dec2024&geoid=26125&type=county&zoom=8.84&vlon=-
83.386415&vlat=42.660334&fixed_br=r&fixed_speed=100_20&fixed_tech=1_2_3_6_7&fixed_pct_cvg=0&mobile_t
ech=tech_all&mobile_env=0&mobile_pct_cvg=0
Taken together, these two maps indicate that there is broadband service widely
available throughout the County; however, data on low levels of internet access among
low-income groups indicates that affordability of internet services is a major concern
within the County. Initiatives such as increasing competition among providers,
investigating opportunities for broadband offered as a City or County utility, or creating
broadband assistance funds for low- to moderate-income residents may help to narrow
the digital divide in Oakland County.
140
MA-65 HAZARD MITIGATION - 91.210(A)(5), 91.310(A)(3)
Describe the jurisdiction’s increased natural hazard risks associated
with climate change.
Oakland County’s most recent Hazard Mitigation Plan was updated in 2023 and uses a
rubric to calculate the risk of an event occurring by weighted factors including the
probability of occurrence, the impact of occurrence, and the increased impact of climate
change. The plan notes that according to University Corporation for Atmospheric
Research (UCAR):
• Climate change is causing more extreme weather events, including severe drought
• Places prone to drought are expected to become even drier over the following
century
• Higher temperatures, increasing variation in precipitation patterns, and changes in
lake levels are likely to increase the vulnerability of cities in Oakland County to
extreme events (including flooding, drought, heat waves, and more intense urban
heat island effects), compounding already existing stressors
The plan also discusses the following climate change projections for Oakland County:
• Oakland County is expected to experience a 164% increase in extremely hot days
within 25 years
• By 2048, Oakland County is expected to experience 7 more days that reach above
95°F (from 4 days to 11 days per year)
• Oakland County is projected to experience more rainfall per year but fewer rainy
days per year over the course of the 21st century, meaning that more precipitation
is anticipated per storm, increasing the risk of flooding
After analyzing these and other factors, the Hazard Mitigation Plan identified the
following natural hazards as being of moderate to high risk in Oakland County:
• Flash flooding
• Winter storms or blizzards
• High or severe winds
• River flooding
• Tornadoes
• Ice or sleet storms
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• Extreme cold
• Hail
• Lightning
Describe the vulnerability to these risks of housing occupied by low-
and moderate-income households based on an analysis of data,
findings, and methods.
In its September 2021 report “Climate Change and Social Vulnerability in the United
States,” the US EPA identifies low-income earners, minorities, elderly adults, and
persons with less than a high school diploma as “socially vulnerable.” Socially
vulnerable persons are described as having a reduced capacity to “cope with and
recover from climate change impacts,” and socially vulnerable groups are described as
more likely to live in poorer neighborhoods with lower elevations and poorly maintained
infrastructure. The 2019-2023 ACS estimated that nearly 97,000 people in Oakland
County are living below the poverty line. Additionally, mobile home residents, who are
more likely to be low-income, are especially vulnerable to climate related hazards. The
2019-2023 ACS estimates that there are over 15,000 households living in mobile homes
or other similar types of homes in Oakland County.
The 2023 Oakland County Hazard Mitigation Plan also notes 21 disadvantaged
communities within the County as being at higher risk of climate hazards, describing the
following:
According to the U.S. Council on Environmental Quality (ACEQ), a
community is identified as “disadvantaged” if it is located in a census
tract that is at or above the threshold for one or more environmental,
climate, or other burdens, and at or above the threshold for associated
socioeconomic burdens, including poverty and language barriers (U.S.
Council on Environmental Quality, 2022). The total population of these
21 census tracts is 112,641 which is 22% of the total Oakland County
population. Each census tract is further identified in Appendix F,
illustrating specific socioeconomic burdens to each census tract. This
information was used as part of the hazard risk ranking process and to
determine potential inequities and disparities regarding potential
impacts from natural hazards.
The plan also assesses specific vulnerabilities and concerns faced by these
disadvantaged communities for each type of natural disaster.
142
2026-2030
Strategic Plan
143
SP-05 OVERVIEW
Strategic Plan Overview
The Strategic Plan will guide the allocation of Community Development Block Grant
(CDBG), HOME Investment Partnerships (HOME), and Emergency Solutions Grant
(ESG) funding during the 2026-2030 planning period. Oakland County’s goals for the
2026-2030 period focus on a number of high priority needs identified through data
analysis, community member input, consultation with County staff and other public
agencies, and review of recently completed plans and studies. Available resources will
be targeted toward specific goals designed to address those priority needs. These goals
include:
• Increase and improve affordable housing options
• Increase and improve homeless service, shelter, and prevention efforts
• Create and sustain a suitable living environment through infrastructure and public
facility improvements
• Provide public services to expand economic opportunity, improve safety,
enhance food access, and provide other assistance for low- and moderate-
income households, seniors, people with disabilities, and other eligible groups
• Administration of funding and projects
The above-listed goals will be used to guide funding decisions for each program year
and to prepare the Annual Action Plans. Each program year, the County will allocate
funding to subrecipients through a competitive application process. Each year over the
five-year planning timeframe, Oakland County anticipates receiving an estimated
$3,767,803 in CDBG funds, $1,877,222.90 in HOME funds, and $328,280 in ESG
funds. Actual funding levels will vary each year. While some funding investments will be
made throughout the County, others will be geographically focused in specific target
areas. The County will target these countywide, with emphasis on areas of low- and
moderate-income census tracts.
144
SP-10 GEOGRAPHIC PRIORITIES – 91.215 (A)(1)
Geographic Area
Target Area Percentage of Funds
Countywide 67%
HOME Consortium area 33%
TABLE 51 - GEOGRAPHIC PRIORITY AREAS
Area Name: Oakland County
Area Type: Urban County
Other Target Area Description: N/A
HUD Approval Date: N/A
% of Low/ Mod: N/A
Revital Type: N/A
Other Revital Description: N/A
Identify the neighborhood
boundaries for this target area. All participating CDBG/ESG communities
Include specific housing and
commercial characteristics of this N/A
citizen participation process help
you to identify this neighborhood N/A
Identify the needs in this target
area. N/A
145
What are the opportunities for
improvement in this target area? N/A
Are there barriers to improvement
in this target area? N/A
Area Name: Oakland County HOME Consortium
Area Type: Consortium
Other Target Area Description: N/A
HUD Approval Date: N/A
% of Low/ Mod: N/A
Revital Type: N/A
Other Revital Description: N/A
Identify the neighborhood
boundaries for this target area. All participating HOME communities
Include specific housing and
commercial characteristics of this N/A
citizen participation process help
you to identify this neighborhood
N/A
Identify the needs in this target
area. N/A
What are the opportunities for
improvement in this target area? N/A
Are there barriers to improvement
in this target area? N/A
146
General Allocation Priorities
Describe the basis for allocating investments geographically within
the jurisdiction (or within the EMSA for HOPWA)
Oakland County does not allocate investments geographically and does not plan to
identify any specific Neighborhood Revitalization Strategy Areas (NRSA). Activities
selected will be eligible for funding based on their ability to meet Oakland County goals,
which currently prioritize housing and other similarly transformative projects.
The following 52 (85%) of Oakland County communities participate in the County's
"Urban County" CDBG housing and community development programs: Cities - Auburn
Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale,
Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights,
Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Rochester, Rochester
Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom Townships - Addison,
Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon,
Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White
Lake Villages - Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville,
Oxford and Wolverine Lake. Farmington Hills, Royal Oak, Southfield, Pontiac, and
Waterford Township are HUD entitlement communities. These communities with over
50,000 residents are "entitled" to receive HUD funds and have chosen to administer
their own CDBG programs. The City of Lake Angelus, Novi Township, Southfield
Township and the Village of Bingham Farms do not receive HUD funds.
Oakland County’s Recapture and Reallocation Policy allows the County to take back
CDBG funds from participating communities if they remain unobligated for two years,
ensuring compliance with federal timeliness rules. The County then redistributes these
recaptured dollars to communities or projects that can spend them quickly and
effectively, helping maintain HUD’s required expenditure pace and directing resources
to activities that benefit low‑ and moderate‑income residents.
Oakland County HOME Consortium - Oakland County serves as the lead entity for
the Oakland County HOME Consortium (OCHC), which is comprised of the Urban
County of Oakland, Farmington Hills, Royal Oak, and Southfield. The HOME program
funds HIP, Rental Development/Preservation gap financing and CHDO activities
throughout Consortium communities.
147
SP-25 PRIORITY NEEDS - 91.215(A)(2)
Priority Needs
During the development of the Consolidated Plan, seven priority needs were identified.
Each of the needs is described in the table that follows along with a basis for its priority
designation and the populations to be served.
TABLE 52 – PRIORITY NEEDS SUMMARY
1
Priority Need Increase and Improve Affordable Housing Options
Priority Level High
Population
Extremely low income
Low income
Moderate income
Large family
Families with children
Elderly/frail elderly
Public housing residents
People with disabilities
People experiencing homelessness
Geographic Areas
Affected Countywide
Associated Goals Increase and Improve Affordable Housing Options
Description
Activities furthering access to and availability of affordable housing
options including but not limited to: rental and homeowner
rehabilitation efforts; increased marketing of available services and
funding throughout the County, especially in northern and rural
areas; aging in place initiatives; home ownership assistance and
education; increased availability of programs and materials in non-
English languages, especially Spanish; code enforcement efforts;
and other relevant initiatives.
Basis for Relative
Priority
The primary housing need identified by residents, stakeholders, and
service providers in Oakland County through the community
participation process was a significant need for increased access to
and inventory of affordable housing for all low- and moderate-
income groups. Additional needs included emergency rehab and
148
repair for both renters and owners and a significant need for better
advertisement of available programs and services, especially in
northern and/or rural parts of the County – residents in these areas
reported a pressing need for programs such as emergency rehab
and repair which already exist, indicating that there is a need for
better marketing and collaboration with rural parts of the County.
2
Priority Need Increase Homeless Shelter, Service, and Prevention Efforts
Priority Level High
Population
Extremely low income
Low income
Moderate income
Large family
Families with children
Elderly/frail elderly
Public housing residents
People with disabilities
People experiencing homelessness
Geographic Areas
Affected Countywide
Associated Goals Increase Homeless Shelter, Service, and Prevention Efforts
Description
Activities furthering access to and availability of homeless shelter,
service, and prevention efforts, including but not limited to:
additional overnight and warming center beds; eviction prevention;
expanded street outreach efforts; initiatives to narrow the digital
divide among the homeless population, including expansion of the
existing informational kiosk program; increased shelter and service
options for survivors of domestic violence; increased shelter and
service options in northern and/or rural areas of the County; and
other relevant initiatives.
Basis for Relative
Priority
Service providers and residents who provided feedback during the
community engagement process overwhelmingly reported that
homelessness is a growing issue within Oakland County – an
observation that is backed by data from the Alliance for Housing,
which serves as the CoC for the County. In particular, service
providers noted an urgent need for additional emergency night
shelter and warming center space, with some reporting that they
had experienced clients freezing to death due to a lack of access to
beds or warming centers. Other urgent needs consistently reported
149
included access to the internet and electronic devices, which is
required to participate in case management and access resources
and services; access to transportation; broad/non targeted street
outreach efforts; and increased homelessness and eviction
prevention efforts – service providers especially noted that in the
2010s and during COVID there was a significantly larger amount of
prevention funding available, and that the loss of this funding has
led to significant issues and an increase in homelessness.
3
Priority Need Create And Sustain a Suitable Living Environment through
Infrastructure and Public Facility Improvements
Priority Level High
Population
Extremely low income
Low income
Moderate income
Large family
Families with children
Elderly/frail elderly
Public housing residents
People with disabilities
People experiencing homelessness
Geographic Areas
Affected Countywide
Associated Goals Create and sustain a suitable living environment through
infrastructure and public facility improvements
Description
Activities furthering creating and sustaining a suitable living
environment through infrastructure and public facility improvements,
including but not limited to: park, playground, community center, and
other recreation facility expansion, repair, and maintenance; street,
sidewalk, street light, and drain expansion, repair, and maintenance;
ADA accessibility improvements; infrastructure improvements in
rural areas of the County; and other relevant initiatives.
Basis for Relative
Priority
Community members and stakeholders engaged in the community
feedback process most often noted a need for improvements of
parks and recreation facilities, roads, sidewalks, streetlights, and
community centers. Additionally, a lack of infrastructure suitable to
support development in rural areas of the County was noted as a
barrier to expanding affordable housing access.
150
4
Priority Need
Provide public services to expand economic opportunity,
improve safety, enhance food access, and provide other
assistance for low- and moderate-income households, seniors,
people with disabilities, and other eligible groups
Priority Level High
Population
Extremely low income
Low income
Moderate income
Large family
Families with children
Elderly/frail elderly
Public housing residents
People with disabilities
People experiencing homelessness
Geographic Areas
Affected Countywide
Associated Goals
Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for low-
and moderate-income households, seniors, people with disabilities,
and other eligible groups
Description
Activities furthering public service availability and access, including
but not limited to: increased service availability in northern and rural
parts of the County; increased access to free or affordable transit
services; increased access to free or affordable childcare services;
increased access to programs and services available in Spanish;
increased housing-related services including housing counseling,
homebuyer education, and financial literacy; formation and/or
advertisement of a centralized phone-based resource hub for
residents who do not have access or the ability to use a computer;
and other relevant initiatives.
Basis for Relative
Priority
Community members and stakeholders engaged in the community
feedback process noted significant needs related to childcare and
transit options, especially for low-income groups, noting that a lack
of transit and/or childcare frequently prevents eligible residents from
accessing existing resources. Other needs noted were programs
and information available in Spanish, especially housing information
and services; homebuyer education programs and services; and
better organized information on how to access services in northern
and rural parts of the County. Residents in these areas of the
151
County reported people “making phone calls all day and still not
knowing how to get help”; however, comprehensive resource guides
are easy to find with a web search, indicating that this issue may
most affect those who cannot or do not know how to access
information via web.
5
Priority Need Administration of Funding and Projects
Priority Level High
Population
Extremely low income
Low income
Moderate income
Large family
Families with children
Elderly/frail elderly
Public housing residents
People with disabilities
People experiencing homelessness
Geographic Areas
Affected Countywide
Associated Goals Administration of Funding and Projects
Description
Costs and activities related to and/or supporting the administration
of funding and projects, including marketing of available initiatives
and services
Basis for Relative
Priority
Program administration costs associated with the coordination and
delivery of services to Oakland County residents.
152
SP-30 INFLUENCE OF MARKET CONDITIONS – 91.215 (B)
Influence of Market Conditions
TABLE 53 – INFLUENCE OF MARKET CONDITIONS
Affordable Housing Type Market Characteristics that will influence
the use of funds available for housing type
Tenant Based Rental Assistance
(TBRA)
High level of cost burdens among low-income
households; waiting lists for assisted housing
units; and need for short-term rental assistance
for homeless individuals and families
transitioning to permanent housing. Currently,
TBRA is provided through HUD’s Section 8
Housing Choice Voucher program administered
through local housing authorities.
TBRA for Non-Homeless Special
Needs
High level of cost burdens among low-income
households, including non-homeless special
needs populations; waiting lists for assisted
housing units for seniors and people with
disabilities.
New Unit Production
Age and condition of housing; waiting lists at
existing assisted housing developments; high
occupancy rates and rental rates; sales prices
unaffordable to low/moderate income
households.
Rehabilitation
Age and condition of housing; issues related to
substandard housing, especially for low-income
renters; need for home repairs for seniors and
other homeowners, including lead-based paint
remediation.
Acquisition, including preservation
Subsidized housing developments anticipated to
age out of their affordability period; age,
condition, and availability of multifamily
properties suitable for acquisition/rehabilitation;
vacant/hazardous buildings identified through
code enforcement.
153
SP-35 ANTICIPATED RESOURCES - 91.215(A)(4), 91.220(C)(1,2)
Introduction
Oakland County is eligible to receive funding from three CPD formula grants (CDBG, HOME, and ESG). Combined, the
County will receive an anticipated $5,973,305.90 in HUD grant funds for the 2026 program year. The table below outlines
anticipated funding levels by program.
Anticipated Resources
TABLE 54 - ANTICIPATED RESOURCES
Pr
o
g
r
a
m
Fu
n
d
s
Expected Amount Available Year 1 Expected
Amount
Available
Remainder
of ConPlan
Narrative
Description Annual
Allocation
Program
Income
Prior Year
Resources Total
CDBG
public
-
federal
Acquisition
Admin and
Planning
Economic
Development
Housing
Public
Improvements
Public Services
$3,767,803.00
$1,481,204.14
$0.00 $5,249,007.14 $19,471,212.00
neighborhood
and housing
improvements,
multi-family
rehab, and
public
services
benefiting low-
income
persons
throughout
Oakland
County Urban
County
participating
154
HOME
public
-
federal
Acquisition
Homebuyer
assistance
Homeowner
rehab
Multifamily
rental new
construction
Multifamily
rental rehab
New
construction for
ownership
Tenant Based
Rental
Assistance
(TBRA)
$1,877,222.90 $1,600,000.00 $0.00 $3,477,222.90 $13,908,891.60
rehabilitation,
new
construction of
affordable
housing
including
rental
development
and
homebuyer
assistance
throughout
Oakland
County
HOME
Consortium
participating
ESG
public
-
federal
and
rehab for
transitional
housing
Financial
Assistance
Overnight
shelter
Rapid
rehousing
(rental
assistance)
Rental
Assistance
Services
Transitional
$328,280.00 $0.00 $0.00 $328,280.00 $1,313,120.00
Emergency
Shelter,
Homeless
Prevention and
Rapid Re-
Housing, HMIS
and
Administration
throughout
Oakland
County Urban
County
participating
communities.
155
Explain how federal funds will leverage those additional resources
(private, state and local funds), including a description of how
matching requirements will be satisfied
CDBG - No Match Requirement
• In-kind County level administrative functions: human resources, marketing, fiscal
services, purchasing, auditing, corporation counsel, record retention and mail
room support services
• Infrastructure and public facility projects supported with funds from participating
• Revolving Loan Fund (RLF) generated from paybacks on CDBG funded housing
rehabilitation loans supplement the HIP. During PY 2026 the County will recycle
approximately $1,100,00 in CDBG RLF into the HIP for the rehabilitation of
approximately 50 single-family homes of LI residents
• Program Income (PI) Estimate generated from Neighborhood Stabilization
paybacks. During PY 2026 the County will recycle approximately $381,204.14 in
CDBG PI into the eligible activities.
• Emergency, youth, senior and other public services designed to meet special
needs of LI residents are expanded through leverage from various public service
agencies.
HOME - 25% Match Requirement
• Oakland County ensures that all housing projects receive $1 of non-federal match
for every $4 of HOME funds expended, in accordance with federal guideline
(s.92.218)
• The HOME program requires a 25% match on all non-administrative activities. In
PY 2026, $469,306 in general funds will serve as match for County level housing
rehabilitation, rental development/preservation and homebuyer assistance
activities
• CHDO’s leverage HOME funds with state and private resources to develop
affordable housing
• PI generated from paybacks on HOME funded housing rehabilitation loans
supplement the HIP
ESG - 100% Match Requirement
• Oakland County passes on the match requirements to its vendors
• Cash contributions for allowable costs including staff salaries/fringe benefits
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• Noncash contributions
• Volunteer services are matched at the current minimum wage salary unless the
recipient can verify a higher rate of pay for current employees performing similar
work
• Real property, equipment, goods or services that if the recipient had to pay for
them with grant funds, the payments would have been indirect costs
• The value of donated goods and services such as clothing, food, diapers, haircuts,
etc. - value placed should be consistent with Office of Management and Budget
Circulars
If appropriate, describe publicly owned land or property located
within the jurisdiction that may be used to address the needs
identified in the plan
Designated CHDOs may access publicly owned land or property for redevelopment as
affordable housing through public or private entities. The County created the Oakland
Together Housing Trust Fund (HTF) and a Land Bank Authority to invest in publicly
owned and/or tax-foreclosed land. The HTF was initially funded with $18M of American
Rescue Plan Act (ARPA) funding as well as an ongoing $2M annual appropriation of
County resources. The HTF and NHD partners with affordable housing developers, non-
profits, CHDOs, local municipalities to develop a wide range of housing including shelter
space, permanent supportive housing, PBV/HCV supported housing, senior affordable
housing, family affordable housing, workforce housing, adaptive reuse housing, and
other types of housing. The housing investments of NHD and the HTF leverage federal
and County funds with other financial sources such as LIHTC, State funding, local
funding, property tax exemptions, brownfield tax increment financing, private loans,
private equity, and other available resources.
Since 2023, over 1,550 units of mixed income housing have been created or preserved
using NHD and HTF funding. These units are at various stages of development from
completed, under construction, or awaiting financial close in the near term. NHD and the
HTF’s total investment of $37.1M includes $18M in ARPA funding, $5.6M in County
general funds, and $13.5M in HOME/CDBG funding resulting in a leveraged investment
of over $404M into affordable and workforce housing throughout the County.
Discussion
Oakland County recognizes that Congress is considering updates to the CDBG program
that could expand the eligible use of funds for housing development, including potential
authority for communities to dedicate a portion of their CDBG allocation to new housing
construction. While these changes remain speculative and subject to congressional
negotiation, the County acknowledges the possibility that future statutory or regulatory
157
revisions may shift CDBG toward a stronger housing‑production focus. Should such
changes be enacted, the County will adapt its CDBG program accordingly to ensure a
maximum commitment of funds to address the housing affordability needs of low‑ and
moderate‑income residents.
158
SP-40 INSTITUTIONAL DELIVERY STRUCTURE – 91.215(K)
Explain the institutional structure through which the jurisdiction will
carry out its consolidated plan including private industry, non-profit
organizations, and public institutions.
Agencies and organizations through which Oakland County will carry out its
Consolidated Plan are shown in Table 55. In addition to those listed in the table, the
County will rely on a variety of non-profit and private sector housing developers,
including Community Housing Development Organizations (CHDOs), Low Income
Housing Tax Credit developers, and others.
TABLE 55 - INSTITUTIONAL DELIVERY STRUCTURE
Responsible
Entity
Responsible
Entity Type Role Geographic Area
Served
Oakland County
Neighborhood and
Housing Development Government
Affordable housing
(ownership and rental)
Public facilities
Public services
Homelessness
Non-homeless special
needs
Neighborhood
improvements
Planning
Jurisdiction
Oakland County
Housing Trust Fund Government Affordable housing
(ownership and rental) Jurisdiction
Oakland County
Veteran's Services Government
Homelessness
Non-homeless special
needs
Public services
Jurisdiction
Alliance for Housing CoC
Affordable housing
(ownership and rental)
Homelessness
Planning
Jurisdiction
159
Plymouth Housing
Commission PHA
Affordable housing
(rental)
Public housing
Planning
South Lyon Housing
Commission PHA
Affordable housing
(rental)
Public housing
Planning
Jurisdiction
Royal Oak Township
Housing Commission PHA
Affordable housing
(rental)
Public housing
Planning
Jurisdiction
Ferndale Housing
Commission PHA
Affordable housing
(rental)
Public housing
Planning
Jurisdiction
Southfield Housing
Commission PHA
Affordable housing
(rental)
Public housing
Planning
Jurisdiction
Royal Oak Housing
Commission PHA
Affordable housing
(rental)
Public housing
Planning
Jurisdiction
Madison Heights
Housing Commission PHA
Affordable housing
(rental)
Public housing
Planning
Jurisdiction
Michigan State Housing
Development Authority
(MSHDA) PHA
Affordable housing
(rental)
Public housing
Planning
State
Participating CDBG
Communities Government Public facilities
Neighborhood
Jurisdiction
160
improvements
Planning
HOME Consortium Government
Public facilities
Neighborhood
improvements
Planning
Jurisdiction
Assess of Strengths and Gaps in the Institutional Delivery System
Oakland County is a very large jurisdiction both in land mass and in number of
participating jurisdictions, entities, and organizations. This variety within the institutional
delivery system is a strength in that it provides a diverse offering of resources dispersed
broadly throughout the County, each with their own ties to the community. However,
this large number of participating organizations requires special consideration and effort
in the area of collaboration and data-sharing to ensure that funding and efforts are most
effectively directed to serve the jurisdiction as a whole without redundancies. Interviews
with service providers during the community participation process indicated that
Oakland County has made significant improvements in inter-agency collaboration in
recent years, but that collaboration could still be improved. As long as the County
remains committed to furthering collaboration and data-sharing between its institutional
delivery partners, this diversity of providers will remain a strength and not a weakness.
Availability of services targeted to homeless persons and persons
with HIV and mainstream services
TABLE 56 - HOMELESS PREVENTION SERVICES SUMMARY
Homelessness
Prevention Services
Available in the
Community
Targeted to
Homeless
Targeted to
People with HIV
Homelessness Prevention Services
Counseling/Advocacy X X X
Legal Assistance X X X
Mortgage Assistance X
Rental Assistance X X X
Utilities Assistance X X X
Street Outreach Services
161
Describe how the service delivery system including, but not limited
to, the services listed above meet the needs of homeless persons
(particularly chronically homeless individuals and families, families
with children, veterans and their families, and unaccompanied youth)
The Oakland County Continuum of Care, operated through the Alliance for Housing,
unites 37 agencies and organizations in order provide housing and services to people
experiencing homelessness, including but not limited to:
• A total of 249 year-round and 42 seasonal or voucher-based emergency housing
beds for families with children, adults alone, and unaccompanied children
• A total of 78 transitional housing beds for families with children, adults alone, and
unaccompanied children
Law Enforcement X X
Mobile Clinics X X X
Other Street Outreach
Services X X X
Supportive Services
Alcohol & Drug Abuse X X X
Child Care X X
Education X
Employment and
Employment Training X X
Healthcare X X X
HIV/AIDS X X X
Life Skills X X X
Mental Health Counseling X X
Transportation X X
Other
Other
162
• A total of 1,144 permanent supportive housing beds for families with children,
adults alone, chronically homeless persons and families, and veterans
• Searchable databases providing connections to resources including education,
employment, financial, food, goods, health, housing, legal, transportation, and
warming or cooling centers
• A comprehensive resource guide to mainstream services which may be useful to
individuals experiencing homelessness compiled by McLaren Physician Partners
Describe the strengths and gaps of the service delivery system for
special needs population and persons experiencing homelessness,
including, but not limited to, the services listed above
As with the service delivery system as a whole, the large number of individual service
providers united under the Alliance for Housing may comprise both a strength and a
weakness, depending on the level of collaboration and data sharing between
organizations. Service providers interviewed during the community engagement
process indicated that collaboration has increased significantly in recent years and that
the largest gaps lie in the following areas:
• A large insufficiency of emergency shelter beds
• Insufficient comprehensive transit options for low-income and homeless
populations
• Insufficient consistent access to internet and electronic devices for people
experiencing homelessness, which are required for participation in most homeless
resource programs
• Insufficient street outreach targeted to those who are homeless but who are not
experiencing mental or behavioral health concerns
• Insufficient affordable, accessible childcare options for low-income and homeless
populations
Provide a summary of the strategy for overcoming gaps in the
institutional structure and service delivery system for carrying out a
strategy to address priority needs
Service providers in Oakland County will continue to actively increase collaboration and
data sharing efforts in order to avoid redundancy in services and target limited funds in
the most impactful ways. The Alliance for Housing will continue to organize service
providers and serve as the lead agency and CoC for homelessness and related
services within Oakland County while continually attempting to expand services
provided. Finally, Oakland County is currently addressing a noted gap in internet and
163
device access for those experiencing homelessness by installing free resource access
kiosks throughout the County.
164
SP-45 GOALS SUMMARY – 91.215(A)(4)
Goals Summary Information
TABLE 57 – GOALS SUMMARY
Sort
Order Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
1
Increase and
Improve
Affordable
Housing
Options
2026 2030
Housing
Affordability
and
Condition
Countywide Housing
Affordability
and Condition
CDBG:
$13,410,363.05
HOME:
$15,647,502.60
Rental units
constructed:
570 housing units
Rental units
rehabilitated:
580 housing units
Homeowner housing
rehabilitated:
700 housing units
Direct financial
assistance to
homebuyers:
50 households assisted
Homeowner housing
added:
35 housing units
2
Increase and
Improve
Homeless
Shelter,
Service, and
Prevention
Efforts
2026 2030 Homeless Countywide Homeless
Needs
ESG:
$1,641,400.00
Homeless person
overnight shelter:
2,500 persons assisted
Homelessness
prevention:
500 persons assisted
165
Sort
Order Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
3
Create and
sustain a
suitable living
environment
through
infrastructure
and public
facility
improvements
2026 2030
Non-Housing
Community
Development
Countywide
Infrastructure
and Public
Facility
Improvements
CDBG:
$4,316,015.00
Public facility or
infrastructure activities
other than
low/moderate-income
housing benefit:
150,000 persons
assisted
Public facility or
infrastructure activities
for low/moderate-
income housing benefit:
10,000 households
assisted
Housing code
enforcement/Foreclosed
property care:
25,000 housing units
Buildings demolished:
25 buildings
166
Sort
Order Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
4
Provide public
services to
expand
economic
opportunity,
improve
safety,
enhance food
access, and
provide other
assistance for
low- and
moderate-
income
households,
seniors,
people with
disabilities,
and other
eligible groups
2026 2030
Non-
Homeless
Special
Needs
Non-Housing
Community
Development
Countywide Public
Services
CDBG:
$3,653,352.25
Public service activities
other than
low/moderate-income
housing benefit:
3,500 persons assisted
Public service activities
for low/moderate-
income housing benefit:
250 households
assisted
5
Administration
of funding and
projects
2026 2030
Non-
Homeless
Special
Needs
Non-Housing
Community
Development
Affordable
Housing
Homeless
Countywide Program
Administration
CDBG:
$4,867,803.00
HOME:
$1,738,611.45
N/A
167
Goal Descriptions
Goal Name Goal Description
Increase and Improve Affordable
Housing Options
Activities furthering access to and availability of affordable
housing options including but not limited to: new housing
production, multifamily rental acquisition and rehabilitation
efforts; homeowner rehabilitation efforts; tenant-based rental
assistance, increased marketing of available services and
funding throughout the County, especially in northern and
rural areas; aging in place initiatives; home ownership
assistance and education; increased availability of programs
and materials in non-English languages, especially Spanish;
code enforcement efforts; and other relevant initiatives.
Increase and Improve Homeless
Shelter, Service, and Prevention
Efforts
Activities furthering access to and availability of homeless
shelter, service, and prevention efforts, including but not
limited to: additional overnight and warming center beds;
eviction prevention; expanded street outreach efforts;
initiatives to narrow the digital divide among the homeless
population, including expansion of the existing informational
kiosk program; increased shelter and service options for
survivors of domestic violence; increased shelter and service
options in northern and/or rural areas of the County; and other
relevant initiatives.
Create and sustain a suitable living
environment through infrastructure
and public facility improvements
Activities furthering creating and sustaining a suitable living
environment through infrastructure and public facility
improvements, including but not limited to: park, playground,
community center, and other recreation facility expansion,
repair, and maintenance; street, sidewalk, street light, and
drain expansion, repair, and maintenance; ADA accessibility
improvements; infrastructure improvements in rural areas of
the County; and other relevant initiatives.
Provide public services to expand
economic opportunity, improve safety,
enhance food access, and provide
other assistance for low- and
moderate-income households,
seniors, people with disabilities, and
other eligible groups
Activities furthering public service availability and access,
including but not limited to: increased service availability in
northern and rural parts of the County; increased access to
free or affordable transit services; increased access to free or
affordable childcare services; increased access to programs
and services available in Spanish; increased housing-related
services including housing counseling, homebuyer education,
and financial literacy; formation and/or advertisement of a
centralized phone-based resource hub for residents who do
not have access or the ability to use a computer; and other
relevant initiatives.
Administration of funding and projects
Program administration costs associated with the coordination
and delivery of services to Oakland County residents,
including but not limited to staff salary, planning, and
administrative service delivery costs for implementing the
Community Development Block Grant (CDBG), HOME
Investment Partnerships (HOME) and Emergency Solutions
Grant (ESG) programs.
168
Estimate the number of extremely low-income, low-income, and
moderate-income families to whom the jurisdiction will provide
affordable housing as defined by HOME 91.315(b)(2)
Oakland County invested $1.4M in HOME entitlement and Match funding into John
Grace Arms, a 60-unit senior affordable rental community. This development contains 7
HOME-funding units as part of the total 60 units (all low-income).
Oakland County also plans to fund the substantial renovation of Ferndale Park Co-op, a
200-unit senior rental community which will include 10 HOME-funded units. All 200 units
are restricted for low-income seniors. One for-sale unit developed by Venture, Inc, a
Oakland County CHDO will also be sold to a household earning less than 80% of the
area median income.
As a part of the County administered Home Improvement Program 50 Single Unit
Owner Occupied Rehab projects will be funded using HOME Funds for the upcoming
program year .
169
SP-50 PUBLIC HOUSING ACCESSIBILITY AND INVOLVEMENT –
91.215(C)
Need to Increase the Number of Accessible Units (if Required by a
Section 504 Voluntary Compliance Agreement)
N/A, the jurisdiction is not under a Section 504 Voluntary Compliance Agreement.
Activities to Increase Resident Involvements
Resources for residents of publicly supported housing are accessible through the
Community Housing Network’s comprehensive Housing Resource Center. Residents of
Oakland County can call the HRC to be paired with a trained housing specialist who will
connect them with programs, resources, and housing opportunities based on caller
eligibility, location, and circumstances. The Housing Resource Center is the designated
HARA (Housing Assessment and Resource Agency) for Oakland County through the
Continuum of Care and MSHDA (the Michigan State Housing Development Authority)
and provides a comprehensive one-stop resource center for resources available
through various PHAs and service providers throughout the County.
Is the public housing agency designated as troubled under 24 CFR
part 902?
Oakland County Neighborhood & Housing Development Division does not administer a
public housing commission; a total of 7 local housing commissions and the Michigan
State Housing Development Authority provide publicly supported housing and resources
within the County. None of these agencies are designated as troubled.
Plan to remove the ‘troubled’ designation
N/A
170
SP-55 BARRIERS TO AFFORDABLE HOUSING – 91.215(H)
Barriers to Affordable Housing
Negative Effects of Public Policies on Affordable Housing and Residential
Investment
Oakland County’s 2020 Analysis of Impediments to Fair Housing Choice (AI) identifies
several challenges related to housing affordability and access as county’s barriers to fair
housing choice. The AI also includes a review of the county’s existing zoning code and
identifies policies that may limit the development of affordable housing in the region.
Housing problems and limited access to homeownership disproportionately
impact protected classes
Analysis of 2008-2017 homeownership data from the Housing Mortgage Disclosure Act
(HMDA) showed that the mortgage denial rate in Oakland County is disproportionately
among Black and African American households, who had an average denial rate of
29%. This denial rate was significantly higher than the county’s overall average of 15%.
Comparatively, White households had the county’s lowest average denial rate at 13%.
Additionally, Comprehensive Housing Affordability Strategy (CHAS) data analysis on
housing needs performed in this Consolidated Plan revealed that Black households
exhibited disproportionately high rates of housing problems compared to the county as
a whole.
Disparate patterns in lending, moderate to high levels of segregation, insufficient
affordable housing in a range of unit sizes, racial minority households with
disproportionate rates of housing problems, insufficient accessible affordable housing,
and discrimination on the basis of disability were all identified as high priority
contributing factors that impacted fair housing choice in the county’s latest AI.
Zoning, Affordability, and Housing Choice
Although zoning ordinances and land use codes play an important role in regulating the
health and safety of the built environment, overly restrictive codes can negatively impact
housing affordability and fair housing choice within a jurisdiction. A Land Use Planner
Survey of jurisdictions’ zoning codes and land use regulations was conducted to identify
any barriers that might impede access to housing. This survey found that most
jurisdictions define the word “family” as related by blood, marriage, or adoption or
"related" in any other traditional sense, which may limit access to housing choice. In
171
addition, few jurisdictions actively encourage affordable housing development or
inclusionary policies.
Barriers to housing access in the private market
In addition to these public-sector barriers, the private market can also create barriers.
Some landlords may refuse to rent units to households receiving other forms of housing
assistance. This practice, known as source of income discrimination, reduces the
affordability of existing units in the private housing stock and creates barriers to
obtaining affordable housing. While source of income discrimination is illegal in the state
of Michigan, many residents still struggle to find landlords willing to accept Section 8 or
Housing Choice Vouchers for reasons ranging from stigma and discrimination to
landlord concern about the potential for added cost. Housing Choice Vouchers make up
a significant portion of publicly supported housing within Oakland County and are a key
element in providing affordable housing to the county’s most vulnerable populations.
Because of this, landlord reluctance presents a significant barrier to affordable housing.
Strategy to Remove or Ameliorate the Barriers to Affordable Housing
Oakland County has implemented several strategies to increase access to affordable
housing in the region through countywide programs and partnerships with area
nonprofits and service organizations. These actions include the County’s establishment
of the Housing Trust Fund (HTF) in 2023, which supports the development and
preservation of affordable, attainable, workforce, and mixed-income housing throughout
the county. Eligible applicants for HTF funds include developers, Community Housing
Development Organizations (CHDOs), government entities, local housing
commissions/authorities, and other housing-related development/preservation entities.
The HTF and NHD have been instrumental in funding financial gaps for many affordable
housing developments since its inception, which includes the preservation or creation of
1,550 mixed income units throughout the County.
The Unlocking Doors Oakland County Program also helps remove barriers to housing
for homeless individuals receiving voucher assistance. This program incentivizes
landlords to rent their home or apartment to a homeless individual with a housing
voucher by providing up to $3,000 in assistance for minor unit repairs if they participate.
172
SP-60 HOMELESSNESS STRATEGY – 91.215(D)
Describe how the jurisdiction's strategic plan goals contribute to:
Reaching out to homeless persons (especially unsheltered persons)
and assessing their individual needs
Homeless service providers interviewed during the community engagement process
noted a need to expand street outreach efforts to include non-targeted/broad community
outreach to homeless persons, noting that existing outreach efforts were limited to those
with mental or behavioral health concerns. Expansion of street outreach efforts is
included in Goal #2 as outlined in SP-45.
Addressing the emergency and transitional housing needs of
homeless persons
Homeless service providers in Oakland County noted that the most urgent
homelessness related need in the County is expansion of emergency shelter and
warming center options, with service providers reporting that they had experienced
clients freezing to death due to a lack of shelter or warming center bed space. Because
of the life or death nature of this need, expansion of emergency shelter and warming
center options should be the primary focus of homelessness related initiatives in
Oakland County until such time as the County has adequate bed space to protect the
life and health of the homeless population. Expansion of bed space is included in Goal
#2 as outlined in SP-45.
Helping homeless persons (especially chronically homeless
individuals and families, families with children, veterans and their
families, and unaccompanied youth) make the transition to permanent
housing and independent living, including shortening the period of
time that individuals and families experience homelessness,
facilitating access for homeless individuals and families to affordable
housing units, and preventing individuals and families who were
recently homeless from becoming homeless again.
Homeless service providers interviewed reported several needs related to transitions
out of homelessness and avoiding a return to homeless. The most pressing of these
needs was consistent and long-term access to internet and electronic devices for
people experiencing homelessness, with many providers noting that a lack of consistent
access to these resources was a significant barrier to clients being able to receive
services or remain in long-term programs. Many providers noted clients losing touch
173
with case management or being unable to contact a client who had received housing
because the client had lost access to internet and/or a functioning device. Other needs
noted as relevant to transitioning out of and remaining out of homelessness were
access to free or low-cost transportation and childcare, with a lack of these services
being adversely related to a return to homelessness. Expansion of these services and
resources are included in Goal #2 as outlined in SP-45.
Help low-income individuals and families avoid becoming homeless,
especially extremely low-income individuals and families who are
likely to become homeless after being discharged from a publicly
funded institution or system of care, or who are receiving assistance
from public and private agencies that address housing, health, social
services, employment, education or youth needs
Homelessness and eviction prevention initiatives were reported as a key need by
homeless service providers within the County, with several noting that there was
significantly more funding available for such programs in the 2010s and during COVID
and that the loss of this funding has had significant adverse impacts on homelessness
within Oakland County. Expansion and funding of such services are included in Goal #2
as outlined in SP-45.
174
SP-65 LEAD BASED PAINT HAZARDS – 91.215(I)
Actions to address LBP hazards and increase access to housing
without LBP hazards
Oakland County follows HUD’s Lead Safe Housing Rule requirements for any federally
funded affordable housing development activities. The rule includes requirements for
disclosure of lead-based paint hazards, risk assessment, evaluation, hazard reduction,
interim controls, maintenance, and rehabilitation of properties.
As of April 30, 2025, the State of Michigan requires blood lead testing for young
children. If a client receives a test result with a lead level of 3.5 micrograms per deciliter
(µg/dL) or greater, they qualify for lead case management services through Oakland
County’s Health Division. The County also offers lead screenings at various locations
and times throughout the month. These services are offered as part of the County’s
Childhood Lead Poisoning Prevention Program.
How are the actions listed above related to the extent of lead
poisoning and hazards?
Following the Lead Safe Housing Rule requirements in federally funded housing
activities reduces risk of lead poisoning and hazards. The Lead Safe Housing Rule is
designed to reduce hazards relating to lead-based paint in housing, which include
irreversible health effects, brain and nervous system damage, reduced intelligence, and
learning disabilities. Children, pregnant women, and workers are most at risk of
experiencing negative health effects resulting from exposure to lead-based paint
hazards. More than 20 million homes in the United States built before 1978 contain
lead-based paint hazards. For these reasons, it is vital that Oakland County reduce
lead-based paint hazards in all federally funded housing activities, as over half (55%) of
its housing stock was built prior to 1980. Additionally, county-level data from Michigan
Department of Health and Human Services (MDHHS) indicates that in 2024, 2.7% of
children under 6 years old in Oakland County reported elevated blood lead levels.
How are the actions listed above integrated into housing policies and
procedures?
Oakland County has integrated Lead Safe Housing Rule requirements into housing
policies and procedures by following HUD’s Lead Safe Housing Rule requirements in all
of the County’s federally funded affordable housing development activities.
175
SP-70 ANTI-POVERTY STRATEGY – 91.215(J)
Jurisdiction Goals, Programs and Policies for reducing the number of
Poverty-Level Families
An estimated 7.7% of Oakland County residents were living below the poverty level in
the past 12 months, according to American Community Survey 5-Year Estimates for
2019-2023. The county’s poverty rate is below the statewide poverty rate of 13.1% The
county has a multifaceted approach to reducing the number of households living in
poverty, including workforce development initiatives, strategies to increase access to
affordable housing, and social services. The county’s workforce development initiatives
are detailed in the MA-45 section of this plan, and its strategies to remove barriers to
housing are outlined in section SP-55.
Supportive services such as homeless prevention/assistance, emergency rental/utility
assistance, food assistance, education, and health resources are offered by a variety of
area nonprofits and organizations, including Oakland Livingston Human Service Agency
(OLHSA), Community Housing Network (CHN), Lighthouse, and HOPE Shelters,
among others. These organizations are guided by the goal of reducing the number of
Oakland County households living in poverty through direct assistance via financial aid,
food pantries, clothing distribution,
How are the Jurisdiction poverty reducing goals, programs, and
policies coordinated with this affordable housing plan
The housing affordability, workforce development, and homelessness programs detailed
in this plan aim to support the achievement of housing and economic development
goals for the county and region. The County will continue to fund public services,
facilities, and infrastructure that address the region’s most pressing homelessness,
economic development, and workforce needs.
Many of the anti-poverty programs listed above are managed by organizations that
participated in the development of this plan through focus groups, community meetings,
and stakeholder interviews. Maintaining strong partnerships with these stakeholders
through the duration of this plan will help the County more effectively coordinate
programs and policies in a way that meets these anti-poverty goals.
176
SP-80 MONITORING – 91.230
Describe the standards and procedures that the jurisdiction will use
to monitor activities carried out in furtherance of the plan and will use
to ensure long-term compliance with requirements of the programs
involved, including minority business outreach and the
comprehensive planning requirements
As described in 2 CFR 200.331 and 24 CFR 85.40, Oakland County is responsible for
monitoring its participating communities/agencies to ensure compliance with all
applicable Federal requirements. This includes individual project goals and
requirements for the CDBG, HOME and ESG programs. The NHD monitoring approach
is an ongoing process involving continuous communication and evaluation with the end
goal of improving or reinforcing program participant performance.
NHD uses several informal and formal techniques to review community/agency program
effectiveness, management efficiency, compliance and spending performance.
Monitoring tools include frequent telephone/email contacts, written communications,
interviews, periodic meetings, analysis of project documents, reports and audits, desk
evaluations, risk assessments, on-site monitoring and spending performance tracking
implemented in the HUD IDIS PR 59 - CDBG Activities at Risk Dashboard. Staff
routinely tracks and evaluates ongoing capacity of communities/agencies to meet
CDBG, HOME and ESG financial, production and overall management requirements
and provides technical assistance to improve performance.
Monitoring Schedule - Oakland County determines its monitoring schedule based
upon HUD requirements. The Division uses a Risk Analysis to determine which CDBG
participating communities/agencies receive an onsite monitoring visit. Oakland County
monitors all HOME and ESG recipients through onsite monitoring visits each year or at
least once during a given contract period. As situations dictate, the Division provides
additional onsite monitoring and/or technical assistance. Regardless of the frequency,
the purpose and intent of any site visit or technical assistance initiative is to identify
potential areas of risk or non-compliance and assist the community/agency in making
necessary programmatic changes. By identifying and correcting compliance issues, the
likelihood of efficient and effective service delivery to beneficiaries’ increases and
ensures continued program success.
Individual Monitoring Strategy – NHD devises an individual monitoring strategy for
each community/agency to define the scope and focus of monitoring efforts conducted
remotely or onsite. NHD operates a reimbursement financial system that requires
communities to provide supporting documentation for approval prior to payment. This
177
policy maximizes community/agency compliance with Federal regulations on an
ongoing basis. The Division reviews several areas during monitoring visits including:
• Minority and Women-Owned Business Compliance
• Section 504/Handicap Accessibility Requirements
• Comprehensive planning requirements
A copy of the Division Monitoring Policy is on file at the Division Office.
178
2026-2030
2026 Annual Action Plan
179
AP-15 EXPECTED RESOURCES – 91.220(C)(1,2)
Introduction
Oakland County is eligible to receive funding from three CPD formula grants (CDBG, HOME, and ESG). Combined, the
County will receive an anticipated $5,973,305.90 in HUD grant funds for the 2026 program year. The table below outlines
anticipated funding levels by program.
Anticipated Resources
TABLE 58 - EXPECTED RESOURCES – PRIORITY TABLE
Pr
o
g
r
a
m
Fu
n
d
s
Expected Amount Available Year 1 Expected
Amount
Available
Remainder
of ConPlan
Narrative
Description Annual
Allocation
Program
Income
Prior Year
Resources Total
CDBG
public
-
federal
Acquisition
Admin and
Planning
Economic
Development
Housing
Public
Improvements
Public Services
$3,767,803.00 $1,481,204.14 $0.00 $5,249,007.14 $19,471,212.00
neighborhood
and housing
improvements,
multi-family
rehab, and
public
services
benefiting low-
income
persons
throughout
Oakland
County Urban
County
participating
180
HOME
public
-
federal
Acquisition
Homebuyer
assistance
Homeowner
rehab
Multifamily
rental new
construction
Multifamily
rental rehab
New
construction for
ownership
Tenant Based
Rental
Assistance
(TBRA)
$1,877,222.90 $1,600,000.00 $0.00 $3,477,222.90 $13,908,891.60
rehabilitation,
new
construction of
affordable
housing
including
rental
development
and
homebuyer
assistance
throughout
Oakland
County
HOME
Consortium
participating
ESG
public
-
federal
and
rehab for
transitional
housing
Financial
Assistance
Overnight
shelter
Rapid
rehousing
(rental
assistance)
Rental
Assistance
Services
Transitional
$328,280.00 $0.00 $0.00 $328,280.00 $1,313,120.00
Emergency
Shelter,
Homeless
Prevention and
Rapid Re-
Housing, HMIS
and
Administration
throughout
Oakland
County Urban
County
participating
communities.
181
Explain how federal funds will leverage those additional resources
(private, state and local funds), including a description of how
matching requirements will be satisfied
CDBG - No Match Requirement
• In-kind County level administrative functions: human resources, marketing, fiscal
services, purchasing, auditing, corporation counsel, record retention and mail
room support services
• Infrastructure and public facility projects supported with funds from participating
• Revolving Loan Fund (RLF) generated from paybacks on CDBG funded housing
rehabilitation loans supplement the HIP. During PY 2026 the County will recycle
approximately $1,100,00 in CDBG RLF into the HIP for the rehabilitation of
approximately 50 single-family homes of LI residents
• Program Income (PI) Estimate generated from Neighborhood Stabilization
paybacks. During PY 2026 the County will recycle approximately $381,204.14 in
CDBG PI into the eligible activities.
• Emergency, youth, senior and other public services designed to meet special
needs of LI residents are expanded through leverage from various public service
agencies.
HOME - 25% Match Requirement
• Oakland County ensures that all housing projects receive $1 of non-federal match
for every $4 of HOME funds expended, in accordance with federal guideline
(s.92.218)
• The HOME program requires a 25% match on all non-administrative activities. In
PY 2026, $469,306 in general funds will serve as match for County level housing
rehabilitation, rental development/preservation and homebuyer assistance
activities
• CHDO’s leverage HOME funds with state and private resources to develop
affordable housing
• PI generated from paybacks on HOME funded housing rehabilitation loans
supplement the HIP
ESG - 100% Match Requirement
• Oakland County passes on the match requirements to its vendors
• Cash contributions for allowable costs including staff salaries/fringe benefits
182
• Noncash contributions
• Volunteer services are matched at the current minimum wage salary unless the
recipient can verify a higher rate of pay for current employees performing similar
work
• Real property, equipment, goods or services that if the recipient had to pay for
them with grant funds, the payments would have been indirect costs
• The value of donated goods and services such as clothing, food, diapers, haircuts,
etc. - value placed should be consistent with Office of Management and Budget
Circulars
If appropriate, describe publicly owned land or property located
within the jurisdiction that may be used to address the needs
identified in the plan
Designated CHDOs may access publicly owned land or property for redevelopment as
affordable housing through public or private entities. The County created the Oakland
Together Housing Trust Fund (HTF) and a Land Bank Authority to invest in publicly
owned and/or tax-foreclosed land. The HTF was initially funded with $18M of American
Rescue Plan Act (ARPA) funding as well as an ongoing $2M annual appropriation of
County resources. The HTF and NHD partners with affordable housing developers, non-
profits, CHDOs, local municipalities to develop a wide range of housing including shelter
space, permanent supportive housing, PBV/HCV supported housing, senior affordable
housing, family affordable housing, workforce housing, adaptive reuse housing, and
other types of housing. The housing investments of NHD and the HTF leverage federal
and County funds with other financial sources such as LIHTC, State funding, local
funding, property tax exemptions, brownfield tax increment financing, private loans,
private equity, and other available resources.
Since 2023, over 1,550 units of mixed income housing have been created or preserved
using NHD and HTF funding. These units are at various stages of development from
completed, under construction, or awaiting financial close in the near term. NHD and the
HTF’s total investment of $37.1M includes $18M in ARPA funding, $5.6M in County
general funds, and $13.5M in HOME/CDBG funding resulting in a leveraged investment
of over $404M into affordable and workforce housing throughout the County.
Discussion
Oakland County recognizes that Congress is considering updates to the CDBG program
that could expand the eligible use of funds for housing development, including potential
authority for communities to dedicate a portion of their CDBG allocation to new housing
construction. While these changes remain speculative and subject to congressional
negotiation, the County acknowledges the possibility that future statutory or regulatory
183
revisions may shift CDBG toward a stronger housing‑production focus. Should such
changes be enacted, the County will adapt its CDBG program accordingly to ensure a
maximum commitment of funds to address the housing affordability needs of low‑ and
moderate‑income residents.
184
2026-2030
Annual Goals and
Objectives
185
AP-20 ANNUAL GOALS AND OBJECTIVES
Goals Summary Information
TABLE 59 - GOALS SUMMARY
Sort
Order Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
1
Increase and
Improve
Affordable
Housing
Options
2026 2027
Housing
Affordability
and
Condition
Countywide Housing
Affordability
and Condition
CDBG:
$ 2,241,636.95
HOME:
$2,876,075.52
Rental units
constructed:
114 housing units
Rental units
rehabilitated:
116 housing units
Homeowner housing
rehabilitated:
140 housing units
Direct financial
assistance to
homebuyers:
10 households assisted
Homeowner housing
added:
7 housing units
2
Increase and
Improve
Homeless
Shelter,
Service, and
Prevention
Efforts
2026 2027 Homeless Countywide Homeless
Needs ESG: $328,280
Homeless person
overnight shelter:
500 persons assisted
Homelessness
prevention:
100 persons assisted
186
Sort
Order Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
3
Create and
sustain a
suitable living
environment
through
infrastructure
and public
facility
improvements
2026 2027
Non-Housing
Community
Development
Countywide
Infrastructure
and Public
Facility
Improvements
CDBG: $922,435
Public facility or
infrastructure activities
other than
low/moderate-income
housing benefit:
30,000 persons
assisted
Public facility or
infrastructure activities
for low/moderate-
income housing benefit:
2,000 households
assisted
Housing code
enforcement/Foreclosed
property care:
5,000 housing units
Buildings demolished:
5 buildings
187
Sort
Order Goal Name Start
Year
End
Year Category Geographic
Area
Needs
Addressed Funding Goal Outcome
Indicator
4
Provide public
services to
expand
economic
opportunity,
improve
safety,
enhance food
access, and
provide other
assistance for
low- and
moderate-
income
households,
seniors,
people with
disabilities,
and other
eligible groups
2026 2027
Non-
Homeless
Special
Needs
Non-Housing
Community
Development
Countywide Public
Services
CDBG:
$729,670.45
Public service activities
other than
low/moderate-income
housing benefit:
700 persons assisted
Public service activities
for low/moderate-
income housing benefit:
50 households assisted
5
Administration
of funding and
projects
2026 2027
Non-
Homeless
Special
Needs
Non-Housing
Community
Development
Affordable
Housing
Homeless
Countywide Program
Administration
CDBG:
$973,560.60
HOME:
$347,722.29
N/A
188
Goal Descriptions
Goal Name Goal Description
Increase and Improve
Affordable Housing Options
Activities furthering access to and availability of affordable housing options
including but not limited to: new housing production, multifamily rental
acquisition and rehabilitation efforts; homeowner rehabilitation efforts;
tenant-based rental assistance, increased marketing of available services
and funding throughout the County, especially in northern and rural areas;
aging in place initiatives; home ownership assistance and education;
increased availability of programs and materials in non-English languages,
especially Spanish; code enforcement efforts; and other relevant initiatives.
Increase and Improve
Homeless Shelter, Service, and
Prevention Efforts
Activities furthering access to and availability of homeless shelter, service,
and prevention efforts, including but not limited to: additional overnight and
warming center beds; eviction prevention; expanded street outreach efforts;
initiatives to narrow the digital divide among the homeless population,
including expansion of the existing informational kiosk program; increased
shelter and service options for survivors of domestic violence; increased
shelter and service options in northern and/or rural areas of the County;
and other relevant initiatives.
Create and sustain a suitable
living environment through
infrastructure and public facility
improvements
Activities furthering creating and sustaining a suitable living environment
through infrastructure and public facility improvements, including but not
limited to: park, playground, community center, and other recreation facility
expansion, repair, and maintenance; street, sidewalk, street light, and drain
expansion, repair, and maintenance; ADA accessibility improvements;
infrastructure improvements in rural areas of the County; and other relevant
initiatives.
Provide public services to
expand economic opportunity,
improve safety, enhance food
access, and provide other
assistance for low- and
moderate-income households,
seniors, people with disabilities,
and other eligible groups
Activities furthering public service availability and access, including but not
limited to: increased service availability in northern and rural parts of the
County; increased access to free or affordable transit services; increased
access to free or affordable childcare services; increased access to
programs and services available in Spanish; increased housing-related
services including housing counseling, homebuyer education, and financial
literacy; formation and/or advertisement of a centralized phone-based
resource hub for residents who do not have access or the ability to use a
computer; and other relevant initiatives.
Administration of funding and
projects
Program administration costs associated with the coordination and delivery
of services to Oakland County residents, including but not limited to staff
salary, planning, and administrative service delivery costs for implementing
the Community Development Block Grant (CDBG), HOME Investment
Partnerships (HOME) and Emergency Solutions Grant (ESG) programs.
189
PROJECTS: AP-35 PROJECTS – 91.220(D)
Introduction
Listed below are the projects which Oakland County intends to implement and fund in
FY 2026.
Projects
TABLE 60 – PROJECT INFORMATION
# Project Name
1 CDBG Administration
2 CDBG Housing Rehabilitation/Revolving Loan Fund Estimate
3 CDBG Housing/HIP Direct Project Costs
4 CDBG Public Services Housing Counseling
5 CDBG PS/Battered & Abused
6 CDBG Mobile Home Minor Home Repair
7 CDBG Code Enforcement
8 CDBG Minor Home Repair
9 CDBG Public Facilities and Infrastructure
10 CDBG Homebuyer Assistance (13B)
11 CDBG Homebuyer Assistance (05R)
12 CDBG Shelter/Homeless Operations
13 CDBG Homeless Facilities
14 CDBG Public Services (Minus Battered & Abused)
15 HOME Administration/Program Income Estimate
16 HOME Housing Rehabilitation
190
Describe the reasons for allocation priorities and any obstacles to
addressing underserved needs
Quantitative research (housing market and demographic analysis) and qualitative
research (surveys, public meetings, focus groups, and resident input) impacted the
priority needs and strategies for the Oakland County PY 2026-2030 Consolidated Plan.
Oakland County does not allocate investments geographically and does not plan to
identify any specific Neighborhood Revitalization Strategy Areas (NRSA). Activities
selected will be eligible for funding based on their ability to meet Oakland County goals,
which currently prioritize housing and other similarly transformative projects.
The primary obstacle to addressing underserved needs is the lack of adequate financial
resources. Oakland County will continue to pursue funding from a variety of sources in
order to overcome this barrier
# Project Name
17 HOME CHDO Rental
18 HOME CHDO Operating Expenses
19 HOME CHDO Homebuyer
20 HOME Rental
21 ESG Administration and ESG Homelessness
191
AP-38 PROJECT SUMMARY
Project Summary Information
1 Project Name CDBG Administration
Target Area Oakland County
Goals Supported Administration and Funding of Projects
Needs Addressed Administration and Funding of Projects
Funding $973,560.60
Description Administration of the CDBG program including management,
public information and fair housing activities.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
N/A
Location Description Oakland County Neighborhood & Housing Development Division
1200 N. Telegraph Rd. Bldg. 34E, Pontiac, MI 48341
Planned Activities General program administration.
192
2 Project Name CDBG Housing Rehabilitation/Revolving Loan Fund Estimate
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $883,500.00
Description Contract work and estimated loan payments of the County's
Home Improvement Program which is available to income-
qualified homeowners in participating communities.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
80
Location Description Specific and variable
Planned Activities Contract work and estimated loan payments of the County's
Home Improvement Program which is available to income-
qualified homeowners in participating communities.
193
3 Project Name CDBG Housing/HIP Direct Project Costs
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $684,701.47
Description Direct project costs of contract work of the County's Home
Improvement Program which is available to income qualified
homeowners of single-family owner-occupied units and owner
occupants of attached single family rental (2-4 units) in
participating communities.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
80
Location Description Specific and variable
Planned Activities Housing rehabilitation – direct project costs.
194
4 Project Name CDBG Public Services – Housing Counseling
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for
low- and moderate-income households, seniors, people with
disabilities, and other eligible groups.
Needs Addressed Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for
low- and moderate-income households, seniors, people with
disabilities, and other eligible groups.
Funding $319,546.00
Description Comprehensive housing counseling services to help address
housing matters including foreclosure, homebuyer and tenant
issues.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
Oakland County Neighborhood & Housing Development Division
1200 N. Telegraph Rd. Bldg. 34E, Pontiac, MI 48341
Location Description Specific and variable
195
Planned Activities Housing counseling services.
5 Project Name CDBG Public Services – Battered & Abused
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for
low- and moderate-income households, seniors, people with
disabilities, and other eligible groups.
Needs Addressed Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for
low- and moderate-income households, seniors, people with
disabilities, and other eligible groups.
Funding $70,134.45
Description Services for victims of domestic violence, dating violence, sexual
assault or stalking as part of a County executed and administered
contract with HAVEN.
Target Date 06/30/2027
196
Estimate the number and type of families
that will benefit from the proposed
activities
330
Location Description HAVEN
801 Vanguard Drive, Pontiac, MI 48341
Planned Activities Housing counseling services.
6 Project Name CDBG Mobile Home Minor Home Repair
Target Area Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $161,730.00
Description Minor home repair for the mobile homes of income qualified
households as part of a County executed and administered
contract with a third-party non-profit. Repairs will conform to
Oakland County guidelines and State of Michigan Lead Based
Paint requirements.
Target Date 06/30/2027
197
Estimate the number and type of families
that will benefit from the proposed
activities
11 low-mod families
Location Description Specific and variable
Planned Activities Minor repair to mobile homes.
7 Project Name CDBG Code Enforcement
Target Area Oakland County
Goals Supported Create and sustain a suitable living environment through
infrastructure and public facility improvements
Needs Addressed Create and sustain a suitable living environment through
infrastructure and public facility improvements
Funding $285,851.00
Description Code enforcement activities.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
5,000 housing units inspected
198
Location Description Area wide
Planned Activities Code enforcement activities.
8 Project Name CDBG Minor Home Repair
Target Area Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $511,705.48
Description Minor home repairs for the homes of income qualified
households. Repairs will confirm to Oakland County guidelines
and State of Michigan Lead Based Paint guidelines.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
80 households
Location Description Specific and variable
Planned Activities Minor home repair.
199
9 Project Name CDBG Public Facilities and Infrastructure
Target Area Oakland County
Goals Supported Create and sustain a suitable living environment through
infrastructure and public facility improvements
Needs Addressed Create and sustain a suitable living environment through
infrastructure and public facility improvements
Funding $567,352.00
Description Public facility and infrastructure improvements.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
30,000 low-mod people assisted
Location Description Specific and variable
Planned Activities Including but not limited to: parks & recreation facilities, remove
architectural barriers, senior centers, sidewalks.
10 Project Name CDBG Homebuyer Assistance (13B)
200
Target Area Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $190,602.07
Description Providing assistance to eligible low- and moderate-income
homebuyers to include subsidizing interest rates and mortgage
principal; financing purchase of homes occupied by buyers;
securing guarantees for private mortgage financing; providing up
to half of required downpayment; and/or covering reasonable
homebuyer closing costs.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
18 low-mod households
Location Description Specific and variable
Planned Activities Homebuyer assistance.
11 Project Name CDBG Homebuyer Assistance (05R)
Target Area Oakland County
201
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $190,602.07
Description Providing assistance to eligible low- and moderate-income
homebuyers to include subsidizing interest rates and mortgage
principal; financing purchase of homes occupied by buyers;
securing guarantees for private mortgage financing; providing up
to half of required downpayment; and/or covering reasonable
homebuyer closing costs.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
18 low-mod households
Location Description Specific and variable
Planned Activities Homebuyer assistance.
12 Project Name CDBG Shelter/Homeless Operations
Target Area Oakland County
Goals Supported
202
Needs Addressed
Funding $500.00
Description
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
Location Description
Planned Activities
13 Project Name CDBG Homeless Facilities
Target Area Oakland County
Goals Supported
Needs Addressed
Funding $500.00
Description
203
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
Location Description
Planned Activities
14 Project Name CDBG Public Services (Minus Battered & Abused)
Target Area Oakland County
Goals Supported Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for
low- and moderate-income households, seniors, people with
disabilities, and other eligible groups.
Needs Addressed Provide public services to expand economic opportunity, improve
safety, enhance food access, and provide other assistance for
low- and moderate-income households, seniors, people with
disabilities, and other eligible groups.
Funding $340,490.00
Description Various public service programs.
204
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
700 people assisted
Location Description Specific and variable
Planned Activities Including but not limited to: Child Care Services, Disabled
Services, Emergency Services, Housekeeping Services, Senior
Services, Services for Victims of Domestic Violence, Dating
Violence, Sexual Assault, or Stalking, Transportation Services,
Yard Services, Youth Services, Homebuyer Down Payment
Assistance.
15 Project Name HOME Administration
Target Area Oakland County HOME Consortium
Goals Supported Administration and Funding of Projects
Needs Addressed Administration and Funding of Projects
Funding $347,722.29
Description Administration of the HOME program including management,
public information and fair housing activities.
205
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
N/A
Location Description Oakland County Neighborhood & Housing Development Division
1200 N. Telegraph Rd. Bldg. 34E, Pontiac, MI 48341
Planned Activities General program administration.
16 Project Name HOME Housing Rehabilitation
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $1,876,075.52
Description Direct project costs of contract work of the County's Home
Improvement Program which is available to income qualified
homeowners in participating communities.
Target Date 06/30/2027
206
Estimate the number and type of families
that will benefit from the proposed
activities
80 households assisted
Location Description Specific and variable
Planned Activities Housing rehabilitation.
17 Project Name HOME CHDO Rental
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $84,475.03
Description Contracts with qualified CHDOs to construct or rehabilitate
affordable single family (1-4 units) and multifamily rental housing
in HOME Consortium Communities. This investment targets
renters at or below 60% of area median income.
Target Date 06/30/2027
207
Estimate the number and type of families
that will benefit from the proposed
activities
4 low-income families.
Location Description Specific and variable
Planned Activities Rehab or development of CHDO rental units.
18 Project Name HOME CHDO Operating Expenses
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $84,475.03
Description Fund the operating expenses of Community Housing
Development Organizations (CHDOs) when carrying out Oakland
County HOME funded projects.
Target Date 06/30/2027
208
Estimate the number and type of families
that will benefit from the proposed
activities
N/A
Location Description Specific and variable
Planned Activities CHDO operating expenses.
19 Project Name HOME CHDO Homebuyer
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $84,475.03
Description Contracts with qualified Community Housing Development
Organizations (CHDOs) to develop affordable housing for income
qualified homebuyers through acquisition, rehab or new
construction.
Target Date 06/30/2027
209
Estimate the number and type of families
that will benefit from the proposed
activities
2 low-mod families.
Location Description Specific and variable
Planned Activities Housing rehabilitation, acquisition, and/or new construction.
20 Project Name HOME Rental
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase and Improve Affordable Housing Options
Needs Addressed Increase and Improve Affordable Housing Options
Funding $1,000,000.00
Description Acquisition, rehabilitation, or new construction of housing for
affordable rental stock.
Target Date 06/30/2027
Estimate the number and type of families
that will benefit from the proposed
activities
11 low-mod families or seniors.
210
Location Description Specific and variable
Planned Activities Acquisition, rehabilitation, or new construction of housing for
affordable rental stock.
21 Project Name ESG Administration and ESG Homelessness
Target Area Oakland County HOME Consortium
Oakland County
Goals Supported Increase Homeless Shelter, Service, and Prevention Efforts
Needs Addressed Increase Homeless Shelter, Service, and Prevention Efforts
Funding $328,280.00
Description County's cost of administering the Oakland County ESG program.
Fund qualified agency to perform data collection/evaluation
through HMIS. The agency will provide reports/training/technical
assistance to ESG participating agencies and the County. Funds
will be provided to a qualified agency to provide rental assistance
and housing relocation and stabilization services for eligible
homeless and/or at risk of homelessness clients. Fund qualified
shelters for eligible essential service for homeless clients, shelter
operations and organizational support.
Target Date 06/30/2027
211
Estimate the number and type of families
that will benefit from the proposed
activities
Homeless person overnight shelter: 500 persons assisted
Homelessness prevention: 100 persons assisted
Location Description Specific and variable
Planned Activities General program administration = $24,027.90
Data collection/evaluation through HMIS = $24,027.90
Rental Assistance and housing relocation/stabilization services =
$101,664.00
Essential services, shelter operations and organizational support
= $170,652.20
212
AP-50 GEOGRAPHIC DISTRIBUTION – 91.220(F)
Description of the geographic areas of the entitlement (including
areas of low-income and minority concentration) where assistance
will be directed
Oakland County does not allocate investments geographically and does not plan to
identify any specific Neighborhood Revitalization Strategy Areas (NRSA). Activities
selected will be eligible for funding based on their ability to meet Oakland County goals,
which currently prioritize housing and other similarly transformative projects.
The following 52 (85%) of Oakland County communities participate in the County's
"Urban County" CDBG housing and community development programs: Cities - Auburn
Hills, Berkley, Birmingham, Bloomfield Hills, Clarkston, Clawson, Farmington, Ferndale,
Hazel Park, Huntington Woods, Keego Harbor, Lathrup Village, Madison Heights,
Northville, Novi, Oak Park, Orchard Lake Village, Pleasant Ridge, Rochester, Rochester
Hills, South Lyon, Sylvan Lake, Troy, Walled Lake, Wixom Townships - Addison,
Bloomfield, Brandon, Commerce, Groveland, Highland, Holly, Independence, Lyon,
Milford, Oakland, Orion, Oxford, Rose, Royal Oak, Springfield, West Bloomfield, White
Lake Villages - Beverly Hills, Franklin, Holly, Lake Orion, Leonard, Milford, Ortonville,
Oxford and Wolverine Lake. Farmington Hills, Royal Oak, Southfield, Pontiac, and
Waterford Township are HUD entitlement communities. These communities with over
50,000 residents are "entitled" to receive HUD funds and have chosen to administer
their own CDBG programs. The City of Lake Angelus, Novi Township, Southfield
Township and the Village of Bingham Farms do not receive HUD funds.
Oakland County’s Recapture and Reallocation Policy allows the County to take back
CDBG funds from participating communities if they remain unobligated for two years,
ensuring compliance with federal timeliness rules. The County then redistributes these
recaptured dollars to communities or projects that can spend them quickly and
effectively, helping maintain HUD’s required expenditure pace and directing resources
to activities that benefit low‑ and moderate‑income residents.
Oakland County HOME Consortium - Oakland County serves as the lead entity for
the Oakland County HOME Consortium (OCHC), which is comprised of the Urban
County of Oakland, Farmington Hills, Royal Oak, and Southfield. The HOME program
funds HIP, Rental Development/Preservation gap financing and CHDO activities
throughout Consortium communities.
213
Geographic Distribution
TABLE 61 - GEOGRAPHIC DISTRIBUTION
Target Area Percentage of Funds
Oakland County HOME
Consortium 33%
Oakland County 67%
Rationale for the priorities for allocating investments geographically
Oakland County does not allocate investments geographically and does not plan to
identify any specific Neighborhood Revitalization Strategy Areas (NRSA). Activities
selected will be eligible for funding based on their ability to meet national program
objectives and Consolidated Plan goals.
214
2026-2030
215
AP-55 AFFORDABLE HOUSING – 91.220(G)
Introduction
Considering only HOME program funds and programs, The County anticipates assisting
61 homeowners with home repairs, and producing 8 new units of affordable housing.
TABLE 62 - ONE YEAR GOALS FOR AFFORDABLE HOUSING BY SUPPORT REQUIREMENT
One Year Goals for the Number of Households to be Supported
Homeless 0
Non-Homeless 69
Special-Needs 0
Total 69
TABLE 63 - ONE YEAR GOALS FOR AFFORDABLE HOUSING BY SUPPORT TYPE
One Year Goals for the Number of Households Supported Through
Rental Assistance 0
The Production of New Units 8
Rehab of Existing Units 61
Acquisition of Existing Units 0
Total 69
216
AP-60 PUBLIC HOUSING – 91.220(H)
Introduction
Public housing within the Oakland County consortium is provided through a large
number of Housing Authorities under the jurisdictions of its various member
communities. Oakland County itself does not administer a PHA but rather collaborates
with and supports its various member PHAs. Planned activities relating to this are
detailed below.
Actions planned during the next year to address the needs to public
housing
The County has regular meetings with the Pontiac Housing Commission on the needs
for public housing and partnership opportunities to bring housing to families.
Through the County’s HOME, CDBG, and Housing Trust Fund rental development and
rehabilitation programs, the County has supported the creation or preservation of 981
project-based voucher units. Additional units may be supported by the Housing Choice
Voucher program at the various properties in which the County has invested federal and
local funds.
Actions to encourage public housing residents to become more
involved in management and participate in homeownership
Oakland County housing counselors will meet with public housing residents and/or
housing choice voucher holders to explore the potential for future homeownership
including converting a rental voucher to a homeownership voucher. The housing
counseling unit provides referrals to each local PHC. The status of each PHC waiting
list is provided to the Neighborhood & Housing Development Division through its
Alliance membership.
NHD is currently working with an Oakland County CHDO to convert 7 rental units from
the LIHTC program to homeownership using CDBG funds. 6 of the 7 rental units have
closed with first time homebuyers. The final unit is expected to sell in 2026. NHD and
the HTF have invested funds into additional rental conversion properties; however, the
units will not be available in the near term due to LIHTC compliance regulations.
If the PHA is designated as troubled, describe the manner in which
financial assistance will be provided or other assistance
N/A
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AP-65 HOMELESS AND OTHER SPECIAL NEEDS ACTIVITIES –
91.220(I)
Introduction
Oakland County works closely with the Alliance for Housing, which serves as the
jurisdiction’s Continuum of Care and lead agency organizing service providers in the
area. The Continuum of Care secures and distributes funding for direct service
providers in the housing and homeless community and provides guidance to strengthen
policies and programs. Homeless needs activities were identified as an urgent need
during the community engagement and data analysis processes. Planned activities
relating to this are detailed below.
The Blueprint to End Homelessness was developed in 2021 and is comprised of more
than 60 stakeholders, including Oakland County Neighborhood and Housing
Development, Community Corrections, the Alliance for Housing, Oakland University
William Beaumont School of Medicine, HOPE, Community Housing Network,
Lighthouse, Haven, Samaritas, Street Democracy, the City of Ferndale, Centro
Multicultural de la Familia, and many others. As the lead nonprofit agency dedicated to
ending homelessness and coordinating housing and funding to support Oakland County
residents experiencing homelessness, the Alliance for Housing serves as the local
Continuum of Care (CoC).
These stakeholders meet regularly to implement action items that address all facets of
homelessness. Meetings are chaired jointly by NHD leadership and the Alliance for
Housing. In 2026, an updated Blueprint to End Homelessness will be finalized, reflecting
progress made to date and outlining next steps for continued system improvement..
This Blueprint also serves as a roadmap for strategic planning and actions towards
reducing and ending homelessness.
Describe the jurisdictions one-year goals and actions for reducing
and ending homelessness including:
Reaching out to homeless persons (especially unsheltered persons)
and assessing their individual needs
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Oakland County through is HOME/CDBG funding and Housing Trust Fund have closed
1,395 units of affordable housing in the near-term pipeline that will provide safe, decent,
and affordable housing to prevent residents from becoming homeless. This pipeline will
also serve as permanent housing for residents of existing emergency shelters and
transitional housing. NHD has additional units currently in the pipeline to support these
efforts.
Oakland County also plans to fund and support additional shelter capacity throughout
the County using both federal grant funding and other County resources.
Addressing the emergency shelter and transitional housing needs of
homeless persons
Oakland County has funded 21 units resulting in 98 total beds of non-congregant
housing using HOME-ARP and ARPA funding that is anticipated to be operational by
the end Program Year 2027. Oakland County also seeks to acquire and/or build
transitional housing for youth aging out of foster care, young mothers and families,
veterans, and other residents.
Helping homeless persons (especially chronically homeless
individuals and families, families with children, veterans and their
families, and unaccompanied youth) make the transition to permanent
housing and independent living, including shortening the period of
time that individuals and families experience homelessness,
facilitating access for homeless individuals and families to affordable
housing units, and preventing individuals and families who were
recently homeless from becoming homeless again
Oakland County, in partnership with the Alliance for Housing (the local Continuum of
Care), implements a coordinated system of ESG funded services, housing counseling,
and supportive programs designed to help individuals and families experiencing
homelessness especially chronically homeless households, families with children,
veterans, and unaccompanied youth transition to permanent housing as quickly as
possible and maintain long term stability.
Through ESG funded rapid re housing and prevention, housing counseling, wrap
around services, HMIS driven system planning, and the strategic framework of the
Blueprint to End Homelessness, Oakland County is committed to helping individuals
and families transition quickly into permanent housing, maintain long term stability, and
prevent future homelessness. The County’s investments in new affordable housing and
its strong partnerships across more than 60 agencies ensure a comprehensive and
effective response to homelessness.
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Oakland County uses ESG funds to support a Homeless Prevention and Rapid Re
Housing (HPRRH) program administered by Lighthouse and Community Housing
Network. These agencies provide rental assistance, rental fees, utility assistance,
housing search support, and case management to households who are homeless or at
imminent risk of homelessness. Lighthouse offers a twelve month follow up program
that includes in home case management, with 90% of participants maintaining housing
after one year. These interventions significantly shorten the length of time households
experience homelessness and support long term housing stability.
Providing Housing Counseling is a key component of the County’s strategy to support
successful transitions into permanent housing. Counseling services include budgeting,
tenant education, landlord mediation, and assistance navigating affordable housing
opportunities. By now using outreach methods such as Wellness Wednesdays and
Friendship Fridays we can increase access to HUD Certified Housing Counseling
through wraparound services and supporting housing readiness
Since the inception of Wellness Wednesdays, Oakland County has provided 2,332
individuals with wrap around services that reduce barriers to housing and support
independent living. These include:
• 228 with Housing Counseling Services
• 596 guests accessing shower services
• 538 loads of laundry completed
• 141 individuals receiving medical support
• 173 individuals connected to resources through Oakland Connects
• 69 individuals assisted by Community Housing Network
• 40 individuals supported by Lighthouse
These services improve health, stability, and readiness for permanent housing.
Shortening the Length of Homelessness. The Continuum of Care tracks and analyzes
the length of time individuals and families experience homelessness using HMIS.
Current data shows:
• Families are typically homeless 1–3 months before entering a program
• Individuals entering shelter are typically homeless one week or less
• Individuals entering transitional or permanent housing programs are typically
homeless 1–3 months
Length of stay data is reviewed regularly by the Systems Implementation and
Coordination Committee, which develops strategies to reduce time spent being
homeless and improve system operations.
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The Continuum of Care actively tracks returns to homelessness through HMIS and
produces quarterly reports on exits from rapid re housing, transitional housing, and
permanent supportive housing. These reports are reviewed by the CoC Board and the
Project Monitoring and Performance Outcomes Committee to identify trends, strengthen
program practices, and improve follow up care. Program specific technical assistance
includes an examination of exit procedures as well as follow-up care procedures and
accessibility.
Oakland County continues to expand the supply of affordable and supportive housing to
ensure that individuals exiting homelessness have access to long term housing options.
Recent and upcoming developments include:
• Shepherd House, a 53-unit permanent supportive housing community in
Ferndale
• 166 additional affordable housing units under construction in Pontiac and
Southfield, expected to be completed in PY 2026 or shortly thereafter
These units increase the availability of permanent housing for individuals and families
transitioning from homelessness.
The Blueprint to End Homelessness guides the County’s long-term strategy to reduce
homelessness and improve system performance. The Blueprint establishes goals
focused on preventing homelessness before it occurs, strengthening coordinated
outreach, improving access to shelter and crisis response, expanding pathways to
permanent housing, and increasing stabilization supports to ensure long term housing
retention. Stakeholders meet regularly to implement action items aligned with these
goals, addressing prevention, outreach, shelter, housing, and stabilization across the
entire homelessness response system. An updated Blueprint will be finalized in 2026,
reflecting progress made to date and outlining new strategies to strengthen the
homelessness response system.
Helping low-income individuals and families avoid becoming
homeless, especially extremely low-income individuals and families
and those who are: being discharged from publicly funded
institutions and systems of care (such as health care facilities, mental
health facilities, foster care and other youth facilities, and corrections
programs and institutions); or, receiving assistance from public or
private agencies that address housing, health, social services,
employment, education, or youth needs
Oakland County also seeks to acquire and/or build transitional housing for youth aging
out of foster care, young mothers and families, veterans, and other residents. Oakland
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County through is HOME/CDBG funding and Housing Trust Fund also have 1,395 units
of affordable housing in the near-term pipeline that will provide safe, decent, and
affordable housing to prevent residents from becoming homeless. This pipeline will also
serve as permanent housing for residents existing emergency shelters and transitional
housing.
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AP-75 BARRIERS TO AFFORDABLE HOUSING – 91.220(J)
Introduction:
Negative Effects of Public Policies on Affordable Housing and Residential
Investment
Oakland County’s 2020 Analysis of Impediments to Fair Housing Choice (AI) identifies
several challenges related to housing affordability and access as county’s barriers to fair
housing choice. The AI also includes a review of the county’s existing zoning code and
identifies policies that may limit the development of affordable housing in the region.
Housing problems and limited access to homeownership disproportionately
impact protected classes
Analysis of 2008-2017 homeownership data from the Housing Mortgage Disclosure Act
(HMDA) showed that the mortgage denial rate in Oakland County is disproportionately
among Black and African American households, who had an average denial rate of
29%. This denial rate was significantly higher than the county’s overall average of 15%.
Comparatively, White households had the county’s lowest average denial rate at 13%.
Additionally, Comprehensive Housing Affordability Strategy (CHAS) data analysis on
housing needs performed in this Consolidated Plan revealed that Black households
exhibited disproportionately high rates of housing problems compared to the county as
a whole.
Disparate patterns in lending, moderate to high levels of segregation, insufficient
affordable housing in a range of unit sizes, racial minority households with
disproportionate rates of housing problems, insufficient accessible affordable housing,
and discrimination on the basis of disability were all identified as high priority
contributing factors that impacted fair housing choice in the county’s latest AI.
Zoning, Affordability, and Housing Choice
Although zoning ordinances and land use codes play an important role in regulating the
health and safety of the built environment, overly restrictive codes can negatively impact
housing affordability and fair housing choice within a jurisdiction. A Land Use Planner
Survey of jurisdictions’ zoning codes and land use regulations was conducted to identify
any barriers that might impede access to housing. This survey found that most
jurisdictions define the word “family” as related by blood, marriage, or adoption or
"related" in any other traditional sense, which may limit access to housing choice. In
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addition, few jurisdictions actively encourage affordable housing development or
inclusionary policies.
Barriers to housing access in the private market
In addition to these public-sector barriers, the private market can also create barriers.
Some landlords may refuse to rent units to households receiving other forms of housing
assistance. This practice, known as source of income discrimination, reduces the
affordability of existing units in the private housing stock and creates barriers to
obtaining affordable housing. While source of income discrimination is illegal in the state
of Michigan, many residents still struggle to find landlords willing to accept Section 8 or
Housing Choice Vouchers for reasons ranging from stigma and discrimination to
landlord concern about the potential for added cost. Housing Choice Vouchers make up
a significant portion of publicly supported housing within Oakland County and are a key
element in providing affordable housing to the county’s most vulnerable populations.
Because of this, landlord reluctance presents a significant barrier to affordable housing.
Actions it planned to remove or ameliorate the negative effects of
public policies that serve as barriers to affordable housing such as
land use controls, tax policies affecting land, zoning ordinances,
building codes, fees and charges, growth limitations, and policies
affecting the return on residential investment
Oakland County has implemented several strategies to increase access to affordable
housing in the region through countywide programs and partnerships with area
nonprofits and service organizations. These actions include the County’s establishment
of the Housing Trust Fund (HTF) in 2023, which supports the development and
preservation of affordable, attainable, workforce, and mixed-income housing throughout
the county. Eligible applicants for HTF funds include developers, Community Housing
Development Organizations (CHDOs), government entities, local housing
commissions/authorities, and other housing-related development/preservation entities.
The HTF and NHD have been successful in working with their local city, village, and
township partners to approve zoning changes, payment in lieu of taxes (PILOTs), tax
increment financing districts, and other local control matters that has resulted in the
creation or preservation of over 1,550 mixed-income housing units.
The Unlocking Doors Oakland County Program also helps remove barriers to housing
for homeless individuals receiving voucher assistance. This program incentivizes
landlords to rent their home or apartment to a homeless individual with a housing
voucher by providing up to $3,000 in assistance for minor unit repairs if they participate.
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AP-85 OTHER ACTIONS – 91.220(K)
Introduction:
This section details Oakland County’s plans to ensure safe and affordable housing for
its residents, meet underserved needs, reduce poverty, develop institutional structure,
and enhance coordination between public and private sector housing and community
development agencies.
Actions planned to address obstacles to meeting underserved needs
Residents and stakeholders who participated in this planning process noted that
underserved needs in Oakland County include housing affordable to residents with low
or moderate incomes; housing and services for people experiencing or at risk of
homelessness; and a range of public services and facilities to meet specific community
needs. Obstacles to meeting underserved needs include:
• Loss of existing affordable housing due to factors such as increasing rents and
home values and aging housing stock in need of rehabilitation
• High costs of new development and associated need for subsidies for
development of new affordable housing
• Increasing homelessness due to high housing costs and need for services to
connect residents with permanent housing and services, and
• Limited funding to provide needed services and facilities.
To develop additional resources to address affordable housing, homelessness, and
public services and facilities needs, Oakland County will fund a variety of projects to
meet underserved needs such as affordable housing, homelessness, public facilities
and infrastructure, and public services. The County will continue to leverage a variety of
funds, including CDBG, HOME, and HTF funds to accomplish this work.
Actions planned to foster and maintain affordable housing
To maintain and expand the current affordable housing stock, Oakland County through
NHD and the HTF, will continue to identify and develop partnerships with nonprofit
housing organizations and housing developers with the goal of increasing the supply of
affordable housing by leveraging outside resources and their development experience.
These may include LIHTC or other developers considering housing projects in the
county. The County will also look at using funding or grants that can be leveraged to
bring new dollars for affordable housing or homelessness into the community. Finally,
the County will continue to increase housing affordability by providing funding for
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infrastructure to support affordable housing development, accessibility and home repair
programs, and tenant-based rental assistance.
In addition to specific programs designed to foster and maintain affordable housing,
participating cities will review zoning ordinance for prospective barriers to affordable
housing development and make amendments as needed, including possible changes
that would decrease costs or risk for multifamily and other affordable housing
developments, and identifying zones where multifamily and other affordable housing
types, such as accessory dwelling units or smaller homes, may be built as-of-right.
Actions planned to reduce lead-based paint hazards
An important initiative emanating from HUD in the last decade is the reduction of lead-
based paint hazards, and many jurisdictions around the country have focused on
reaching this goal. The federal Residential Lead-Based Paint Hazard Reduction Act of
1992 (Title X of the Housing and Community Development Act of 1992) amends the
Lead-Based Paint Poisoning Prevention Act of 1971, which is the law covering lead-
based paint in federally funded housing. These laws and subsequent regulations issued
by the U.S. Department of Housing and Urban Development (24 CFR part 35) protect
young children from lead-based paint hazards in housing that is financially assisted or
being sold by the federal government.
Should Oakland County undertake any property rehabilitation projects, the County will
assess whether lead-based paint might be present and, if so, follow the guidelines set
forth in the Residential Lead-Based Paint Hazard Reduction Act of 1992. Oakland
County is committed to testing and abating lead in all pre-1978 housing units assisted
with federal grant funds in any of the housing programs it implements.
Actions planned to reduce the number of poverty-level families
Supportive services such as homeless prevention/assistance, emergency rental/utility
assistance, food assistance, education, and health resources are offered by a variety of
area nonprofits and organizations, including Oakland Livingston Human Service Agency
(OLHSA), Community Housing Network (CHN), Lighthouse, and HOPE Shelters,
among others. These organizations are guided by the goal of reducing the number of
Oakland County households living in poverty through direct assistance via financial aid,
food pantries, clothing distribution, and other wraparound services that help residents
meet basic needs and move toward long‑term stability.
In addition, NHD and the HTF have invested in the development or preservation of
1,550 mixed-income housing units including 981 project-based voucher units. Included
in the 981 voucher units are 173 permanent supportive housing units. NHD is
committed to providing and connecting Oakland County residents with wrap around
services intended to eliminate housing insecurity.
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Actions planned to develop institutional structure
The unmet needs of rental housing affordable to low-income residents and social
services for individuals and families experiencing or at risk of homelessness present an
opportunity for the County to further connect with and support organizations, affordable
housing developers, and agencies working to address these needs in Oakland County.
The County will also continue to work within existing partnerships and coalitions, such
as the Alliance for Housing to work toward meeting local housing and service needs.
Oakland County will continue to work closely with state and local agencies and
governments, nonprofit organizations, and other service providers to coordinate delivery
of services to county residents. The Neighborhood and Housing Development Division
will continue to consult with various housing, homelessness, social service, elderly, and
disability resource agencies to gather data and identify service gaps.
Actions planned to enhance coordination between public and private
housing and social service agencies
Oakland County will continue to be an active participant in the Alliance for Housing,
which secures and distributes funding for direct service providers in the housing and
homeless community and provides guidance to strengthen policies and programs. This
work includes street outreach, emergency shelter, transitional housing, rapid rehousing,
prevention and diversion, and permanent supportive housing. The County will also
continue to partner with regional organizations, such as the Southeast Michigan
Economic Development Council, to enhance coordination between area agencies.
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2026-2030
Program Specific
228
AP-90 PROGRAM SPECIFIC REQUIREMENTS – 91.220(L)(1,2,4)
Introduction:
CDBG Revolving Loan Funds are used to support Home Improvement Program projects
in accordance with CDBG & HUD guidelines.
Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year
are identified in the Projects Table. The following identifies program income that
is available for use that is included in projects to be carried out.
1. The total amount of program income that will have been received
before the start of the next program year and that has not yet been
reprogrammed
0
2. The amount of proceeds from section 108 loan guarantees that will
be used during the year to address the priority needs and specific
objectives identified in the grantee's strategic plan
0
3. The amount of surplus funds from urban renewal settlements 0
4. The amount of any grant funds returned to the line of credit for which
the planned use has not been included in a prior statement or plan. 0
5. The amount of income from float-funded activities 0
Total Program Income 0
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Other CDBG Requirements
HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)
1. A description of other forms of investment being used beyond those identified in
Section 92.205 is as follows:
Other forms of investment include private and other public investments. HOME
funds will not be invested in a loan guarantee as an eligible activity as indicated in
24 CFR 92.205(b).
2. A description of the guidelines that will be used for resale or recapture of HOME
funds when used for homebuyer activities as required in 92.254, is as follows:
The Oakland County Neighborhood & Housing Development Division has
comprehensive program guidelines which provide for the recapture of HOME funds
in compliance with program requirements 24 CFR 92.254(a). Under the recapture
provision, the HOME investment subject to recapture is the HOME assistance that
enables the homebuyer to afford the dwelling unit. This homebuyer assistance is a
subsidy ($1,000.00 minimum) that makes the home affordable to a low-income
homebuyer. The County’s home buyer assistance is a deferred payment loan with
0% interest. The Division secures its interest in the property with a mortgage and
note. One hundred percent of the HOME investment is recaptured upon conversion
of property use and/or ownership unless, due to foreclosure, there are not enough
proceeds to pay the full amount of the loan. The County will accept the balance of
the net proceeds as payment in full, the debt will be extinguished and the
affordability period ends. Recaptured funds must be used to carry out HOME eligible
1. The amount of urgent need activities 0
2. The estimated percentage of CDBG funds that will be used for
activities that benefit persons of low and moderate income. Overall
Benefit - A consecutive period of one, two or three years may be used
to determine that a minimum overall benefit of 70% of CDBG funds is
used to benefit persons of low and moderate income. Specify the
years covered that include this Annual Action Plan.
98%
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activities.
3. A description of the guidelines for resale or recapture that ensures the affordability of
units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows:
The HOME Program stipulates an affordability period on projects assisted with
HOME funds to ensure that HOME investments yield affordable housing over the
long term. Section 215 of the National Affordable Housing Act outlines the term
“affordable housing”. To qualify as affordable, all rental and homeownership units
constructed or rehabilitated with HOME funds must adhere to the regulation. It is the
responsibility of each HOME participating jurisdiction to report to HUD the number of
affordable units completed on an annual basis. Although the CDBG program does
not require the qualification of units as “affordable” following the HOME Section 215
regulations, it is useful to keep track of affordable units rehabilitated with CDBG
funds. Oakland County meets Section 215 requirements as:
• HOME assisted units are available for households at 80% of area median income
(AMI) or below
• Initial purchase price of units does not exceed HUD Homeownership Value Limits
• The units serve as the owner’s principal residence
• All newly constructed housing meets energy efficiency standards
• Recapture provisions allow the County to provide assistance as a deferred loan
secured by mortgage and note (0% interest)
• The loan becomes due and payable when the homeowner vacates, sells,
transfers, or assigns any legal or equitable interest in the property except where
prohibited by law. Upon the deaths of the loan recipients, it is the responsibility of
the estate or heirs to repay the loan when the estate is settled.
4. Plans for using HOME funds to refinance existing debt secured by multifamily
housing that is rehabilitated with HOME funds along with a description of the
refinancing guidelines required that will be used under 24 CFR 92.206(b), are as
follows:
The Oakland County HOME Consortium does not intend to refinance existing debt
secured by multifamily housing rehabilitated with HOME funds.
5. If applicable to a planned HOME TBRA activity, a description of the preference for
persons with special needs or disabilities. (See 24 CFR 92.209(c)(2)(i) and CFR
91.220(l)(2)(vii)).
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Not Applicable.
6. If applicable to a planned HOME TBRA activity, a description of how the preference
for a specific category of individuals with disabilities (e.g. persons with HIV/AIDS or
chronic mental illness) will narrow the gap in benefits and the preference is needed
to narrow the gap in benefits and services received by such persons. (See 24 CFR
92.209(c)(2)(ii) and 91.220(l)(2)(vii)).
Not Applicable.
7. If applicable, a description of any preference or limitation for rental housing projects.
(See 24 CFR 92.253(d)(3) and CFR 91.220(l)(2)(vii)). Note: Preferences cannot be
administered in a manner that limits the opportunities of persons on any basis
prohibited by the laws listed under 24 CFR 5.105(a).
Not Applicable.
Emergency Solutions Grant (ESG) Reference 91.220(l)(4)
1. Include written standards for providing ESG assistance (may include as
attachment)
For the Homeless Assistance and Rapid Re-housing portion of the grant, recipient
agencies will conduct an initial evaluation to determine each individual or family’s
eligibility for ESG assistance and the amount and types of assistance the household
needs to regain stability in permanent housing. The evaluations will be conducted in
accordance with the centralized assessment requirements of the Oakland County
Continuum of Care. Eligibility requirements for the Rapid ReHousing and/or
prevention components of the program include:
• The program participant must meet the criteria under the Federal homeless
definition as amended under the HEARTH act. A homeless certification form is
required.
• The household income must be less than 30% of AMI. Annual income will be
calculated using the standards for calculating income under HOME and Section 8
income guidelines.
• The household cannot have assets more than $1,000 for an individual or $2,000
for a family
• The program participant lacks enough resources and support networks
necessary to retain housing without ESG Assistance, but for this assistance they
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would be homeless.
After an initial evaluation, a housing plan will be developed, and a participant must
meet with his or her caseworker as prescribed under the plan. Unless prohibited
under the Violence Against Women Act, as amended or the Family Violence
Prevention and Services Act, the recipient will be connected to appropriate
supportive services including assistance in obtaining permanent housing, mental
health treatment, counseling and other services essential for achieving independent
living. They will also be linked to federal, state, local and private assistance available
to assist with obtaining housing stability including Medicaid, food assistance, WIC,
unemployment benefits, SSI, SSDI, Veteran’s benefits, medical assistance, legal
aid, employment assistance and other locally available assistance programs. A plan
will be developed to assist the program participant to retain permanent housing after
the assistance ends, considering all relevant considerations such as the program
participants current or expected income and expenses, other public or private
assistance for which the program participant will be eligible and likely to receive and
the affordability of available housing in the area. Each participant will be linked to
available PSH programs or the local HCV, Section 8 Voucher Programs, Public
Housing Authorities and project based rental assistance when the waiting lists are
open.
2. If the Continuum of Care has established centralized or coordinated assessment
system that meets HUD requirements, describe that centralized or coordinated
assessment system.
Oakland County agencies practice a no wrong door approach. Coordination among
emergency shelter providers, essential services providers, homelessness prevention
and rapid re-housing assistance providers, other homeless assistance providers and
mainstream services and housing providers will be done through HMIS sharing, the
centralized assessment form, the local Homeless Assistance and Recovery Agency
(HARA) and the Community Inter-Agency Service Team (CIST). All ESG recipients
will be required to be an active member of the Continuum of Care and attend
bimonthly meetings. At these meetings, case managers can share information and
resources and assist each other with resources for clients. MSHDA and Michigan
DHHS with the full support from the Michigan Coalition Against Homelessness
requires the use of a single assessment tool for people experiencing homelessness.
This tool, known as the Vulnerability Index - Service Prioritization Decision Assistance
Tool (VI-SPDAT) will provide HARAs and other housing agencies with a standardized,
evidence-informed assessment process that prioritizes vulnerability. Michigan’s
Campaign to End Homelessness is committed to Housing First and has identified VI-
SPDAT as the tool that will be implemented in every community so that our state
moves forward in ending homelessness while supporting HEARTH Act regulations.
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Youth programs are exempt and use their own similar statewide assessment tool.
Oakland County providers meet once a month and have calls weekly to discuss VI-
SPDAT scores and prioritize program openings based on need
VI-SPDAT training is provided and offered free of charge. The training is mandatory
for HARA midlevel management, HARA front line staff, DHHS Continuum of Care mid-
level management and DHHS Continuum of Care Program front line staff. The DHHS
Continuum of Care Program includes the following projects: Rapid Re-Housing
Initiative, Transitional Supportive Housing Leasing Assistance Program, Rural
Housing & Supportive Services and the Rural Homeless PSH Initiative. HARA and
DHHS Continuum of Care Program and Executive Directors are strongly encouraged
to attend the training. HMIS entry is not granted to agency employees until VI-SPDAT
training has been completed.
3. Identify the process for making sub-awards and describe how the ESG allocation
available to private nonprofit organizations (including community and faith-based
organizations).
Generally, each June the Division hosts an ESG application workshop. The
workshop is advertised in the Oakland Press, on the Oakland County website and
on the Alliance for Housing list serve. The workshop provides details on the
application requirements for the emergency shelter, HMIS and homeless prevention
and rapid re-housing activities. Applicants are required to submit supporting
documents including non-profit status, HMIS certification, non-debarment status,
financial statements, insurance, policies and procedures and budgets. All
emergency shelters that meet the application requirements receive funding based on
formula. The lead agency of the CoC receives the HMIS funds. HPRP is scored
based upon specific criteria and the awards are determined by committee. One-year
contracts are awarded once funds are released.
4. If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR
576.405(a), the jurisdiction must specify its plan for reaching out to and consulting
with homeless or formerly homeless individuals in considering policies and funding
decisions regarding facilities and services funded under ESG.
The Division has a member of Citizen Advisory Council who was previously
homeless and was “couch surfing” with her child for a period of time. Though this
does not meet the official definition of homeless, Oakland County is committed to
having representation of formerly homeless individuals on its advisory board.
However, through consultation with the Continuum of Care and citizen participation
process, the County obtains input from homeless or formerly homeless persons. In
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addition, as previously required in the ESG and Homeless Prevention and Rapid Re-
Housing Program, the Division is passing this requirement on to funded agencies via
contract language. This requirement will be checked at monitoring. The Continuum
of Care has a formerly homeless person on their board. The Continuum of Care
provides input to the Division on the ESG program.
5. Describe performance standards for evaluating ESG.
ESG Monitoring Standards and Procedures - Oakland County will continue to
implement a monitoring policy to ensure that ESG recipients follow applicable
requirements. Annual onsite monitoring of shelters and transitional housing
providers will include inspections to ensure that housing conforms to habitability
standards under the HEARTH Act as well as LBP regulations. In addition to project
performance, accountability, financial responsibility and adherence to federal grant
management regulations. Monitor reviews will sample client files to ensure that case
management, action plans and referrals to mainstream benefits are provided and the
files are maintained appropriately.
Reimbursement requests will be reviewed, and cross referenced with contracts and
procurement documents as warranted. Rapid re-housing and homeless prevention
files will be checked to ensure that all required documents including homeless
certification forms, income calculations, lease, recertification documents and
habitability inspection reports are accurate. In addition, before reimbursement can
be made verification will be required including certification of homelessness, lease
documents, income calculations, as well as cancelled checks and invoices. A
contract will be developed requiring quarterly reimbursement requests and timely
expenditure of funds. Monitoring was done via desk audits or in person as the
COVID-19 pandemic restrictions allow.
Performance Measures - Oakland County’s ESG program complies with CoC
performance measurements which are available at
https://www.oaklandhomeless.org/
Homeless - 65% of participants who meet the homeless definition will be stably
housed 90 days after being exited from ESG/HARA through independent means or
through linkage to another program (e.g. PSH, subsidized housing).
Chronically Homeless - 50% of participants who meet the chronically homeless
definition will be stably housed 90 days after being exited from ESG/HARA through
independent means or through linkage to another program (e.g. PSH, subsidized
235
housing).
In April 2016, MDHHS, MSHDA and MCAH issued an important update to the
SPDAT which outlines the VI- SPDAT and SPDAT requirements. SPDAT has
brought Michigan further along in the goal to redesign systems by providing every
community a standardized evidence-based tool to support coordinated entry while
taking Housing First practices to scale statewide. Since the implementation of the VI-
SPDAT, the Alliance has reported that the tool helps them gauge the progression of
client self-sufficiency as it relates to housing. Because the full VI-SPDAT is used
during every follow-up meeting completed with active ESG clients assisted, it is
instrumental in practicing progressive engagement with clients to ensure not only
that basic needs are being fulfilled but that linkage to other resources is being made.
Additional MSHDA/ESG outcomes include:
• Percentage of those served who maintain housing one year after assistance
ends (RRH and Prevention)
• Percentage of clients that increase income within that year and/or within the
timeframe of active housing assistance
• Length of time between screening/intake and moving into housing
• Minimum number of households served each PY Modifications to the
residency factor in the ESG formula have been discussed at the staff level.
The Division plans to meet with stakeholders and to present any proposed
changes for CAC and BOC consideration. For the PY 2026-2030
Consolidated Plan the Division will follow its Citizen Participation Plan
amendment process if required to address any ESG formula changes that
may impact the County’s program.
www.hud.gov
TABLE OF CONTENTS
SECTION 1: OVERVIEW OF THE CONSOLIDATED PLAN NOTICE ............................. 3
1.1 Who’s this Notice for? ........................................................................................................... 3
1.2 What is “consolidated planning”? ......................................................................................... 3
1.3 What’s the purpose of the Consolidated Plan? ...................................................................... 4
1.4 What’s covered in this Notice? .............................................................................................. 4
1.5 What’s new in this Notice? .................................................................................................... 5
1.6 Who can I contact if I have questions? ................................................................................. 5
SECTION 2: WHEN TO SUBMIT YOUR PLAN ..................................................................... 6
2.1 When is my plan due according to the consolidated planning regulations? ......................... 6
2.2 Between what dates can I submit my plan each FY? ............................................................ 6
2.3 Can I submit my plan after August 16? ................................................................................. 6
2.4 How do late appropriations affect my plan due date? ........................................................... 7
2.5 Why can’t I submit my plan using estimated grant amounts? .............................................. 7
2.6 Do I need to request a regulatory waiver of 24 CFR 91.15(a)(1) if I can’t submit
my plan before my normal plan due date (45 days before my PY start date)? ..................... 8
2.7 How do I figure out my plan due date, given late appropriations, which may delay
my “normal plan due date”? .................................................................................................. 8
2.8 How should HTF grantees (and HTF subgrantees) submit a plan, given different
timing of HTF allocations? ................................................................................................. 10
SPECIAL ATTENTION:
All CPD Division Directors
HUD Field and Regional Offices
All CDBG Grantees
All HOME Participating Jurisdictions
All HTF Grantees
All ESG Grantees
All HOPWA (Formula) Grantees
NOTICE: CPD-26-05
Issued: April 01, 2026
Expires: Remains in effect until amended,
superseded, or rescinded.
Regulatory Cross References:
24 CFR Part 91, Part 92, Part 93
24 CFR Part 570
2 CFR Part 200
SUBJECT: Guidance on Submitting Consolidated Plans and Annual Action Plans
for HUD Community Planning and Development (CPD) Formula Grant Programs
SECTION 3: WHAT TO SUBMIT AND HOW TO SUBMIT ................................................ 12
3.1 What’s the minimum I should submit to meet the August 16 application deadline? .......... 12
3.2 Where must I list my actual grant amounts in my plan? ..................................................... 13
3.3 How must I submit my plan to HUD? ................................................................................. 13
3.4 Am I required to submit hard original copies of any documents or email digital
copies of any required documents to my CPD field office? ................................................ 13
3.5 What types of signatures on documents will HUD accept and who must sign? ................. 13
3.6 If my jurisdiction was awarded a CDBG-DR or CDBG-MIT grant, are we required
to incorporate these grants into our Consolidated Plan/Action Plan? ................................. 14
3.7 What HUD resources are available to help me with preparing my plan? ........................... 14
3.8 How do Opportunity Zones intersect with my plan(s)? ...................................................... 14
SECTION 4: HUD’S REVIEW OF YOUR PLAN .................................................................. 16
4.1 What standards does HUD use to review my plan? ............................................................ 16
4.2 How long does HUD have to review my plan? ................................................................... 16
4.3 What happens if I submit a plan that contains estimated (not actual) grant amounts? ....... 16
4.4 What are the reasons HUD may disapprove my plan? ........................................................ 17
4.5 What are examples of plans that are “substantially incomplete”? ...................................... 17
4.6 When must I resubmit my plan if HUD disapproves my first submission? ........................ 17
4.7 Am I required to carry out additional citizen participation after making changes
to my plan because HUD disapproved my first submission? .............................................. 17
4.8 How can I determine if I need to carry out additional citizen participation? ...................... 18
SECTION 5: HOW TO MEET CITIZEN PARTICIPATION REQUIREMENTS
IN THE INTERIM BEFORE HUD ANNOUNCES GRANT ALLOCATIONS ................... 19
5.1 Is my jurisdiction required to meet citizen participation requirements before
submitting my plan? ............................................................................................................ 19
5.2 Is my jurisdiction allowed to expedite the citizen participation process? ........................... 19
5.3 What are my options for meeting my citizen participation requirements? ......................... 19
5.4 Option 1: Carry out citizen participation using estimated funding amounts ....................... 20
5.5 Option 2: Carry out citizen participation after HUD announces grant allocations ............. 21
5.6 Why should I follow one of these options (described in Sections 5.4 or 5.5)? ................... 21
SECTION 6: GUIDANCE ON PRE-AWARD COSTS ........................................................... 22
6.1 What are “Pre-Award Costs”? ............................................................................................. 22
6.2 What general provisions apply to all CPD formula program grantees? .............................. 22
6.3 Do I need a regulatory waiver to incur Pre-Award Costs for CDBG or HOME grants? .... 24
6.4 What specific provisions apply for each of the five CPD formula grant programs? .......... 25
3
SECTION 1: OVERVIEW OF THE CONSOLIDATED PLAN NOTICE
1.1 Who’s this Notice for?
This Notice is for all grantees1 of the five HUD community planning and development
(CPD) formula grant programs listed below. These programs require grantees to submit
a “consolidated planning” document to HUD:
1. Community Development Block Grant (CDBG) Program2
2. HOME Investment Partnerships (HOME) Program
3. Housing Trust Fund (HTF) Program
4. Emergency Solutions Grants (ESG) Program
5. Housing Opportunities for Persons With AIDS (HOPWA) Formula Program
1.2 What is “consolidated planning”?
HUD laws and regulations require grantees under these programs to submit a Consolidated
Plan—and annual updates referred to as the Annual Action Plan—to HUD for review.
HUD regulations for consolidated planning are at 24 CFR Part 91.
1.2.1 The Consolidated Plan
Every three or five years, your jurisdiction must submit a Consolidated Plan to
HUD for review.3 This document serves as a “comprehensive housing affordability
strategy,” community development plan, and your jurisdiction’s application for
funding for these programs.4
In the plan, your jurisdiction describes how you will use HUD’s CPD formula
grant funding to provide: 1) decent housing, 2) a suitable living environment, and
3) expanded economic opportunities (primarily for the benefit of low-income and
moderate-income people). These are the three overall goals of HUD CPD formula
grant programs (24 CFR 91.1(a)).
The “comprehensive housing affordability strategy” includes five components:
1. Housing and Homeless Needs Assessment (24 CFR §§ 91.205, 91.305, 91.405);
2. Housing Market Analysis (24 CFR §§ 91.210, 91.310, 91.410);
1 This Notice also applies to HOME Investment Partnerships (HOME) Program participating jurisdictions (PJs).
HUD uses “grantees” in this Notice for simplicity.
2 The guidance in this Notice for CDBG grantees and the consolidated planning regulations at 24 CFR Part 91 apply
to all CDBG grantees: 1) CDBG Entitlement grantees; 2) State CDBG grantees; 3) CDBG Insular Areas grantees;
and 4) CDBG Non-Entitlement Hawaiian Counties.
3 The plan is called the Consolidated Plan because before it was created in 1995, grantees were required to submit
different plans for each CPD formula grant program.
4 Your jurisdiction must submit Standard Form 424 (SF-424): Application for Federal Assistance as part of each
Annual Action Plan. See 24 CFR §§ 91.220(a), 91.320(a), 91.420(a).
4
3. Strategic Plan (24 CFR §§ 91.215, 91.315, 91.415);
4. Action Plan (24 CFR §§ 91.220, 91.320, 91.420); and
5. Certifications (24 CFR §§ 91.225, 91.325, 91.425).
1.2.2 The Annual Action Plan
Each year of your jurisdiction’s “consolidated planning cycle,”5 your jurisdiction
must also submit an Annual Action Plan to HUD for review. The Action Plan is a
component of the Consolidated Plan.
In the Action Plan, your jurisdiction provides more specific details on activities
you will carry out in the next year to address the needs and goals identified in
your Consolidated Plan. Ultimately, HUD evaluates your jurisdiction based on
its performance towards goals in your Consolidated Plan and Action Plans.6
1.3 What’s the purpose of the Consolidated Plan?
The Consolidated Plan fulfills four purposes or functions (per 24 CFR 91.1(b)):
1. A planning document for the jurisdiction, based on a participatory process
that engages citizens, organizations, businesses, and other stakeholders
2. An application for federal funds under HUD’s CPD formula grant programs
3. A strategy to follow in carrying out HUD’s CPD formula grant programs
4. A management tool for assessing grantee performance and tracking results
1.4 What’s covered in this Notice?
This Notice provides guidance for grantees on:
When to submit your Consolidated Plan and/or Annual Action Plan
What constitutes an acceptable plan submission (what you must submit)
How to submit your plans and documents (technical submission details)
CPD program flexibility to meet citizen participation requirements
Costs you may incur before executing your grant agreement (“Pre-Award Costs”)
NOTE : The guidance in this Notice applies equally to Consolidated Plans and Action Plans, regardless of
whether the Action Plan is submitted as a stand-alone document or submitted with the full Consolidated Plan.7
5 Most grantees are on a five-year consolidated planning cycle.
6 Your jurisdiction must submit a Consolidated Annual Performance and Evaluation Report (CAPER) each year.
7 For simplicity, HUD uses “plan” to refer to both types of plans in this Notice. The first program year of your
three- or five-year consolidated planning cycle, your jurisdiction must submit an Action Plan as part of your full
Consolidated Plan. The remaining years of your cycle, you must only submit an Action Plan.
5
1.5 What’s new in this Notice?
Converted to a standing Notice: HUD will no longer publish this Notice annually.
This Notice is now a standing Notice and will remain in effect until amended,
superseded, or rescinded. Each fiscal year (FY), HUD may choose to publish
a memorandum providing additional guidance on consolidated planning.
Clarified what to submit and how to submit: This Notice clarifies what you must
submit (at minimum) to meet the statutory August 16 application deadline. This
Notice also provides more details about the format and methods of submission
HUD will accept. GO TO SECTION 3 : WHAT TO SUBMIT AND HOW TO SUBMIT.
Eliminated Pre-Award Costs regulatory waiver for CDBG and HOME:
In previous FYs and prior versions of this Notice, HUD attached a regulatory waiver
concerning Pre-Award Costs for CDBG grantees and HOME PJs. Due to changes in
the 2025 HOME rule8 (which affects CDBG), this waiver is no longer necessary.
Added more headings, subheadings, and a table of contents: HUD added more
headings, subheadings, and a table of contents to this Notice to make information
easier to find. The Notice is more “scannable” now and you can use the table of
contents to search for what you need.
Rewritten in Plain Language: HUD rewrote the Notice in plain language based on
the U.S. Government’s Principles of Plain Language and Guidelines for Document
Designers. The Plain Writing Act of 2010 (Pub. L. No. 111-274) requires executive
branch agencies to use plain writing in any communication intended for the public.
Rewritten towards grantees: A key principle of plain language is to write directly
towards a specific audience, focusing on their needs. HUD rewrote this Notice to
speak to its main audience: grantees like you. The Notice still provides guidance
for HUD’s CPD field staff indirectly, but it directly addresses grantees throughout.
1.6 Who can I contact if I have questions?
Contact your CPD Representative or your local CPD field office.
8 HOME Investment Partnerships Program: Program Updates and Streamlining, 90 Fed. Reg. 746 (Jan. 06, 2025)
6
SECTION 2: WHEN TO SUBMIT YOUR PLAN
2.1 When is my plan due according to the consolidated planning regulations?
Per 24 CFR 91.15(a)(1), you should submit your plan to HUD at least 45 days before the
start of your “program year” (PY).9 This is your “normal plan due date.” For example, if
your PY start date is June 1, your plan must be submitted no later than April 16.
However, your normal plan due date may be substituted with a “revised plan due date”
due to Congress not appropriating funding for HUD by October 1 (the start of the federal
fiscal year). In this Notice, HUD refers to this as “late appropriations.” Revisions and
delays to your plan due date because of late appropriations are especially common if you
have an earlier PY start date (January 1–April 1). GO TO SECTION 2 .7 for guidance on
how to figure out your plan due date.
2.2 Between what dates can I submit my plan each FY?
Per 24 CFR 91.15(a)(2), you may only submit your plan between November 15 and
August 16 each FY. Your plan due date is determined by two dates each FY: 1) your PY
start date and 2) the date HUD announces your grant allocations. GO TO SECTION 2 .7
for guidance on how to figure out your plan due date.
You are advised not to submit your plan until HUD announces your grant allocations
AND after you have incorporated your actual grant amounts into your plan and all
required grant application documents (e.g., SF-424s).
2.3 Can I submit my plan after August 16?
Failure to submit your plan by the August 16 deadline will result in your jurisdiction’s
automatic loss of CDBG funds for that FY. This requirement is established by statute10
and regulations,11 so HUD cannot waive or extend the August 16 application deadline.
Grant funding under the other CPD formula programs (HOME, HTF, ESG, HOPWA)
is not subject to the August 16 deadline. However, since virtually all CPD formula
grantees receive CDBG funding, the CDBG deadline effectively establishes the final
application deadline for all five programs.
9 This is called your “PY start date.” Your jurisdiction chooses the dates of your PY, and the only two criteria
are that your PY must begin on the first calendar day of a month (the earliest PY start date is January 1) and
your PY must run for a 12-month period. Your jurisdiction can change its PY start date by following the
requirements at 24 CFR 91.10(b).
10 Housing and Community Development Act (HCDA) of 1974 42 USC 5316: Transition provisions
11 24 CFR 91.15(a)(2)
7
2.4 How do late appropriations affect my plan due date?
Late appropriations delay HUD’s ability to calculate and announce CPD formula grant
allocations (your actual grant amounts). This causes delays to some grantees’ plan due
dates because HUD requires plans to be based on, and contain, actual grant amounts or
HUD will disapprove them. Actual grant amounts are often not available until several
months into the FY due to late appropriations.
Your jurisdiction must figure out your plan due date each FY because the date that HUD
announces CPD formula grant allocations will vary each FY due to late appropriations.
GO TO SECTION 2 .7 for more guidance on how to figure out your plan due date.
In general, HUD does not require grantees to submit their plan until 60 days after HUD
announced CPD formula grant allocations. The reason for delaying plan due dates is to
allow time for affected grantees to add their actual grant amounts into their plan and to
carry out citizen participation activities for their plan, if necessary.
2.4.1 Background: The CPD formula grant allocation process
After Congress enacts an appropriations bill for HUD, HUD must compute your
grant amounts for the CPD formula grant programs your jurisdiction participates
in. This CPD formula grant allocation process takes time as allocations are based
on several formulas across the five programs and HUD must accurately determine
the number of jurisdictions participating in each program each FY. Generally, the
appropriations acts require HUD to announce CPD formula allocations within 60
days of the enactment of the appropriation.
2.5 Why can’t I submit my plan using estimated grant amounts?
In the past, HUD allowed grantees to submit plans based on, and containing, estimated
grant amounts. HUD did not disapprove plans just because they were based on estimated
grant amounts and these plans were typically deemed approved. This practice resulted in
extra work for both HUD and grantees. After HUD announced grant allocations, grantees
had to re-submit revised SF-424s to reflect their actual grant amounts for each of their
formula grant programs. In many cases, grantees also had to make changes to their plan
to account for their actual grant amounts. Sometimes this may have even triggered a
“substantial amendment” under 24 CFR 91.505. Depending on the provisions in the
grantee’s Citizen Participation Plan (24 CFR 91.105), some grantees were also required
to seek public comments on the “substantial” changes to their plan.
To minimize burden and duplication of effort, HUD now requires you to submit plans
based on, and containing, your actual grant amounts. HUD won’t execute your grant
agreement(s) until HUD has received a plan that incorporates your actual grant amount(s)
and that plan is deemed approved. If you submit a plan without your actual grant amounts,
HUD will disapprove your plan and return it to you for resubmission.
8
2.6 Do I need to request a regulatory waiver of 24 CFR 91.15(a)(1) if I can’t submit my
plan before my normal plan due date (45 days before my PY start date)?
No. You do not need to request a regulatory waiver of 24 CFR 91.15(a)(1) if you can’t
submit your plan by your normal plan due date (due to late appropriations and HUD’s
announcement of formula grant allocations). As the regulatory provision states, “HUD
may grant a jurisdiction an extension of the submission deadline for good cause.”
This Notice provides that a late appropriation serves as good cause for HUD to extend
the submission deadline for your plan. You do not have to request an exception to your
normal Action Plan due date under 24 CFR 91.15(a)(1). Your local CPD field office also
does not have to grant an exception to your Action Plan submission deadlines (24 CFR
91.20) to implement the procedures in this Notice.
If you will not be able to submit your plan by your normal or revised plan due date,
please notify your CPD field office. These are extensions that are unrelated to late
appropriations and HUD’s announcement of grant allocations (e.g., your jurisdiction
is simply running late in submitting your plan).
2.7 How do I figure out my plan due date, given late appropriations, which may delay
my “normal plan due date”?
This section provides guidance on how to figure out your plan due date given that late
appropriations may delay your “normal plan due date.” Many, but not all, grantees are
affected by late appropriations (depending on their PY start dates). Your plan due date is
based on two dates: 1) your PY start date and 2) the date HUD announced grant allocations.
2.7.1 Revised plan due dates for CDBG, HOME, ESG, and HOPWA grantees
SECTION 2 .7 applies to CDBG, HOME, ESG, and HOPWA grantees12 whose
normal plan due date has already passed or is fewer than 60 days after the
date HUD announces grant allocations.
If your normal plan due date has already passed OR is fewer than 60 days after
the date HUD announces grant allocations, you may delay submitting your plan
up to 60 calendar days after the date HUD announced your grant allocations.
This gives your jurisdiction two months to add your actual grant amounts into
your plan and conduct any additional citizen participation (if necessary).
NOTE : If your normal plan due date is more than 60 days after the date HUD announced grant
allocations, you will have enough time to incorporate your actual grant amounts. As a result,
your normal plan due date will remain unchanged.
12 For guidance on submitting your plan for HTF Program grantees, GO TO SECTION 2 .8 .
9
2.7.2 PLAN DUE DATE TABLE EXAMPLE: Plan due dates based on HUD announcing grant allocations on April 1
This table shows your plan due date based on a fictional example of HUD announcing grant allocations on April 1.
This date is only for illustrative purposes, as HUD does not know when it will announce grant allocations each FY.
PY Start Date Normal Plan Due Date
(45 days before PY start date) If HUD announced grant allocations APRIL 1, your Normal Plan Due Date is…
January 1 November 15 IN THE PAST. Your normal plan due date passed before HUD announced grant allocations.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
February 1 December 17 IN THE PAST. Your normal plan due date passed before HUD announced grant allocations.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
March 1 January 14 IN THE PAST. Your normal plan due date passed before HUD announced grant allocations.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
April 1 February 14 IN THE PAST. Your normal plan due date passed before HUD announced grant allocations.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
May 1 March 16 IN THE PAST. Your normal plan due date passed before HUD announced grant allocations.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
June 1 April 16 FEWER THAN 60 DAYS AFTER HUD ANNOUNCED GRANT ALLOCATIONS.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
July 1 May 16 FEWER THAN 60 DAYS AFTER HUD ANNOUNCED GRANT ALLOCATIONS.
Your revised plan due date is June 1 (60 days after HUD announced grant allocations).
August 1 June 16 MORE THAN 60 DAYS AFTER HUD ANNOUNCED GRANT ALLOCATIONS.
You must submit your plan by your normal plan due date. (24 CFR 91.15(a)(1))
September 1 July 17 MORE THAN 60 DAYS AFTER HUD ANNOUNCED GRANT ALLOCATIONS.
You must submit your plan by your normal plan due date. (24 CFR 91.15(a)(1))
October 1 August 16 MORE THAN 60 DAYS AFTER HUD ANNOUNCED GRANT ALLOCATIONS.
You must submit your plan by your normal plan due date. (24 CFR 91.15(a)(1))
10
2.8 How should HTF grantees (and HTF subgrantees) submit a plan, given different
timing of HTF allocations?
2.8.1 HTF Program background and timing of HTF allocations
HTF is a formula grant program awarded to State governments to increase and
preserve decent, safe, and sanitary affordable housing for extremely low-income
and very low-income families. HTF program regulations are at 24 CFR Part 93.
The timing of HTF allocations is different from the other CPD formula grant
allocations (CDBG, HOME, HOPWA, ESG) because HTF funding is from
mandatory set-asides from two government-sponsored enterprises (GSEs)13
rather than from Federal appropriations. The earliest HUD expects to publish
HTF allocations any FY is in April.
2.8.2 Plan submission process for HTF Program grantees (State governments)
HTF regulations require your State to submit an HTF allocation plan14 as part
of your Consolidated Plan (24 CFR 93.100(b)). The requirements for your HTF
allocation plan are at 24 CFR 91.320(k)(5), including but not limited to the
requirements that it describes 1) your method of distribution for HTF funds and
2) your application requirements and criteria for selecting applications from
local governments.
If HUD has not published HTF allocations before your State is due to submit its
plan, you may submit a plan covering your other CPD formula programs by their
plan due date. After HUD publishes HTF allocations (likely in April), your State
must then submit your HTF allocation plan as a substantial amendment to your
Action Plan.
2.8.3 Plan submission process for HTF Program subgrantees
Per 24 CFR 91.220(l)(5), a unit of general local government or State agency
selected by a grantee to administer all, or a portion, of a State’s HTF program
(as a subgrantee) must include an HTF allocation plan as part of their Action
Plan. The local government’s HTF allocation plan must be consistent with the
State’s HTF allocation plan.
A subgrantee’s HTF allocation plan must contain the elements listed in 24 CFR
91.220(l)(5), which include but is not limited to 1) their method of distribution
of HTF funds and 2) their application requirements and criteria for selecting
applications submitted by eligible recipients (which meet their local
jurisdiction’s priority housing needs).
13 The GSEs are the Federal National Mortgage Association (“Fannie Mae”) and the Federal Home Loan Mortgage
Corporation (“Freddie Mac”).
14 The HTF allocation plan is the annual submission to HUD required by Section 1338 of the Federal Housing
Enterprises Financial Safety and Soundness Act of 1992, as amended (12 U.S.C. 4568).
11
Due to the timing of publication of HTF allocations and the selection process of
HTF grantees, a subgrantee(s) must submit a plan covering their other CPD formula
programs by their plan due date. After HUD publishes HTF allocations—and after
the State has selected a local government as a subgrantee according to the State’s
HTF allocation plan—any local government subgrantee selected must then submit
their HTF allocation plan as a substantial amendment to their Action Plan.
12
SECTION 3: WHAT TO SUBMIT AND HOW TO SUBMIT
3.1 What’s the minimum I should submit to meet the August 16 application deadline?
You should submit these four components or documents (at a minimum) by the August 16
application deadline to prevent the loss of your CPD formula allocation:
1. Standard Form 424 (SF-424): Application for Federal Assistance15
2. HUD-424-B: Applicant and Recipient Assurances and Certifications16
3. Certifications required by 24 CFR 91.225, 24 CFR 91.325, and 24 CFR 91.42517
4. A brief executive summary of your jurisdiction’s community and economic development
objectives and projected use of funds. You may fulfill this requirement by completing
ES-05: Executive Summary in the IDIS eCon Planning Suite. Consult the eCon Planning
Suite Desk Guide for instructions.18 Refer to 24 CFR 91.220(b) and 24 CFR 91.320(b).
KEY GUIDANCE ON THE AUGUST 1 6 APPLICATION DEADLINE
Failure to make a submission by August 16 will result in your jurisdiction’s
automatic loss of CDBG funds for that FY. HUD cannot waive or extend the
August 16 deadline. GO TO SECTION 2 .3 for more details.
This is the bare minimum you should submit to meet the August 16 deadline.
HUD strongly encourages you to submit a fully completed plan instead so that
you may use the grant funds allocated to your jurisdiction as soon as possible.
If you only submit the components above, your CPD field office will disapprove
your submission as “substantially incomplete” and return it for resubmission.
HUD will still consider your jurisdiction to have met the August 16 application
deadline if your initial plan submission is disapproved, but you must complete
and resubmit your full plan in compliance with 24 CFR Part 91.
GO TO SECTION 4 .5 for examples of “substantially incomplete” plans.
GO TO SECTION 4 .6 for more on resubmitting a plan after a disapproval.
15 An SF-424 must be completed for each formula grant program you are applying for (e.g., CDBG, HOME, HTF,
ESG, HOPWA). SF-424 form instructions are at https://www.grants.gov/forms/forms-repository/sf-424-family.
16 Some certifications in the HUD-424-B are also included in certifications at 24 CFR 91.225 (Local Governments),
24 CFR 91.325 (State Governments), and 24 CFR 91.425 (HOME Consortia). Both the HUD-424-B and certifications
required in the above-cited regulations must be submitted in their entirety. Submitting both sets of certifications
assures that your jurisdiction has met the Consolidated Plan and Annual Action Plan submission requirements.
17 Local Government template: https://www.hud.gov/sites/dfiles/CPD/documents/Non-State-Certifications.pdf
and State Government template: https://www.hud.gov/sites/dfiles/CPD/documents/State-Certifications.pdf.
Insular Areas and Non-Entitlement Hawaiian Counties should use the Local Government template.
18 See pp. 73–76 of the eCon Planning Suite Desk Guide: https://files.hudexchange.info/resources/documents/eCon-
Planning-Suite-Desk-Guide-IDIS-Conplan-Action-Plan-Caper-Per.pdf
13
3.2 Where must I list my actual grant amounts in my plan?
You must ensure that you list your actual grant amounts in your plan’s:
description of resources and objectives;
description of activities to be undertaken;
“method of distribution” (for State Governments only, regarding their CDBG funds;
24 CFR 91.320(k)(1)(i)); and
on all your SF-424 forms (the Application for Federal Assistance forms you must
submit for each of the five grant programs your jurisdiction participates in).
3.3 How must I submit my plan to HUD?
You must submit your plan in the Integrated Disbursement and Information System
(IDIS)—using the IDIS eCon Planning Suite.19 However, if you experience IDIS system
access issues, you may submit paper or digital copies to your CPD field office via mail,
email, or in person. If you mail documents, they must be postmarked by August 16.
3.4 Am I required to submit hard original copies of any documents or email digital
copies of any required documents to my CPD field office?
No. HUD strongly recommends you submit all documents in the IDIS eCon Planning
Suite. However, if you experience IDIS system access issues, and for the purposes of
helping grantees meet the August 16 deadline, HUD will accept hard copies (via mail
or in person) or digital copies (via email) submitted to your CPD field office.
NOTE : You are still required to submit your plan and documents in the IDIS eCon Planning Suite even
if you originally submit hard copies or email copies to your CPD field office.
3.5 What types of signatures on documents will HUD accept and who must sign?
Regardless of how you submit your documents (IDIS, in person, mailed, emailed), HUD
will accept both types of signatures below from your jurisdiction’s chief executive officer:20
traditional “wet” signatures (original copies or scanned copies) OR
“digital” or “electronic” signatures (must show verification the chief executive
officer completed the digital signature and the time and date stamp).
19 24 CFR 91.200(a) and 24 CFR 91.300(a) state that a complete Consolidated Plan consists of required information
“submitted in accordance with instructions prescribed by HUD (including tables and narratives), or in such other
format as jointly agreed upon” by HUD and the jurisdiction or state. This is the basis of HUD’s requirement that
grantees submit plans using the IDIS eCon Planning Suite. For more information, you may refer to Notice CPD-12-
009: Use of IDIS to Submit the Consolidated Plan or any successor Notice. This Notice provides a helpful overview
of the requirement for HUD grantees to submit consolidated planning submissions in IDIS.
20 Your “chief executive officer” is an elected official or legally designated official who has the primary
responsibility for the conduct of your governmental affairs. Examples of chief executive officers include the
mayor, county executive, board chairperson, or governor. For example, see 24 CFR 570.3.
14
3.6 If my jurisdiction was awarded a CDBG-DR or CDBG-MIT grant, are we required
to incorporate these grants into our Consolidated Plan/Action Plan?
Yes. States and CDBG Entitlement grantees awarded a CDBG-Disaster Recovery
(CDBG-DR) or CDBG-Mitigation (CDBG-MIT) grant must incorporate these grants into
their Consolidated Plans within a specified timeframe. CDBG-DR or CDBG-MIT grantees
should consult the applicable Federal Register (FR) Notices for their grant(s) for specific
guidance, as well as HUD’s new Universal Notice for CDBG Disaster Recovery Grantees.
Under HUD’s new “Universal Notice,” grantees must incorporate CDBG-DR funding into
their Consolidated Plan by submitting an Action Plan, or a substantial amendment to their
existing Annual Action Plan, within 24 months of the applicability date of the relevant
Allocation Announcement Notice (AAN). If your jurisdiction is not scheduled to submit
a new Consolidated Plan within the next two years, you must update your existing
Consolidated Plan to reflect your jurisdiction’s disaster-related needs no later than
24 months after the applicability date of the relevant AAN.
When the organization administering the CDBG-DR award is a different entity or agency
from that which administers the applicable State’s or Entitlement’s annual CDBG program,
these entities should coordinate to ensure that the annual CDBG program grantee updates
its Consolidated Plan accordingly.
3.7 What HUD resources are available to help me with preparing my plan?
Below are a few HUD resources to help you with preparing your plan:
HUD.gov Consolidated Planning Website
HUD Exchange Consolidated Plan Website
CPD Maps GIS Website
HUD Database of Consolidated Plans, Annual Action Plans, and CAPERs
Consolidated Plan Updates to Reflect Disaster Recovery and Mitigation Needs
and Associated Priorities
3.8 How do Opportunity Zones intersect with my plan(s)?
Created by the 2017 Tax Cut and Jobs Act, Opportunity Zones (OZs) are economically
distressed communities, defined by individual census tract, nominated by America’s
governors, and certified by the U.S. Secretary of the Treasury via their delegation of
that authority to the Internal Revenue Service (IRS). OZs are designed to stimulate
private investment in designated, low-income census tracts nationwide. Since the
passage of the law, 8,764 OZs were designated in all 50 states, Washington DC,
Puerto Rico, and several Insular Areas.21
21 https://www.hud.gov/opportunity-zones
15
3.8.1 Changes to OZ designation criteria under the One Big Beautiful Bill Act
OZ designations will change at the beginning of calendar year 2027 (and every ten
years thereafter), according to the provisions in the One Big Beautiful Bill Act of
2025 (OBBBA).22 OBBBA made the OZs program permanent by eliminating the
sunset date in the 2017 Tax Cut and Jobs Act and introduced new OZ requirements.
One major change under OBBBA is refining the definition of the term “low-income
community,” which will now mean any census tract where: (a) the poverty rate is at
least 20% and the median family income does not exceed 125% of the applicable
area median income OR (b) the median family income does not exceed 70% of the
applicable area median income (down from 80% in the 2017 Tax Cut and Jobs Act).
Additional changes to the OZ designation criteria in OBBBA include: 1) repealing
the ability to designate census tracts as OZs that were not low-income themselves
but were contiguous to a low-income tract and 2) requiring that at least 33% of OZs
must be rural areas. Under OBBBA, a rural area is considered any city or town with
a population less than 50,0000, excluding census tracts adjacent to a town or city
with more than 50,000 people.
3.8.2 Background on Opportunity Funds and tax incentives for investors
The OZs provisions of the tax code incentivize individuals and companies to invest
equity in real estate projects or in businesses located in OZs. It does so by enabling
individuals to temporarily defer and reduce their tax liability on investments in
privately- or publicly-managed Opportunity Funds. These Opportunity Funds
must invest funds in real estate projects or businesses located in designated OZs.
Moreover, if investors leave their investments in these funds long-term, the profits
they make on Opportunity Fund investments will not be taxed.
3.8.3 Guidance for CPD formula grantees on using grant funding in OZs
HUD issued Notice CPD-20-06, Guidance on Using HUD’s Community Planning
and Development Program (CPD) Funds in Opportunity Zones to encourage CPD
program grantees to consider the use of CDBG, HOME, ESG, HOPWA, and HTF
funds for eligible activities in OZs when developing their Consolidated Plans.
Also, when considering strategies to facilitate the use of CDBG and Section 108
Loan Guarantee funds in OZs, HUD encourages grantees to explore whether an
OZ, or a portion of an OZ, would also qualify as Neighborhood Revitalization
Strategy Areas (NRSAs) under Notice CPD-16-16. Compliance with certain
CDBG requirements can be streamlined through the designation of NRSAs that
may make it more feasible for grantees and their partners to leverage CDBG and
Section 108 Loan Guarantee funds more quickly in OZs.
22 Beginning July 1, 2026, governors of each state will propose (within 90 days) new census tracts every 10 years
to be designated as OZs. Qualified OZs will take effect January 1 of the following year and remain in force for 10
years under renewed eligibility standards. The first new designations for OZs will take effect January 1, 2027.
16
SECTION 4: HUD’S REVIEW OF YOUR PLAN
4.1 What standards does HUD use to review my plan?
HUD reviews your plan using the “standard of review” explained in 24 CFR 91.500(b).
In general, HUD reviews your plan for completeness and compliance with the consolidated
planning regulations (24 CFR Part 91). This includes, but is not limited to, reviewing
whether your plan:
was developed with required citizen participation and consultation;
contains all necessary elements; and
includes accurate certifications.
4.2 How long does HUD have to review my plan?
HUD has 45 calendar days after the day HUD received your submission to review your plan.
HUD will consider the day you submit your documents as “collection day” or “Day 0.”
Therefore, HUD’s 45-day review period begins the day after you submit your plan in the
IDIS eCon Planning Suite OR the day after your CPD field office receives copies of your
executed SF-424(s).23
Per 24 CFR 91.500(a), your plan will be deemed approved at the end of the 45th day after
HUD receives it, unless HUD notifies you before then that your plan is disapproved.
Per 24 CFR 91.500(c), within 15 days after HUD notifies your jurisdiction your plan is
disapproved, HUD must inform you in writing of the reasons for disapproval and actions
that you can take to meet the criteria for approval.
4.3 What happens if I submit a plan that contains estimated (not actual) grant amounts?
HUD will disapprove any plan that does not reflect your actual CDBG, HOME, HTF, ESG,
and HOPWA grant amounts for the FY on the SF-424 (Application for Federal Assistance),
in the description of resources and objectives, and in the description of activities to be
undertaken (or, for States, the method of distribution).
The basis for HUD’s disapproval is that your plan is “substantially incomplete” if it is
not based on, and does not contain, your actual grant amounts for the FY. If your plan
is disapproved for this reason, you must resubmit a revised plan to HUD after you
incorporate your actual grant amounts into your plan.
NOTE : The HTF allocation plan must be included if HUD publishes HTF allocations before you
submit your Consolidated Plan or Action Plan. GO TO SECTION 2.8 for more guidance on including
HTF allocation plans in your plan.
23 You are not required to mail hard original signed copies of your SF-424(s) to your CPD field office. Refer to
SECTIONS 3.3–3 .5 for more guidance on the acceptable submission formats of your plan.
17
4.4 What are the reasons HUD may disapprove my plan?
24 CFR 91.500(b) states HUD may disapprove your plan (or a portion) for three reasons:
1. If it is inconsistent with the purpose of the Cranston-Gonzalez National Affordable
Housing Act (42 U.S.C. 12703);
2. If it is substantially incomplete; or
3. In the case of a CDBG certification under 24 CFR 91.225(a) and 24 CFR 91.225(b)
or 24 CFR 91.325(a) and 24 CFR 91.325(b), if it is not satisfactory to the Secretary
of HUD in accordance with 24 CFR 570.304, 24 CFR 570.429(b), 24 CFR
570.440(e), or 24 CFR 570.485(c).
4.5 What are examples of plans that are “substantially incomplete”?
These four examples of substantially incomplete plans are provided at 24 CFR 91.500(b):
1. A plan developed without the required citizen participation or the required consultation;
2. A plan that fails to satisfy all the required elements in 24 CFR Part 91;
3. A plan for which a certification is rejected by HUD as inaccurate, after HUD has
inspected the evidence and provided due notice and opportunity to the jurisdiction
for comment; and
4. A plan that does not include a description of the manner in which the unit of general
local government or state will provide financial or other assistance to a public
housing agency if the public housing agency is designated as “troubled” by HUD.
4.6 When must I resubmit my plan if HUD disapproves my first submission?
24 CFR 91.500(d) states:“(t)he jurisdiction may revise or resubmit a Plan within 45 days
after the first notification of disapproval.” If HUD disapproves your first submission, this
regulatory provision does not prohibit you from re-submitting your plan beyond the 45 days
after HUD’s notification of disapproval. If your jurisdiction needs additional time to resubmit
beyond the 45 days, send a written request for additional time, including the justification for
the request, to your CPD field office. However, HUD must respond to approve or disapprove
your resubmitted plan within 30 days of receiving your revisions or resubmission.
4.7 Am I required to carry out additional citizen participation after making changes
to my plan because HUD disapproved my first submission?
24 CFR 91.105(c), 24 CFR 91.115(c) and 24 CFR 91.505 require grantees to comply with
citizen participation requirements when they undertake a “substantial amendment” to a plan
that is deemed approved. However, a plan that HUD has disapproved is, by definition, not
deemed approved. If HUD disapproved your plan, the consolidated planning regulations do
not require you to undertake further citizen participation on the changes you make before
resubmitting the plan to HUD. A major exception to this, however, is if the reason for HUD’s
disapproval involved your jurisdiction’s failure to meet citizen participation requirements.
18
4.8 How can I determine if I need to carry out additional citizen participation?
HUD encourages grantees to review their Citizen Participation Plan and local policies
to determine if their jurisdiction needs to carry out additional citizen participation.
24 CFR 91.500(b) states that a plan developed without the required citizen participation
or consultation is substantially incomplete. However, as HUD notes in this Notice, there
are sometimes circumstances in which a grantee may need to make major revisions to a
disapproved plan, which could trigger further citizen participation efforts.
If HUD disapproves your plan, you should review your jurisdiction’s Citizen Participation
Plan and other local policies to determine whether you will need to carry out additional
citizen participation because of the changes you must make to cure the deficiencies
identified by HUD.
19
SECTION 5: HOW TO MEET CITIZEN PARTICIPATION REQUIREMENTS
IN THE INTERIM BEFORE HUD ANNOUNCES GRANT ALLOCATIONS
5.1 Is my jurisdiction required to meet citizen participation requirements before
submitting my plan?
Yes. Before submitting your plan, you must satisfy the consultation and citizen participation
requirements described in 24 CFR Part 91.24 Your jurisdiction’s citizens must be provided
with 30 days to comment on Consolidated Plans, Action Plans, and “substantial
amendments”25 to those plans.
5.2 Is my jurisdiction allowed to expedite the citizen participation process?
No. Citizens in your jurisdiction must be provided 30 days to comment on your draft plan.
As a reminder, expedited citizen participation procedures (such as those authorized by the
CARES Act Notice)26 are no longer permissible. These expedited procedures were only
permitted due to the public health emergency of COVID-19.
5.3 What are my options for meeting my citizen participation requirements?
Your jurisdiction has two options for fulfilling your citizen participation obligations while
waiting for HUD to announce your grant allocations:
1. Option 1: Prepare your draft plan according to your normal timetable and carry
out your citizen participation for your plan using estimated funding amounts.
This approach requires you to explain that the plan is based on estimated
funding and add funding contingency provisions in your draft plan.
OR
2. Option 2: Prepare your draft plan according to your normal timetable but wait until
HUD announces your grant allocations before carrying out citizen participation.
This approach requires you to update your draft plan with your actual grant
amounts and then carry out citizen participation activities.
NOTE : This option is not feasible if you intend to incur “Pre-Award Costs” under the programs
covered by this Notice. This is because citizen participation requirements must be met before
Pre-Award Costs are allowed to be incurred.
24 For example, the consultation requirements outlined at 24 CFR 91.100 require local governments to consult
with various entities, including organizations that represent protected class members, those that enforce fair
housing laws, and public housing authorities (PHAs).
25 A substantial amendment is a significant change to your jurisdiction’s approved Consolidated Plan or
Action Plan. Grantees are required by regulations (e.g., 24 CFR 91.105 and 24 CFR 91.115) to define in
their own Citizen Participation Plan the specific criteria that constitute a substantial amendment.
26 Notice of Program Rules, Waivers, and Alternative Requirements Under the CARES Act for Community
Development Block Grant Program Coronavirus Response Grants, Fiscal Year 2019 and 2020 Community
Development Block Grants, and for Other Formula Programs, 85 Fed. Reg. 51457 (Aug. 20, 2020)
20
5.4 Option 1: Carry out citizen participation using estimated funding amounts
If you choose this option, you must make it clear that the funding levels shown in your draft
plan are estimated amounts. In addition, you should also include “contingency provision”
language in your draft Action Plan. Your contingency provision(s) will explain how you
will adjust your draft plan to match your actual grant amounts after HUD announces them.
NOTE : A draft plan that has not been submitted to HUD yet is not an approved plan. A draft plan must be
revised in accordance with your citizen participation requirements, which may not be the same as your
citizen participation requirements for a substantial amendment to a plan that is deemed approved. HUD
recommends reviewing your Citizen Participation Plan and local policies prior to submitting your plan to
determine whether you must carry out additional citizen participation because of changing your plan to
incorporate your actual grant amounts.
5.4.1 Adding contingency provisions in your draft plan
By including contingency language in your draft plan, you can avoid having to
make significant revisions to your plan after HUD announces CPD formula grant
allocations. The only revisions you would need to make would be to incorporate
your actual grant amounts into your plan and SF-424(s). With this approach, you
may also avoid the potential need to carry out additional citizen participation if your
plan must be significantly revised to reflect your jurisdiction’s actual grant amounts.
5.4.2 Examples of contingency provisions
You may include these or other comparable provisions singly or in any combination
to meet your jurisdiction’s needs. Your jurisdiction may also choose to adopt a
unique contingency approach for each program covered by this Notice.
1. Your plan could state that all proposed activities’ budgets will be increased
or decreased proportionally from the estimated funding levels to match
actual grant amounts.
2. Your plan could express its budget in terms of percentages of the grant amount
to be budgeted for each planned activity, along with the current estimate of
how many dollars that equates to, for each activity.
Examples: “Regardless of final allocation amounts, the United Interfaith
Street Outreach Program will receive 22 percent (currently estimated to be
approximately $38,000) of our ESG allocation.” OR “Regardless of final
allocation amounts, the Tenant-Based Rental Assistance activity will receive
10 percent (currently estimated as $68,750) of our HOME allocation.”
3. Your plan could state that any increase or decrease in funding to match actual
grant amounts will be applied to one or more specific activities.
Example: “Any increase or decrease relative to our estimated allocation amount
will be applied to the single-family housing rehabilitation grant program.”
21
4. Your plan could list proposed activities in priority order and indicate that the
activity may or may not be funded that FY based on availability of funds.
Example: “The East Side Sidewalk Replacement activity is a ‘backup’ activity
that will be funded only if sufficient CDBG funding exists,” OR conversely
“If our actual allocation is less than estimated, the East Side Sidewalk
Replacement activity will not be funded this FY.”
5. Your plan could state that, should your actual grant amount exceed your
estimate, you will increase the budget.
Example: “Should our actual grant amount be higher than estimated, we will
increase the Uptown Sewer Separation activity budget and extend the service
area block-by-block along the 600-900 blocks of Cherry Street, based on the
amount of additional funding available.”
5.5 Option 2: Carry out citizen participation after HUD announces grant allocations
If you choose this option, you will need to update relevant sections of your draft plan (after
HUD announces CPD formula grant allocations) to reflect your actual grant amounts before
you carry out citizen participation on your draft plan. GO TO SECTION 3 .2 for guidance on
where you must list your actual grant amounts in your plan.
As noted earlier, this option is not feasible or available if you intend to incur Pre-Award
Costs. This is because citizen participation requirements must be met before HUD allows
Pre-Award Costs to be incurred. GO TO SECTION 6 : GUIDANCE ON PRE -AWARD COSTS .
5.6 Why should I follow one of these options (described in Sections 5.4 or 5.5)?
HUD developed these two options (SECTIONS 5 .4 AND 5 .5) to minimize disruption and
duplication of effort for grantees. If you don’t follow either Option 1 or Option 2 above,
your jurisdiction risks increasing your own work obligations and costs.
Your jurisdiction will still be required to update your plan to incorporate your actual
grant amounts for HUD to approve your plan. And, depending on the requirements in
your Citizen Participation Plan, you may be required to undertake additional publication
and citizen participation processes based on the difference between your actual grant
amounts and the estimated grant amounts in your draft Action Plan. Local policies and
procedures may also require your jurisdiction to obtain re-approval of your revised plan
from your legislative body or chief executive officer.
22
SECTION 6: GUIDANCE ON PRE-AWARD COSTS
6.1 What are “Pre-Award Costs”?
As a grantee, you may want or need to incur costs against your next FY grant before you
can execute your Grant Agreement with HUD. These are called “Pre-Award Costs.” These
costs can be reimbursed with your future grant funds, provided the funded activity(ies)
meet all grant program-specific regulatory requirements and applicable 2 CFR Part 200
regulatory requirements for Pre-Award Costs.27
HUD generally allows Pre-Award Costs without a regulatory waiver or written approval.
However, under some circumstances for CDBG grantees (24 CFR 570.200(h)(2)), you
must obtain HUD’s written approval to incur Pre-Award Costs.
6.1.1 Example: Pre-Award Costs
For example, your jurisdiction may want to execute annual renewals of agreements
with social service providers (subrecipients) to prevent interrupting their delivery
of critical social services. The annual performance cycle of these agreements
might normally begin after your PY start date but, under the terms of this Notice,
you can’t submit your Action Plan until after the date that the agreements with
service providers needed to be executed.
In general, the timing instructions in this Notice may cause some program costs
to be classified as Pre-Award Costs where they would otherwise not have been.
6.2 What general provisions apply to all CPD formula program grantees?
If your jurisdiction wants to incur costs for your grants prior to executing your Grant
Agreement, you must pay special attention to regulations on Pre-Award Costs in:
2 CFR Part 200 (HTF, ESG, and HOPWA Programs)
24 CFR Part 570 (CDBG Program)
24 CFR Part 92 (HOME Program)
6.2.1 2 CFR Part 200 and Pre-Award Costs (HTF, ESG, and HOPWA Programs)
This section applies only to the HTF, ESG, and HOPWA programs. It does not apply
to the CDBG and HOME programs because those programs have unique Pre-Award
Cost requirements at 24 CFR 570.200(h) (CDBG) and 24 CFR 92.212 (HOME).
The government-wide Uniform Administrative Requirements, Cost Principles and
Audit Requirements regulation (2 CFR Part 200) includes the following provision
concerning agency approval of Pre-Award Costs:
27 See 2 CFR 200.210 and 2 CFR 200.458.
23
2 CFR § 200.458. Pre-award costs. Pre-award costs are those incurred
before the start date of the Federal award or subaward directly pursuant
to the negotiation and in anticipation of the Federal award where such
costs are necessary for efficient and timely performance of the scope of
work. These costs are allowable only to the extent that they would have
been allowed if incurred after the start date of the Federal award and only
with the written approval of the Federal agency. If approved, these costs
must be charged to the initial budget period of the Federal award unless
otherwise specified by the Federal agency or pass-through entity.
Conditional HUD approval of Pre-Award Costs
To minimize workload on grantees and HUD field offices, this Notice establishes
procedures implementing the 2 CFR 200.458 requirements. This Notice provides
conditional HUD approval of Pre-Award Costs once your jurisdiction has completed
and documented the five actions below. This conditional approval is contingent on
the availability, requirements, and authorized uses of the appropriations.
1. You have documented that the costs incurred prior to executing your grant
award are necessary for efficient and timely performance of the activity(ies).
2. You have documented that the costs are for eligible activities under the
regulations for the applicable funding program(s).
3. You have documented your jurisdiction’s compliance with all other requirements
for Pre-Award Costs under the regulations for your applicable program(s).
4. The activity for which costs will be incurred is included in your Consolidated
Plan and/or Action Plan.
5. You have documented that your citizen participation process has been completed
by including in your files a written, dated summary of comments received on
your plan, pursuant to 24 CFR 91.105(b)(5) (local governments) or 24 CFR
91.115(b)(5) (State governments).
6.2.2 Guidance on Pre-Award Costs applicable to all five grant programs
The following requirements apply to all five CPD formula grant programs. GO TO
SECTION 6 .4 for specific provisions on Pre-Award Costs for each program.
Pre-Award Costs are incurred at your own risk
Pre-Award Costs are incurred at your own risk because reimbursement is contingent
on the availability of FY appropriations, satisfying the conditions in this Notice, and
executing your grant agreement with HUD. Any commitments or expenditures your
jurisdiction incurs, which exceed the funds provided by your grant (and authorized
under the applicable FY appropriations law), would be your jurisdiction’s
responsibility to pay for using non-Federal funds.
24
“Proposed plans” vs. “plans” and meeting citizen participation requirements
Before you can incur Pre-Award Costs, your jurisdiction must have already met
citizen participation requirements. Consolidated planning regulations (24 CFR Part
91) make a distinction between “a proposed plan” and “a plan.” Notably, 24 CFR
91.105(b) and 24 CFR 91.115(b) describe citizen participation requirements for a
grantee’s proposed plan.
For the purposes of Pre-Award Costs, HUD considers your plan to have moved
from being “a proposed plan” to “a plan” once your jurisdiction has completed
the publication, public hearing, and public comment requirements at:
24 CFR 91.105(b)(2), 24 CFR 91.105(b)(3), and 24 CFR 91.105(b)(4); or
24 CFR 91.115(b)(2), 24 CFR 91.115(b)(3), and 24 CFR 91.115(b)(4); and
your jurisdiction has developed its written summary of comments received,
per 24 CFR 91.105(b)(5) or 24 CFR 91.115(b)(5).
Environmental review requirements
For CDBG, HOME, ESG, and HOPWA grantees, before you commit any funds
for a Pre-Award Cost—including non-Federal funds—you must either:
make a written determination that the Pre-Award Cost is for an activity
exempt from environmental review or categorically excluded and not
subject to review under related environmental laws and authorities under
24 CFR Part 58; OR
verify that the applicable environmental review has been completed
and a Request for Release of Funds has been approved in accordance
with 24 CFR Part 58, if applicable.
NOTE : Environmental regulations at 24 CFR 58.22 prohibit recipients and any other participants
in the development process from committing HUD funds to a project until the environmental
compliance review process has been successfully completed and until receipt of the Authority to
Use Grant Funds, if applicable. In addition, until the environmental compliance review process
has been successfully completed and until receipt of the Authority to Use Grant Funds, neither a
recipient nor any participant in the development process may commit non-HUD funds on or
undertake an activity or project if the activity or project would have an adverse environmental
impact or limit the choice of reasonable alternatives.
6.3 Do I need a regulatory waiver to incur Pre-Award Costs for CDBG or HOME grants?
No. In previous FYs and prior versions of this Notice, HUD attached a regulatory waiver
concerning Pre-Award Costs for CDBG grantees and HOME PJs. However, under the
new 2025 HOME rule,28 regulatory provisions at 24 CFR Part 570 and 24 CFR Part 92
were updated to account for the late appropriation issue, which impacted Pre-Award
28 HOME Investment Partnerships Program: Program Updates and Streamlining, 90 Fed. Reg. 746 (Jan. 06, 2025)
25
Costs for the CDBG and HOME programs. The regulatory waiver HUD attached in prior
Consolidated Plan Notices is no longer necessary.
In the new HOME rule, HUD added a new 24 CFR 570.200(h)(3) to make the effective
date of the Grant Agreement, in a year when an annual appropriation occurs less than ninety
days before a grantee’s PY start date, the earlier of either the PY start date or the date that
the Consolidated Plan is received by HUD. This change better aligns CDBG with the new
HOME program regulation at 24 CFR 92.212(b)(2) and continues practices implemented
through the annual regulatory waivers attached to prior Consolidated Plan Notices.
6.4 What specific provisions apply for each of the five CPD formula grant programs?
6.4.1 CDBG Program: Specific Pre-Award Costs provisions
CDBG Program regulations at 24 CFR 570.200(h) specify when CDBG grantees
may be reimbursed for Pre-Award Costs. CDBG grantees intending to incur Pre-
Award Costs are cautioned that waiting for your actual grant amounts before
carrying out citizen participation for your plan(s) is not likely a feasible alternative
(this is Option 2 described in SECTION 5.5 ). If you intend to incur Pre-Award
Costs, you should carry out citizen participation for your plan(s) using estimated
grant amounts (this is Option 1 in SECTION 5.4 ).
1. 24 CFR 570.200(h) defines the effective date of your CDBG grant agreement
as either 1) your jurisdiction’s PY start date OR 2) the date that your
Consolidated Plan/Action Plan is received by HUD (whichever is later).
However, the effective date of your grant agreement may also be modified
based on 24 CFR 570.200(h)(3), which states: “In a Federal fiscal year when
an annual appropriation is signed into law less than 90 days before a grant
recipient’s program year start date, the effective date of the grant agreement
will be the earlier of the recipient’s program year start date or the date that
the Consolidated Plan incorporating the recipient's allocation amount for the
Federal fiscal year is received by HUD.”
2. 24 CFR 570.200(h)(1) identifies a list of conditions under which Pre-Award
Costs are eligible for CDBG grantees and subrecipients.
3. 24 CFR 570.200(h)(2) identifies two circumstances in which a CDBG grantee
must obtain written approval (waivers) from HUD authorizing payment for
Pre-Award Costs. These circumstances are if CDBG grantees seek to:
1) make payments for Pre-Award Costs after the first two program years
following the effective date of their grant agreement (waiver for 24 CFR
570.200(h)(1)(v))
2) exceed the total dollar amount of Pre-Award Costs that may be paid
during any program year (waiver for 24 CFR 570.200(h)(1)(vi))
26
6.4.2 HOME Program: Specific Pre-Award Costs provisions
HOME Program regulations (24 CFR 92.212) specify when a PJ may be reimbursed
for Pre-Award Costs. Under 24 CFR 92.212(d), PJs can also authorize subrecipients
or State recipients to incur these Pre-Award Costs with written authorization.
1. Pre-Award admin and planning costs: 24 CFR 92.212(b)(1) states that HOME
PJs may incur eligible administrative and planning costs as of the beginning
of their consolidated program year (PY start date) OR 2) the date that their
Consolidated Plan is received by HUD (whichever is later). However, this
may be modified by 24 CFR 92.212(b)(2), which states: “In any year in
which an appropriation has not been enacted 90 days before a participating
jurisdiction’s program year start date, a participating jurisdiction may incur
eligible administrative and planning costs as of the beginning of its program
year or the date that HUD receives its consolidated plan describing the
HOME allocation to which the costs will be charged, whichever is earlier.”
(Emphasis added.)
2. Pre-Award Project Costs: 24 CFR 92.212(c) allows PJs to incur eligible
project costs before executing their HOME grant agreement, which allows
PJs to initiate projects earlier. These project costs are charged to the PJ’s next
FY grant and are capped at 25% of the PJ’s current FY grant. PJs must
comply with citizen participation requirements, create a “mini-action plan”
detailing proposed projects and costs, and ensure all costs meet HOME
requirements, including environmental reviews. PJs may also seek a waiver
from their local CPD field office to exceed these allowable project cost
amounts, per 24 CFR 92.212(e).
6.4.3 HTF Program: Specific Pre-Award Costs provisions
HTF grantees may be reimbursed for Pre-Award Costs permitted under 2 CFR
200.458 for planning activities and preparation of the HTF allocation plan.
Eligible Pre-Award Costs may include the cost of public hearings, consultations,
and publication of public notices, as well as developing program guidelines. Such
costs must be necessary for efficient and timely performance of the HTF Program.
The costs and corresponding activities must comply with all HTF requirements,
including environmental review requirements at 24 CFR 93.301(f).
6.4.4 ESG Program: Specific Pre-Award Costs provisions
An ESG grantee may be reimbursed for costs incurred before their grant’s period
of performance, subject to the general conditions described in SECTION 6 .2 , plus
these conditions:
1. Other than the date they are incurred, the costs and corresponding activities
must comply with the ESG Program regulations at 24 CFR Part 576.
27
2. The costs and corresponding activities must comply with environmental review
requirements. In accordance with these requirements and section 100261(3) of
the MAP-21 Act, 24 CFR 576.407(d) does not apply. Recipients assume
environmental review responsibilities under 24 CFR Part 58.
6.4.5 HOPWA Program: Specific Pre-Award Costs provisions
A HOPWA formula grantee may be reimbursed for costs incurred before the period
of performance of its grant, subject to the general conditions described in SECTION
6 .2 , plus these conditions:
1. Other than the date they are incurred, the costs and corresponding activities
must comply with HOPWA Program regulations at 24 CFR Part 574.
2. The costs and corresponding activities must comply with environmental
review requirements at 24 CFR 574.510 and 24 CFR Part 58.
estimate*estimate*estimate*estimate*estimate*estimate*
Dept. ##
Budgete
d Class FT/PT Hours Filled As Percentag
e CDBG
Percentag
e HOME ESG EGLE CHIP HOME
ARP
Project
Service
Project
Service
MHSHDA/
HEP Percent
1060701 FTE 1040 CDBG, HOME & ESG 50 35 5 0 0 10 0 0 0 100
1020615 FTE 1664 CDBG, HOME & ESG 50 30 5 5 5 5 0 0 0 100
1060701 FTE 2080 CDBG, HOME & ESG 40 30 5 2.5 2.5 20 0 0 0 100
1060701 FTE 2080 CDBG, HOME & ESG 60 25 5 1 1 8 0 0 0 100
1060701 FTE 2080 CDBG, HOME & ESG 60 20 0 0 0 20 0 0 0 100
1060702 FTE 2080 CDBG, HOME & ESG 85 0 10 0 0 0 0 0 5 100
1060702 FTE 2080 CDBG, HOME & ESG 85 0 10 0 0 0 0 0 5 100
1060702 FTE 2080 CDBG, HOME & ESG 85 0 10 0 0 0 0 0 5 100
1060701 FTE 2080 CDBG & HOME 100 0 0 0 0 0 0 0 0 100
1060701 FTE 2080 CDBG & HOME & ESG 80 20 0 0 0 0 0 0 0 100
1060701 FTE 2080 CDBG & HOME 60 30 0 2.5 2.5 5 0 0 0 100
1060701 FTE 2080 CDBG & HOME 35 20 0 2.5 2.5 0 20 20 0 100
1060701 FTE 2080 CDBG & HOME 35 20 0 2.5 2.5 0 20 20 0 100
1060701 FTE 2080 CDBG & HOME 35 20 0 2.5 2.5 0 20 20 0 100
1060701 FTE 2080 CDBG & HOME 50 30 0 0 0 20 0 0 0 100
1060701 FTE 2080 CDBG & HOME 40 35 0 2.5 2.5 0 10 10 0 100
1060701 FTE 2080 CDBG & HOME 40 35 0 2.5 2.5 0 10 10 0 100
1060701 FTE 2080 CDBG & HOME 40 35 0 2.5 2.5 0 10 10 0 100
1060701 FTE 2080 CDBG & HOME 40 35 0 2.5 2.5 0 10 10 0 100
1060701 FTE 2080 Assistant CDBG, HOME & ESG 50 40 0 0 0 10 0 0 0 100
1060701 Student**PTNE 1250 CDBG, HOME & ESG 50 40 10 0 0 0 0 0 0 100
* The percentage of hours allocated to each grant is an estimate. Hours charged to grants is dictated by grant activities
FY26 Special Revenue Grant
Schedule B - Continuations (PY2026 Con Plan & AAP)
Dept. #
1060701 P00003430 Neighborhood & Housing Development Coordinator FTE 2080 Eligibility Coordinator CDBG and HOME
1060701 P00003231 Neighborhood & Housing Development Coordinator FTE 2080 Eligibility Coordinator CDBG and HOME
1060701 P00009578 Neighborhood & Housing Development Specialist FTE 2080 Specialist CDBG
Request to remove the following positions: