CDBG-DR Action Plan Draft

CONTENTS
1. Executive Summary ................................................................................................................. 1
1.1 Overview ......................................................................................................................... 1
1.2 Disaster-Specific Overview ........................................................................................... 1
1.3 Summary ......................................................................................................................... 5
1.3.1 Needs Assessments and Guiding Principles .......................................................... 5
1.3.2 CDBG-DR Budget ...................................................................................................... 6
1.4 Unmet Needs and Proposed Allocations ................................................................... 8
2. Unmet Needs Assessment ....................................................................................................... 8
2.1 Overview ............................................................................................................................. 8
2.1.1 Unmet Recovery Needs ........................................................................................... 9
2.1.2 Ongoing Hazards and Risks ................................................................................... 11
2.1.3 HUD-Identified Most Impacted and Distressed Areas ....................................... 12
2.1.4 Grantee-Identified Most Impacted and Distressed Areas ................................ 13
2.2 Housing Unmet Needs ..................................................................................................... 14
2.2.1 Disaster Damage and Impacts Summary of Need............................................ 15
2.2.2 Affordable Housing Shortage and Rising Costs .................................................. 18
2.2.3 Role of Manufactured Housing as Affordable Housing in Oregon ................. 21
2.2.4 Labor Shortages and Increased Costs of Residential Construction ................ 23
2.2.5 Single-Family vs. Multifamily Needs: Owner Occupied vs. Tenant .................. 25
2.2.6 Public Housing and Affordable Housing .............................................................. 28
2.2.7 Social Equity, Fair Housing, and Civil Rights......................................................... 32
2.3 Infrastructure Unmet Needs............................................................................................ 63
2.3.1 Statewide Infrastructure Loss and Damages ...................................................... 63
2.3.2 FEMA Programs ....................................................................................................... 65
2.3.3 Hazard Mitigation Grant Program ........................................................................ 67
2.3.4 FEMA Public Assistance Program.......................................................................... 68
2.3.5 Total Cost and Need by PA Category................................................................. 68
2.3.6 Approximate Recovery Cost per Agency .......................................................... 69
2.3.7 Hazard Mitigation Needs per County or Known Project ................................... 69

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 2.4 Economic Revitalization Unmet Needs......................................................................... 70
2.4.1 Disaster Damage and Impacts............................................................................. 70
2.4.2 Total Business Loans Approved by the SBA ......................................................... 74
2.4.3 SBA Applicant Breakdown..................................................................................... 75
2.4.4 Estimating Business Losses ...................................................................................... 76
2.4.5 Increased Occupation Demands ........................................................................ 76
2.5 Mitigation Only Activities ................................................................................................ 76
2.5.1 Overview .................................................................................................................. 76
2.5.2 Mitigation Needs Assessment Data and Methodology .................................... 77
2.5.3 Top Risks Impacting the HUD Most Impacted and Distressed Areas ............... 83
2.5.4 Mitigation Needs Assessment Conclusion ......................................................... 104
3. General Requirements ......................................................................................................... 105
3.1 Citizen Participation....................................................................................................... 105
3.1.1 Outreach and Engagement ............................................................................... 105
3.1.2 Public Hearings ...................................................................................................... 111
3.1.3 Complaints and Appeals..................................................................................... 111
3.2 Public Website ................................................................................................................ 112
3.3 Amendments .................................................................................................................. 113
3.3.1 Substantial Amendment ...................................................................................... 114
3.3.2 Non-Substantial Amendment.............................................................................. 115
3.4 Displacement of Persons and Other Entities .............................................................. 115
3.5 Protection of People and Property ............................................................................. 116
3.5.1 Elevation Standards .............................................................................................. 116
3.5.2 Flood Insurance Requirements ........................................................................... 118
3.5.3 Construction Standards ....................................................................................... 119
3.5.4 Contractors’ Standards........................................................................................ 120
3.5.5 Preparedness, Mitigation, and Resilience ......................................................... 121
3.5.6 Broadband Infrastructure in Housing ................................................................. 125
3.5.7 Cost-Effectiveness ................................................................................................. 126
3.5.8 Duplication of Benefits ......................................................................................... 126
4. Grantee Proposed Use of Funds ......................................................................................... 127
4.1 Overview ......................................................................................................................... 127

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 4.2 Program Budget ............................................................................................................. 127
4.3 Connection to Unmet Needs ....................................................................................... 128
4.4 Leveraging Funds ........................................................................................................... 129
4.4.1 State Funding ........................................................................................................ 129
4.4.2 Federal Assistance and Private Insurance ........................................................ 133
4.4.3 Total Unmet Needs After Leveraging Other Funding ...................................... 134
4.5 Program Partners............................................................................................................ 135
4.6 Distribution of Funds ....................................................................................................... 135
4.6.1 Additional Details in the Program Descriptions ................................................ 135
4.7 Program Income ............................................................................................................ 136
4.8 Resale or Recapture ...................................................................................................... 137
5. Program Details..................................................................................................................... 138
5.1 Housing ............................................................................................................................ 138
5.1.1 Connection to Unmet Needs .............................................................................. 138
5.1.2 Homeowner Assistance and Reconstruction Program ................................... 139
5.1.3 Homeownership Opportunities Program ........................................................... 147
5.1.4 Intermediate Housing Assistance ....................................................................... 157
5.2 Infrastructure ................................................................................................................... 160
5.2.1 Disaster Resilience Infrastructure Program ........................................................ 160
5.3 Public Services ................................................................................................................ 164
5.3.1 Housing and Recovery Services ......................................................................... 164
5.3.2 Legal Services ........................................................................................................ 169
5.4 Planning and Administrative Costs .............................................................................. 172
5.4.1 Community Planning and Revitalization Program ........................................... 172
5.4.2 Administrative Costs ............................................................................................. 175
6. Appendix ............................................................................................................................... 176
6.1 Certifications................................................................................................................... 176
6.2 Waivers ............................................................................................................................ 179
6.2.1 Extension of Tenant-Based Rental Assistance ................................................... 179
6.2.2 Applicability of the Davis-Bacon and Related Acts, Section 3, and Section
504 to Ongoing or Pre-Award Non-Residential and Non-Commercial Construction
Work ................................................................................................................................. 179

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 6.2.3 Section 104(d) One-for-One Replacement of Lower Income Dwelling Units
.......................................................................................................................................... 180
6.3 Summary and Response to Public Comments .......................................................... 180
6.4 Data Sources/Methodologies ...................................................................................... 180
6.4.1 Housing Unmet Needs Calculation .................................................................... 180
6.4.2 Data Sources Referenced in the Action Plan ................................................... 187
6.5 Important Definitions and Terms .................................................................................. 191

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1. Executive Summary
1.1 Overview
The U.S. Department of Housing and Urban Development (HUD) announced that the
State of Oregon (State or grantee) will receive $422,286,000 in funding to support
long-term recovery and mitigation efforts following the 2020 Wildfires (DR-4562) through
the Oregon Housing and Community Services Department (OHCS). Community
Development Block Grant – Disaster Recovery (CDBG-DR) funding is designed to
address the needs that remain after all other assistance has been exhausted. This plan
details how funds will be allocated to address the remaining unmet needs in Oregon.

To meet disaster recovery needs, the statutes making CDBG-DR funds available have
imposed additional requirements and authorized HUD to modify the rules that apply to
the annual CDBG program to enhance flexibility and allow for a quicker recovery.
HUD has allocated $422,286,000 in CDBG-DR funds to the State of Oregon in response to
2020 Wildfires (DR-4562) through publication in the Federal Register, Vol. 87, No. 23,
February 3, 2022 (87 FR 6364). This allocation was made available through the Disaster
Relief Supplemental Appropriations Act of 2022 (Pub. L. 117-43), approved on
September 30, 2021 (the Appropriations Act).

1.2 Disaster-Specific Overview

A disaster was presidentially declared on September 15, 2020, although the 2020
Wildfires engulfed large parts of Oregon beginning September 7, 2020, through the
main containment date of November 3, 2020. In total, 20 out of Oregon’s 36 counties
were included in the disaster declaration under DR-4562. These counties were eligible
for different Federal Emergency Management Agency (FEMA) programs based on the
impacts of the disaster, as demonstrated in Figure 1.

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Figure 1: FEMA DR-456 2 Presidentially Declared Disasters, by County

On September 8, 2020, Oregon’s wildfire season was exacerbated by a historically

extreme wind event. Extremely dry 25- to 50-mile per hour (mph) winds (with gusts up to
60 mph) spread throughout Oregon. The gale force winds downed power lines and
toppled trees, which sparked new fires and made existing fires spread faster than
firefighters could contain.

It was not just the extreme wind in Oregon that caused the fires to spread so quickly. In
2020, most of Oregon was classified as being under severe drought. This resulted in low
moisture content vegetation (fuel loads), making the landscape more receptive to
igniting and burning more quickly and intensely than previous wildfires in Oregon.

In total, the DR-4562 event included 21 fires and burned more than 1.2 million acres.
Five of the fires grew into megafires, defined as fires that burn areas larger than
100,000 acres. Oregon had never experienced more than one fire over 100,000 acres
during a fire season in the State’s recorded history. All major fires were contained by
early December 2020.

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Figure 2 provides a map of the burn scar areas from the 2020 Wildfires that occurred
through November 2020.

Figure 2: 2020 Wildfires: Map of Burn Scar Areas

The largest and most destructive of the 2020 fires included the following:

• The Archie Creek fire in Douglas County burned more than 131,000 acres and
destroyed more than 100 homes between September 7, 2020, and a containment
date of November 16, 2020.
• The Holiday Farm fire in Lane and Linn counties burned more than 170,000 acres and
destroyed more than 700 structures between the start date on September 7, 2020,
and a containment date on November 23, 2020.

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• The Beachie Creek and Lionshead fires started as separate fires on August 16, 2020,
and merged in Clackamas, Linn, and Marion counties on September 8, 2020.
The two fires combined to burn nearly 400,000 acres and more than 1,000 structures.
• The Riverside fire in Clackamas County that burned from September 8 to December
3, 2020, destroyed more than 100 structures.
• The Almeda Fire in Jackson County lasted just 6 days, from September 8 to
September 14, 2020, and burned around 3,000 acres. Despite the relatively small size
and short duration, the fire destroyed 2,500 homes.

Overall, more than 40,000 residents had to evacuate and more than 500,000 were
placed on an evacuation notice. More than 4,300 homes were damaged or destroyed.
Of the 4,300 homes burned, nearly half were manufactured homes.

In addition to the fires’ impacts on homes and residents, they damaged roads,
streetlights, irrigation systems, electrical lines, water delivery systems, and other public
infrastructure. Indeed, at least 923 nonresidential buildings across seven counties were
damaged or destroyed. Nine State highways and two interstate highways were forced
to close due to fire hazards and many remained closed for extended periods of time
due to damage. In Lane County alone, a reported 246,000 consumers were without
power, either from public safety power shutoffs or damage to utility infrastructure, and
more than 40 miles of electrical infrastructure required complete replacement. In
addition, a communications tower on Mt. Hagen was destroyed, resulting in several
citizens not receiving evacuation notices, while damage to the Blue River Water District
delivery system resulted in the loss of potable water service to roughly 400 people.

Fire stations in McKenzie Bridge, White City, and Phoenix were damaged or destroyed
by fire. Several towns in Jackson County, including Phoenix and Talent, suffered
significant damage to roads, street signs, and guardrails, and the county lost several
vehicles, outbuildings, tools, and equipment. Among the hardest hit towns, Phoenix
suffered damages involving every category of work, including those to police patrol
units, public buildings, waterlines, playgrounds, benches, picnic tables, and park
restrooms, and the Southern Oregon Education Service District lost its entire 35,000-
square foot campus. The fires also left behind more than 90,000 hazardous burned trees,
as well as ash and debris, which needed to be removed to allow for reconstruction,
with many such trees threatening public safety or impeding roads. All told, preliminary
damage assessments conducted as part of the FEMA Public Assistance Program
estimate more than $114 million in permanent work across categories C through G.

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Information for this section was extracted from the following sources:

• 2020 Oregon Wildfire Spotlight

• Oregon Office of Emergency Management Wildfire Dashboard
• Oregon Wildfire Response and Recovery

1.3 Summary
1.3.1 Needs Assessments and Guiding Principles
To develop the CDBG-DR Public Action Plan, OHCS engaged State and federal
agencies, local governments, nonprofit organizations, housing-specific workgroups, the
Housing Stability Council, public housing authorities, tribal governments, community-
based organizations, community action agencies, long-term recovery groups, and
other ad hoc work groups focused on recovery. Engagement with these organizations
started in September 2020, in the middle of the wildfires, through the National Disaster
Recovery Framework led by FEMA, the Office of Emergency Management, and other
federal and State agencies; the State’s Disaster Housing Task Force; and other response
and recovery support functions, committees, and workgroups. OHCS and HUD also
collected information and feedback through surveys and local engagement
associated with the development of the State’s Housing Impact Assessment and the
State’s Disaster Housing Recovery Action Plan. OHCS expanded this engagement by
presenting the preliminary unmet needs assessment to state agencies, Tribal and local
governments, wildfire recovery work groups, community based organizations and the
State's Housing Stability Council after the announcement of the CDBG-DR
appropriation in September 2021 through April 2022. The State will hold its public
comment period from May 2, 2022 through June 1, 2022, and the State will ensure that
all hearings are recorded and made available to the public. This CDBG-DR Action Plan
includes an unmet and mitigation needs analysis, as well as recovery and mitigation
programming, which reflect the best available data at the time of publication.

OHCS understands that these data may not comprehensively represent the entire
impact and full spectrum of need across the HUD-identified most impacted and
distressed (MID) and other presidentially declared disaster areas. Therefore, public and
stakeholder engagement will remain ongoing as program policies and procedures are
drafted and implemented to ensure that CDBG-DR programs are accessible to and
benefit households and individuals who have not yet been included in the needs
assessment and who may be marginalized from accessing resources.

For the development of the CDBG-DR Action Plan and its CDBG-DR programs, OHCS
drew on the agency mission and vision; the goals and principles included in OHCS’s
Statewide Housing Plan, the Oregon Disaster Housing Task Force’s Housing Recovery
Action Plan, and the final report of the Governor’s Wildfire Economic Recovery Council;

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feedback from the Housing Stability Council, local governments, and community-based
organizations; and HUD’s published guidance. Drawing on all of these sources, OHCS
has determined that advancing equity and resilience are the two primary pillars and
guiding principles for Oregon’s CDBG-DR program development. The State of Oregon is
committed to equity and resilience as pillars of recovery and will incorporate these
guiding principles into each of its CDBG-DR programs:

• Advancing equity and racial justice and supporting underserved communities.

• Rebuilding homes and communities so that they are more resilient to current and
projected hazards.
Based on the assessment made to date, the 2020 Wildfires severely damaged or
destroyed more than 4,300 housing units across eight counties and burned more than
1.2 million acres across 20 out of Oregon’s 36 counties, leaving behind a trail of
devastated homes, public infrastructure, forests, watersheds, and businesses. Based on
the Unmet Needs Assessment, the State has calculated a total of nearly $1.9 billion in
housing, infrastructure, economic revitalization, and mitigation recovery needs. This
estimate is incomplete. For instance, per HUD-guidance the State drew on Small
Business Administration (SBA) datasets to understand the losses experienced by
businesses, but only 136 of hundreds of impacted businesses applied for SBA assistance.
The State continues to work with local governments to calculate a more accurate
value of unmet infrastructure and economic revitalization needs. This number includes
an alternate methodology for calculating the housing recovery need, which is
reflected in the Data and Methodology section of this Action Plan. At the time of the
assessment, the State has identified under $1.5 billion in other federal, State, and private
insurance resources available to meet the recovery needs of the State, leaving a total
projected unmet need of over $440 million. This estimate also includes over $1 billion in
private insurance proceeds, which includes an unknown amount of insurance provided
for personal contents, vehicles, and other activities that were not included in the needs
calculation. Therefore this estimate is projected to be conservative in estimating the
actual costs for long-term recovery from the 2020 Wildfires.

1.3.2 CDBG-DR Budget

The Federal Register Allocation Announcement and Consolidated Notices (Notices)
require HUD grantees to address unmet needs associated with the rehabilitation,
reconstruction, and new construction of affordable housing and housing for vulnerable
populations. Vulnerable populations are defined by HUD as a group or community
whose circumstances present barriers to obtaining or understanding information or
accessing resources. The Federal Register Notice also requires grantees to demonstrate
a reasonably proportionate allocation of resources relative to areas and categories
(i.e., housing, economic revitalization, and infrastructure) of greatest needs identified in
the impact and unmet needs assessment or provide an acceptable justification for a
disproportionate allocation.

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The Notices also include the following expenditure requirements, which are reflected in
Table 1:

• Program Administration Costs: Limited to 5%—or $21,114,300—of the total allocation.

• Mitigation Activities: At least 15%—or $55,081,000—must be used for mitigation
activities and/or through the incorporation of mitigation measures into recovery
activities. The State plans on incorporating resilience and mitigation measures into all
construction and planning programs. The State will define mitigation activities and
establish mitigation measures within each program.
• HUD-Identified Most Impacted and Distressed (MID) Areas: At least 80%—or
$337,828,800—of the total allocation must benefit the HUD-identified areas.
This includes 80% of expenditures for program administration.
• Benefit to Low- to Moderate-Income (LMI) Persons: At least 70%—or $280,820,190—
of the allocation (less planning and administration costs) must be used for activities
that benefit LMI persons.

The table below summarizes how the State estimates it will meet or exceed HUD’s
expenditure requirements. Actual expenditures will be tracked and reported publicly on
the CDBG-DR website. Descriptions of how these funding decisions reflect the Unmet
and Mitigation Needs Assessments and the State’s guiding principles are included
within each of the program descriptions further below in the Action Plan.

Table 1: Oregon’s CDBG-DR Program Allocation

Est. % to
Est. % to HUD
% of Total Mitigation Defined Est. % to
Program $ Allocation Allocation Activities MID areas LMI
Housing $340,995,945 80.8% 76% 99% 85%
Homeowner Assistance $204,597,567 48.5% 80% 99% 85%
and Reconstruction
Program
Homeownership $119,348,581 28.3% 80% 99% 85%
Opportunities Program
Intermediate Housing $17,049,797 4.0% 0% 99% 85%
Assistance
Infrastructure $40,117,170 9.5% 100% 99% 25%
Disaster Resilience $40,117,170 9.5% 100% 99% 25%
Infrastructure Program
Public Services $12,035,151 2.9% 0% 99% 95%
Housing and Recovery $6,017,576 1.4% 0% 99% 95%
Services
Legal Services $6,017,575 1.4% 0% 99% 95%

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 Est. % to
Est. % to HUD
% of Total Mitigation Defined Est. % to
Program $ Allocation Allocation Activities MID areas LMI
Planning $8,023,434 1.9% 100% 99% N/A
Community Planning $8,023,434 1.9% 100% 99% N/A
and Revitalization
Program
Administration $21,114,300 5% N/A 99% N/A
Total $422,286,000
% of Total 100% 100% 77% 99% 79%

1.4 Unmet Needs and Proposed Allocations

Table 2: Unmet Needs and Proposed Allocations
Program
Remaining % of Unmet Allocation % of Program
Category Unmet Needs Needs Amounts* Allocation
Housing $242,758,000 55% $340,995,945 80.8%
Infrastructure $171,300,000 38% $40,117,170 9.5%
Economic Revitalization $29,974,000 7% $0 0%
Public Services N/A N/A $12,035,151 2.9%
Planning N/A N/A $8,023,434 1.9%
Administrative Costs N/A N/A $21,114,300 5.0%
Total $444,032,000 100% $422,286,000 100%
* Program allocation amounts include project delivery costs.

2. Unmet Needs Assessment

2.1 Overview
This section follows U.S. Department of Housing and Urban Development (HUD)
requirements and details the losses and needs resulting from the 2020 Wildfires,
including the unmet housing, infrastructure, economic revitalization, and mitigation
needs. The information collected through the unmet recovery and mitigation needs
assessment process serves as the foundation for the State’s Community Development
Block Grant – Disaster Recovery (CDBG-DR) program funding and prioritization
decisions. To prepare this assessment, the Oregon Housing and Community Services
Department (OHCS) consulted with and drew on data from the following organizations:

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• Federal Emergency Management Agency (FEMA)
• Small Business Administration (SBA)
• HUD
• US Department of Agriculture
• Oregon Office of Emergency Management (OEM)
• Oregon Department of Land Conservation and Development (DLCD)
• Oregon Department of Environmental Quality
• Oregon Department of Human Services
• Oregon Employment Department
• Oregon Department of Consumer and Business Services
• Oregon Department of Energy
• Business Oregon
• Oregon builders and builders’ associations
• Local and Tribal governments
• Public housing authorities
• Long Term Recovery Groups

• Community Based Organizations

2.1.1 Unmet Recovery Needs

Table 3 provides a summary of disaster impacts using federally available data from
DR-4562 using an SBA–FEMA multiplier methodology that is similar to the one outlined in
the Federal Register Notice(described in the Data and Methodology section of this
Action Plan), as well as the methods for estimating unmet infrastructure and economic
revitalization needs described in the Federal Register Notice. The unmet need is
calculated by subtracting the resources available from the value of the total damages.
However, the “Other Resources Available” includes private insurance paid claims for
personal contents, loss of vehicles, and other expenses that are not included in the
“Total Impact assessment.” This assessment significantly undervalues the remaining costs
of damages and repairs from DR-4562.

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Table 3: HUD Unmet Needs Methodology
Unmet Need (Total Impact
Other Resources minus Anticipated
Category Total Impact Available Available Resources)
Housing $248.076 M $1,126.953 M $(878.88) M
Infrastructure $259.72 M $238.43 M $21.29 M
Economic Revitalization $32.089 M $126.37 M $(94.28) M
TOTAL $539.89 M $1,491.75 M $(951.87) M

Table 4 provides a summary of disaster impacts from DR-4562 using an alternative

methodology (described in the Data and Methodology section of this Action Plan) that
considers the costs of recovering resiliently and equitably, given the affordable housing
recovery needs and current increased reconstruction costs faced in the MID areas.
This methodology is more reflective of the actual unmet need, which the State
anticipates exceeds $443 million. However, the “Other Resources Available” includes
private insurance paid claims for personal contents, loss of vehicles, and other expenses
that are not included in the “Total Impact assessment.” Therefore, the State anticipates
this unmet need to undervalue the unmet recovery needs.

Table 4: Alternative Unmet Needs Methodology

Unmet Need
(Total Impact
Resources less Applied % of
Category Data Source Total Impact Available Resources) Total
Housing Estimated $1,318.697 M $1,126.953 M $241.758 M 55%
Reconstruction or
Replacement of
Damaged Housing
Units
Infrastructure FEMA Public $130.533 M $102.156 M $28.377 M 6%
Assistance (Cat
C-G + 15%
Resilience)
FEMA Hazard $129.188 M $136.269 M $(7.081) M (2)%
Mitigation Grant
Program
Additional Resilient $281.965 M $131.965 M $150 M 34%
Infrastructure Needs
Economic SBA – Commercial $32.089 M $1.994 M $29.974 M 7%
Revitalization Loss

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 Unmet Need
(Total Impact
Resources less Applied % of
Category Data Source Total Impact Available Resources) Total
Additional Assessment $124.378 M
Commercial Losses – still underway
Line Item not
Included in
Calculation
TOTAL $1,892.47 M $1,499.34 M $443.03 M 100%

2.1.2 Ongoing Hazards and Risks

Wildfires have become more common and widespread in Oregon over the past few
decades, and they often threaten communities where development (including
housing) encroaches upon forest lands that are susceptible to fire. The total area
burned by wildfire in the United States, including in Oregon, has increased significantly
since the 1980s, and nine of the 10 years with the most acreage burned have occurred
since 2010s. 1 The table below demonstrates the longevity and increasing frequency of
wildfires in Oregon. The two most recent events (in 2020 and 2021) were significantly
more destructive than events in previous years, which is a trend that is unlikely to reverse
in the face of climate change, extreme heat, and drought. The State of Oregon is
experiencing a heightened risk of fire danger due to drought, tree mortality, and an
increase in severe weather events.

Table 5: Chronology of Recent Severe Oregon Fires

Year County Description of Wildfire Event
2002 Josephine Biscuit Fire destroyed four primary residences and 10 other structures,
and put 15,000 residents on evacuation notice.
2010 Jackson Oak Knoll Fire destroyed 11 homes in fewer than 45 minutes in Ashland.
2014 Wallowa Buzzard Complex Fire burned more than 400,000 acres and significantly
impacted rangeland and cattle farms.
2014 Grant South Fork Complex Fire started with lightning strikes and burned
62,476 acres.
2015 Grant Canyon Creek Complex Fire started by lightning and burned
110,422 acres, destroying more private property than any Oregon
wildfire in the previous 80 years. The wildfire destroyed 43 homes and
almost 100 other structures.
2015 Wallowa Grizzly Bear Complex Fire started by lightning and burned 82,659 acres.
The wildfire destroyed two homes and dozens of other structures.

1 Fire FAQs, Oregon State University

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 Year County Description of Wildfire Event
2017 Mulitple Over 1,000 fires (including Chetco Bar and Eagle Creek) started as
Counties human-ignited or ignited by lightening strikes, burning a total area of
over 451,000 acres.
2020 Multiple Multiple Names/DR-4562 fires killed at least 11 people, burned more
Counties than 1 million acres, and destroyed more than 4,300 homes.
2021 Multiple More than 1,000 fires have burned more than 518,303 acres and
Counties destroyed more than 40 structures.

Including the risks from wildfires, Oregon is vulnerable to additional disasters as

described in the Mitigation Needs Assessment section of this Action Plan. The 2020
Wildfires occurred during the ongoing COVID-19 pandemic response effort, and at the
time of publication, COVID-19 continues to present additional risk to recovering
communities and residents. During the development of this Action Plan, OHCS
consulted with the Oregon OEM, DLCD, and local governments to understand the
current and projected natural hazards and risks faced in the MID areas. For the creation
of the Mitigation Needs Assessment, OHCS also drew heavily from the State’s Natural
Hazards Mitigation Plan and local mitigation plans. Table 6 summarizes the highest
natural hazard risks and threats faced in the MID areas. These risks and hazards will be
factored into Oregon’s recovery and mitigation programming, as described further in
each of the program sections and applicable sections under General Requirements.

Table 6: Summary of Natural Hazards Across HUD-Identified Most Impacted

and Distressed Areas

High-Risk Threat Medium-Risk Threat Low-Risk Threat

Wildfire Landslide Volcanic Event
Earthquake Drought Tsunami
Winter Storm Windstorm
Flooding

2.1.3 HUD-Identified Most Impacted and Distressed Areas

HUD requires funds to be used for costs related to unmet needs in the MID areas
resulting from qualifying disasters. Oregon is required to spend at least 80%—or
$337,828,800—of all CDBG-DR funds to benefit the HUD-identified MID areas.

HUD provided Oregon with the following HUD-identified MID areas in the Allocation
Announcement Notice:

• Clackamas County

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• Douglas County
• Jackson County
• Lane County
• Lincoln County
• Linn County*
• Marion County
* For Oregon, HUD-identified a ZIP Code (97358) in Linn County as a MID area. Within the
Consolidated Notice, HUD allows grantees to expand eligibility to the whole county when HUD
designates a ZIP Code as a HUD-identified MID area. Oregon has expanded eligibility to include
all of Linn County as a HUD-identified MID area.

2.1.4 Grantee-Identified Most Impacted and Distressed Areas

The Consolidated Notice allows Oregon to determine where to use up to 20% of the
remaining amount of the CDBG-DR grant, provided that the funds are used to address
unmet needs within areas that received a presidentially declared disaster declaration
identified within DR-4562. The counties in Table 7 are all included in the presidentially
declared disaster declaration for DR-4562. Of the FEMA Individual Assistance Program
(IA) counties, only Klamath County is not included in the HUD-identified MID areas.

Table 7: DR-4562 Presidentially Declared Disaster Counties and Categories of Awarded

Public Assistance

FEMAPA FEMAPA FEMAPA FEMAPA FEMAPA FEMAPA FEMAPA FEMA

County Cat A Cat B Cat C Cat D Cat E Cat F Cat G IA
Benton X
Clackamas X X X X X X X X
Columbia X
Coos X
Deschutes X
Douglas X X X X X X X X
Jackson X X X X X X X X
Jefferson X
Josephine X X X X X X
Klamath X X X X X X X X
Lake X
Lane X X X X X X X X

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 FEMAPA FEMAPA FEMAPA FEMAPA FEMAPA FEMAPA FEMAPA FEMA
County Cat A Cat B Cat C Cat D Cat E Cat F Cat G IA
Lincoln X X X X X X X X
Linn X X X X X X X X
Marion X X X X X X X X
Multnomah X
Tillamook X X X X X X X
Wasco X
Washington X
Yamhill X

Through its consultation and data analysis process, the State has determined that the
priority is to address housing and housing-related recovery and mitigation needs.
Therefore, the State will include all FEMA IA-declared counties not already included by
HUD in its grantee– identified MID areas:

• Klamath County

2.2 Housing Unmet Needs

The State of Oregon, in collaboration with local and national partners, undertook a
substantial amount of post-disaster planning and data collection and analysis to
leverage as many State and federal resources as possible. The Housing Impact
Assessment, written in collaboration with HUD, FEMA, OHCS, public housing authorities,
and local nonprofits under the Housing Recovery Support Function, published in April
2021, provides a detailed summary of the disaster impacts on housing and the
remaining needs. In addition, the Oregon Disaster Housing Recovery Action Plan,
published in June 2021, outlined housing goals and recovery strategies for the State.
This Action Plan pulls substantially from these documents, but includes updates based
on current information and requirements included in the Notices.

This section of the Unmet Needs Assessment summarizes the disaster impacts on
housing, drawing on data collected from FEMA IA, SBA Home Loans, private insurance
providers, other State agencies, local governments, and nonprofits. This section also
includes information on certain pre-disaster housing conditions that will impact State
and local housing recovery efforts. OHCS also has analyzed barriers to access to
recovery for protected classes, vulnerable populations, and underserved communities.
The information captured herein and additional information collected through the
public comment period and stakeholder consultation were used to develop the
programs identified later in this Action Plan.

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2.2.1 Disaster Damage and Impacts Summary of Need
As described further in Data Sources and Methodology section toward the end of the
Action Plan, the State has calculated housing reconstruction or replacement needs
using two approaches:

• HUD/FEMA/SBA Multiplier Methodology: Calculated using information available

through federal datasets.
• Alternative Methodology – Estimated Costs to Replace Damaged or Destroyed
Housing: Represents a more accurate reflection of the actual impacts and actual
costs to rebuild. Through its damage assessments, engagement, and coordination,
the State identified additional impacted residents who were not included in the
federal datasets. The State’s assessments indicate that the costs to rebuild or
replace damaged or destroyed housing are significantly higher than the projected
estimates calculated through the federal unmet needs analysis process.

The total assessed housing need using the two methodologies—before deducting any
other sources of funding—is included in the table below.

Table 8: Comparison of Need Calculation Methodologies

Number of Estimated
Impacted Reconstruction or
Need Calculation Methodology Households Replacement Need

HUD/FEMA/SBA Multiplier Methodology 3,032 $248,076,254

Alternative Methodology: Estimated Costs to 4,326 $1,318,697,454

Replace Damaged or Destroyed Housing

Difference (additional need projected by 1,294 $1,070,621,200

the Alternative Methodology)

2.2.1.1 Limitations of Federal and Private Data

Through the needs assessment process, OHCS identified the limitations of the federal
disaster impact data available to the State and HUD. To help overcome these
limitations, OHCS has carried out significant outreach and engagement to supplement
the federal data. To design and implement inclusive and equitable programming,
OHCS will continue to collect information and will update its needs assessment in
subsequent amendments. Some of the identified limitations of the federal data are
included below:

• FEMA Individual Assistance (IA) Data: The FEMA IA tables are included in the
sections further below, as they are the data required by HUD. These aggregate
tables were prepared by FEMA with data current as of February 15, 2022. The FEMA

15
 registration data are incomplete in presenting the full picture of the impacts on
housing. Participation and registration with FEMA IA are voluntary. The process can
be overwhelming for survivors because of the documentation requirements, proof of
ownership, limitations on legal residency status, and eligibility criteria that require
appeals or follow-up from the participants, including from those households that are
underinsured. Since the 2020 Wildfires, FEMA has undertaken considerable steps to
make the FEMA IA application and documentation processes more streamlined and
equitable, but at the time of FEMA IA intake for DR-4562, many of those processes
were not in place. In addition, during the intake process for DR-4562, there was a
coordinated application fraud scheme that is being investigated by FEMA and
flagged within the FEMA IA data, which does call into question the accuracy of the
FEMA IA data. Due to the timing of DR-4562 and its overlap with COVID-19, the FEMA
housing damage assessments were not performed in person. It also is important to
note that FEMA IA Home Repair Assistance is intended to make the damaged home
safe, sanitary, or functional. It is not intended to return the home to its pre-disaster
condition and therefore neither the FEMA verified loss nor the FEMA IA award
amounts should be used as a proxy for the actual costs to reconstruct or replace
wildfire damaged or destroyed residential properties.
• SBA Home Data: The SBA disaster loan program also is a voluntary program and it is
limited to impacted homeowners. SBA residential, fully repayable loans are limited
to homeowners and homeowners must qualify through SBA’s underwriting and
eligibility review processes to access SBA loans. SBA verified loss data provide a
better picture of the full cost of repair and replacement, as SBA loan amounts are
based on an inspection that covers the full cost to restore a home. However, the
SBA data are incomplete and fail to include many impacted residential structures.
• Private Insurance Data: While States can rely on National Flood Insurance Program
data for events such as floods and hurricanes, fire damage and claims data must
be collected from individual insurance companies. Individual insurance companies
are inconsistent in how they categorize policies and claims, and they do not report
insurance information into a centrally managed database. OHCS has worked
closely with the Oregon Division of Financial Regulation and the State Insurance
Commissioner to collect aggregate commercial and residential claims information
through a data call to insurance providers. The data provided indicated that:
– Residential and commercial data: Based on the 2020 data, there were
14,836 residential and commercial claims, of which 9,454 resulted in some form of
eligible payment. Of those eligible claims, 4,123 represented a “total loss” or
destroyed property. The total “case incurred loss” or the amount the insurance
companies anticipate paying out for all claims was just under $1.5 billion.

16
 – Residential only data: Based on 2021 data, there were 13,220 residential claims,
of which 9,577 resulted in some form of eligible payment. Of those eligible claims,
2,792 represented a “total loss” or destroyed property. The total “case incurred
loss” or the amount the insurance companies anticipate paying out for all
residential claims is just over $1 billion.
There are several known limitations to the data provided and basing the analysis on this
data:

• Insurance providers do not classify claims or value damages consistently.

• Residential and commercial claims and payouts may include personal property,
vehicles and contents payouts and some may only include structural damage
payouts. Insurance providers could not consistently or accurately distinguish
between contents and structural damages.
• The data call was limited to the major insurance providers in Oregon.
• Some policy holders hold multiple policies and therefore the claims do not
necessarily reflect individual residences or businesses.
• The FEMA IA data indicates 69% of FEMA IA homeowners and 97% of renters with
Major to Severe damages did not have any homeowners or renters insurance,
respectively.

2.2.1.2 State and Local Housing Impact Data

The Oregon OEM is the State agency charged with leading and coordinating disaster
response efforts. Beginning the week of September 28, 2020, while the disaster
declaration was still open and ongoing, OEM conducted joint preliminary damage
assessments with local government partners. These assessments indicated that more
than 4,300 homes were significantly damaged or destroyed. OEM maintains an
updated website storyboard with recorded numbers of destroyed and significantly
damaged residential properties. 2 This assessment was subsequently updated with
additional assessment information from local jurisdictions. The total number of homes
(by structure type) that were either Major Damaged or Destroyed, as assessed by the
State and local jurisdictions, is included in the table below. However, the State
acknowledges that this dataset may exclude impacted residents and is continuing to
work with local community-based organizations, community action agencies, and
other housing support groups to understand the impacts on residents that were not
captured in the State and local government assessments.

2 Damage Assessment, OEM and data provided from local governments

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Table 9: Damaged or Destroyed Homes and Home Types by County

Major Destroyed/
Single-Family Multi-Family Manufactured Damaged Damaged
County Units Units Homes Homes Homes
Clackamas 62 0 0 0 62

Douglas 126 0 12 0 138

Jackson 610 328 1,561 9 2,508

Klamath 11 0 0 0 11

Lane 505 0 69 41 615

Lincoln 65 0 223 0 288

Linn 71 0 0 0 71

Marion 629 0 0 4 633

TOTAL 2,079 328 1,865 54 4,326

2.2.2 Affordable Housing Shortage and Rising Costs

In many ways, the wildfire disaster was primarily a housing disaster. The unprecedented
scale of the 2020 Wildfires, combined with the challenges of the COVID-19 pandemic,
drastically increased Oregon’s already tenuous housing and homelessness crises. Prior
to the 2020 Wildfires, Oregon’s vacancy rate was near the State’s record low and a
third lower than the national average. This means that the State had a significant lack
of available housing—particularly affordable housing—even before the COVID-19
pandemic and 2020 Wildfires.

The severity of the housing shortage, especially for lower income households, has been
well documented in Oregon for years. In 2020, EcoNorthwest conducted Oregon’s first
ever Regional Housing Needs Analysis (RHNA) on behalf of OHCS and Oregon DLCD.
The RHNA analyzes housing needed for all income levels by region and is being used as
a planning tool for informing the State’s CDBG-DR programs. A key finding of the RHNA
is that Oregon will need to produce 30,000 to 40,000 new homes per year over the next
5 years to meet demand and restore balance to the market. The State’s annual
production, as measured by residential building permits, is approximately 20,000
per year—half of what it should be.3

3 2020 RHNA Technical Report and Oregon Disaster Housing Recovery Action Plan (June 2021), p. 9.

18
In addition, prior to the COVID-19 pandemic and 2020 Wildfires, the State was
experiencing significant increases in housing costs. The statewide median home value
rose by 40% (around $100,000) between 2010 and 2018. Similarly, the median rent also
increased by nearly $300 (just above 40% during the same period.4

2.2.2.1 Pre-Disaster Owner-Occupied and Rental Vacancy Rates

HUD’s “Market at a Glance” includes a snapshot of the most current vacancy data
available for the State of Oregon and the impacted counties. Statewide, the data
indicate a 2019 total housing stock of 1.8 million units, with an average 2017–2019 rental
vacancy rate around 4% and a sales vacancy rate around 1.3%. Compared with the
national averages of 6.7% and 1.4%,5 respectively, even before the disaster event,
Oregon lacked sufficient housing to meet the demand. The impacted county pre-
disaster vacancy rate data range from 0.7% (Douglas) to 6.1% (Lincoln) for rentals, and
0.8% (Lane) to 3.8% (Jackson) for sales. Naturally, the major damage and destruction,
as reported by OHCS, of more than 4,300 units in the impacted counties will significantly
affect vacancy rates as survivors vie for available housing.

Table 10: Pre-Disaster Residential Percentages

(a) Pre-Disiaster Vacancy Rates of Renter and Owner-Occupied Housing, by County

Renter-Occupied Owner-Occupied
County Vacancy Rate (%) Vacancy Rate (%)
Clackamas 3.2 1.1
Douglas 0.7 3.4
Jackson 3.3 3.8
Klamath 4.3 1.3
Lane 2.0 0.8
Lincoln 6.1 3.1
Linn 2.1 1.1
Marion 5.8 1.3
Source: 2019 American Community Survey 5-year Estimates

The table below displays the percentage of renter vs. owner occupied housing stock for
each county in the impacted area, based on American Census Survey data. In each of
these impacted counties, the majority of housing units were owner occupied, with
Clackamas having the highest at 71.8% and Lane having the lowest at 58.67%.

4 Oregon Consolidated Plan, p. 119.

5U.S. Census Bureau, Rental and Homeowner Vacancy Rates by Area and
https://www.census.gov/housing/hvs/data/ann20ind.html

19
(b) Pre-Disaster Renter and Owner Occupied Housing, by County

Owner occupied Owner occupied Renter occupied Renter occupied

County (#) (%) (#) (%)
Clackamas 111,885 71.08% 45,523 28.92%
Douglas 30,986 68.17% 14,470 31.83%
Klamath 17,924 64.28% 9,962 35.72%
Lane 89,359 58.67% 62,953 41.33%
Lincoln 13,977 65.63% 7,321 34.37%
Linn 30,748 64.38% 17,014 35.62%
Marion 71,101 60.24% 46,937 39.76%
Jackson 55,792 63.23% 32,449 36.77%
Source: 2019 American Community Survey 5-year Estimates

2.2.2.2 Pre-Disaster Rent Burden

Rent burden is defined as paying 30% or more of household income on gross rent in the
past 12 months. 6 An analysis by the Oregon Health Authority, looking at American
Community Survey (ACS) data, evaluated the rent burden in Oregon compared with
the United States from 2007 to 2019. This pre-disaster dataset showed that, on average,
in Oregon, 52% of renters were paying more than 30% of their income on housing
(slightly higher than the U.S. average of 50%). Furthermore, the lowest income
households have the highest levels of rent burden, with 89% of Oregon households
earning less than $19,999 annually. Looking at pre-disaster housing in the impacted
counties, the rent burdens in Jackson and Lane counties are above the state average.
Lane County had the highest rent burden at 57% 7. Conversely, Douglas County was
observed to have 48% of renters being rent-burdened, which is the lowest rate
recorded among the FEMA IA-declared counties.

The data are helpful for assessing affordable housing throughout the State and
designing programs to not only fill a housing need but also do so in a manner that
avoids furthering the rent burden for the lowest income households.

2.2.2.3 Pre-Disaster Housing Value Range

Given the diversity of populations and environments, the cost of housing in Oregon
varies greatly, especially between metropolitan and rural areas. The median value of
an owner-occupied home across the State was $312,200 in 2019. Meanwhile the

6 Definition of rent burden, Social determinants of health, Oregon Health Authority

7 Housing Impact Assessment, DR-4562-OR, p. 10.

20
median gross rent was around $1,100.. Median home values in the eight impacted
counties varies widely—from $170,600 (Klamath) to $395,100 (Clackamas).

Table 11: Evidence of Cost Burden by County

Median Home Value Median Gross Rent Building Permits Issued

County (in $) (in $ per month) (2020)
Clackamas $395,100 $1,295 2,011
Douglas $199,200 $824 243
Jackson $280,300 $993 886
Klamath $170,600 $772 152
Lane $263,200 $989 1,391
Lincoln $251,200 $924 250
Linn $221,600 $964 796
Marion $247,100 $985 1,743
TOTAL N/A N/A 7,472
Source: U.S. Census Bureau QuickFacts. 8

The rising costs of housing, the limited availability of housing, and the number of renters
experiencing housing cost burdens in the counties impacted by the 2020 Wildfires
highlight the need for reconstruction, replacement, and enhancement of affordable
housing.

2.2.3 Role of Manufactured Housing as Affordable Housing

in Oregon
A manufactured housing unit (MHU), mobile home, or manufactured home is a type of
prefabricated housing that is constructed in a factory and then transported to a site,
to owned or leased land or a manufactured housing park for installation. These homes
are built to a federal code administered by HUD that went into effect in 1976.
Factory-built homes constructed before 1976 are called “mobile homes.” Modular
home components also are prefabricated in a factory but differ from MHUs because
they are built to a local building code, assembled on the permanent housing site, and
cannot be easily transported to another site.

8 Quick Facts, US Census Bureau, Klamath County.

21
2.2.3.1 Manufactured Housing in Oregon
Prior to the 2020 Wildfires, Oregon had approximately 1,067 manufactured housing
parks (MHPs) with a total of 62,397 lots. Only 3,122 of the lots within these parks are
identified as vacant. Of the listed parks, 325 (30.46%) are only open to occupants who
are over age 55; the other 744 parks (69.54%) are not agerestricted.9

In 2017, the State revised their land use statutes to facilitate the expansion of
manufactured housing opportunities. The State directed local governments to revise
their comprehensive land use plans to include manufactured homes in their urban
growth boundaries as “needed housing” 10 inside urban growth boundaries. The State
also disallowed local governments from setting tighter restrictions on manufactured
homes and the placement of MHUs than those set forth by the State.

2.2.3.2 Housing Affordability and Manufactured Housing

Manufactured housing may serve as part of the solution to Oregon’s affordable housing
challenges. At less than half the average cost per square foot compared with site-built
homes, manufactured housing is one of the largest sources of unsubsidized affordable
housing in the country. For example, while manufactured homes represent about 8% of
the State’s total housing volume, they constitute 16% of the affordable housing stock.11

Similarly, the owners of manufactured housing tend to spend considerably less of their
income on housing than residents of other types of homes, especially among
households with incomes at or below the area median. However, almost half of the
State’s existing manufactured homes were built before 1980, which could present
significant financial challenges for residents moving forward.

Manufactured housing provides a lower cost homeownership option for prospective

buyers. Of the manufactured home residents, 78% own their unit compared with 62% of
residents of all other types of housing. While the cost of homeownership may be less,
there are some financial concerns with regard to insuring MHUs. Generally, site-built
homes are insured for their replacement value—meaning that the insurance will cover
the full cost to replace the home, while MHUs are generally covered at actual cost
value—meaning that they depreciate over time and the coverage only provides the
current depreciated value. This has a significant impact on disaster-affected MHUs.

9 A Review of Oregon’s Manufactured Housing Policies, Oregon State University.

10 Comprehensive Land Use Planning, Oregon Revised Statute.
11 Prosperity Now, Oregon Manufactured Housing Data Snapshot.

22
The costs for renting pads or lots in privately owned MHPs are increasing in many
HUD-identified MID areas and throughout the State. OHCS has worked closely with local
nonprofit organizations, 12 resident cooperatives, housing authorities, and other entities
to preserve the affordability of pad or lot rents and prevent MHP closures through their
Preservation of Manufactured Dwelling Parks Program and various other multifamily
development and/or land acquisition programs. 13

2.2.4 Labor Shortages and Increased Costs of Residential

Construction
Oregon, like many other parts of the country, faces challenges related to construction,
manufactured home supply chains, and increased labor and material costs.
Construction costs have increased 20% to 25% since the September 2020 Wildfires,
forcing many lower income property owners or property owners with insufficient funds
to postpone rebuilding. The construction industry has been one of the fastest growing
industries in Oregon, before and during COVID-19, and is facing a labor shortage. In a
2021 publication from the Oregon-Columbia Chapter of Associated General
Contractors, 14 89% of contractors reported having difficulty finding craft workers, 88% of
firms are experiencing project delays, and 93% are affected by rising material prices.
These shortages and increases in costs have resulted in an average 2-year timeline for
constructing or reconstructing a single-family, stick-built home. The nation also is facing
delays in the production of manufactured and other prefabricated homes, with an
anticipated production timeline of more than a year for new manufactured homes to
be delivered after they are ordered.15

As described in Table 12 below, 2,500 housing units were destroyed or damaged in

Jackson County in the 2020 Wildfires, a number that is 2.5 times the number of
residential building permits issued in 2019. Lane County lost 615 homes—all in
unincorporated communities of the McKenzie River Valley—which is three times greater
than the average number of annual permits issued by the county in its unincorporated
area. Across the State, the number of homes damaged or destroyed equate to 19% of
all residential building permits in one year.16 In addition to the magnitude of loss, these
figures speak to the scale of the rebuilding challenges in the impacted rural
communities and underscore how important local and contractor capacity will be to

12https://noah-housing.org/programs/manu/ and https://casaoforegon.org/for-individual/manufactured-

housing-cooperative-development/
13 https://www.oregon.gov/ohcs/development/Pages/nofa-ghap-manufactured-parks.aspx
14https://www.agc-oregon.org/uncategorized/construction-workforce-shortages-reach-pre-pandemic-
levels-2/
15 Oregon Disaster Housing Recovery Action Plan, June 2021, p. 14.
16 Oregon Disaster Housing Recovery Action Plan, June 2021, pp. 8–9.

23
housing recovery. Like much of the country, Oregon was far behind in producing
sufficient housing to meet current and future demand, even before the wildfires.

Table 12: 2020 Wildfire Destruction and Damages as a Percentage of Annual Residential
Building Permits
Lost Homes as a
Percentage of
Destroyed & Annual Residential Pre-Wildfire
Impacted County Damaged Homes (1) Building Permits (2) Area Permits
Clackamas (3) 62 826 8%
Douglas 138 243 55%
Jackson 2,373 921 258%
Klamath 11 137 8%
Lane (3) 615 214 287%
Lincoln 288 333 86%
Linn 71 716 10%
Marion 633 1,638 39%
TOTAL 4,191 5,028 83%
2019 Oregon Permits 22,037 19%
Sources:
1. Oregon Office of Emergency Management.
2. HUD Office of Planning and Research, most recent annual data from 2019 or 2020.
3. Clackamas and Lane counties permit data are for unincorporated areas only.

2.2.4.1 Sheltering and Transitional Housing Post-Disaster

Following the disaster declaration, FEMA, Oregon OEM, the Oregon Health Authority,
the Oregon Department of Human Services, Red Cross, and OHCS worked to develop a
range of sheltering and housing solutions, using a multi-phased operations approach,
as described in the Disaster Sheltering and Housing Strategy. 17 Since the declaration,
FEMA approved multiple transitional housing programs and related supports for
Oregon’s survivors, including non-congregate sheltering and FEMA Direct Housing
missions in Jackson, Lane, Linn, and Marion counties.

The long-standing shortage of housing, especially affordable housing, meant that

wildfire survivors with the fewest resources could not find a new place to live. The loss of
housing because of the wildfires was further stressed by the ongoing global pandemic.
Many of the displaced wildfire survivors were placed in hotels, motels, and other

17 FEMA, Disaster Sheltering and Housing Strategy, FEMA-4562-DR-OR.

24
non-congregate shelters to reduce transmission of the COVID-19 virus. 18 Untold numbers
of other survivors doubled-up, resorted to camping, or otherwise remained precariously
housed. The Oregon Department of Human Services (ODHS) worked closely with the
American Red Cross to help wildfire survivors access shelter.19

At the time of publication, nearly 400 survivors remain housed through FEMA’s Direct
Housing mission and/or through non-congregate sheltering in hotels or recreational
vehicles (RVs) through programs administered by ODHS. 20 Disaster case managers
(overseen by ODHS in partnership with nonprofit organizations and funded through
FEMA) are helping residents move through their permanent housing plans to move out
of FEMA-funded temporary housing. This work is being supplemented by State of
Oregon funding to Community Action Agencies to provided specialized “housing
navigation” assistance in addition to disaster case manager (DCM) services. FEMA also
is implementing the FEMA Temporary Housing Unit (THU) Sales and Donations Program, 21
whereby participants in the Direct Housing mission are given the option of purchasing
their FEMA THU.

In fall 2021, OHCS partnered with community action agencies and long-term recovery
groups, through sub-recipient agreements, to administer the State-funded Wildfire
Recovery and Resilience Account (WRRA). WRRA provides flexible funding for wildfire
survivors with a verified housing impact. Funds may be used for a wide range of
activities, including rental assistance and related supports, as well as for reconstruction
or replacement of damaged housing. The program prioritizes low-income households
and requires the equitable distribution of funding to high-risk participants facing housing
insecurity. This program is helping many survivors transition out of FEMA sheltering and
transitional housing programs and into housing that is more stable or suitable for their
households.

2.2.5 Single-Family vs. Multifamily Needs: Owner Occupied vs.

Tenant
Based on data for the eight counties approved for FEMA IA Individuals and Household
Program (IHP), it is estimated that 59% of the impacted residents were homeowners and
41% were tenants. While this information is not inclusive of all impacted residents, it is the
only data set available specific to fire survivors that includes a breakout of renters and
homeowners, and therefore will be used to inform initial programming.

18 Oregon Disaster Housing Recovery Action Plan, June 2021, p. 2.

19 Oregon Disaster Housing Recovery Action Plan, June 2021, p. 2.
20 Oregon Wildfire Response and Recovery Overview Dashboard.
21 FEMA, Individual Assistance Program and Policy Guide, p. 118.

25
 FEMA Individual Assistance (IA) # of Owner Applicants # of Tenant Occupants
Total Registrants 6,958 (29%) 17,055 (71%)
Total With IHP Award 1,914 (59%) 1,329 (41%)

2.2.5.1 Definition of Affordable Rents, Income Limits for Tenants, and

Minimum Affordability Periods
The State has included the definitions of affordable rents, income limits for tenants
and minimum affordability periods within each of the applicable program descriptions
further below.

2.2.5.2 FEMA IA – Owner Occupied

Table 13: FEMA IA Owner-Occupied by County
Number of Number
Number of Number of Inspections Received Total FEMA Avg. FEMA
County Applicants Inspections with Damage IHP Verified Loss Verified Loss
Clackamas 983 163 141 93 $1,870,857.57 $13,268.49
Douglas 521 119 110 51 $3,235,475.33 $29,413.41
Jackson 2,385 948 935 1,098 $49,263,081.27 $51,638.45
Klamath 117 27 26 4 $374,805.68 $14,415.60
Lane 886 214 197 224 $8,983,145.86 $45,599.73
Lincoln 478 145 136 179 $5,722,512.69 $41,467.48
Linn 404 87 77 67 $2,746,631.96 $35,670.54
Marion 1,184 211 191 198 $12,682,036.25 $66,052.27
TOTAL 6,958 1,914 1,726 1,914 $74,863,532.59 $274,447.99
Data from Federal Emergency Management Agency Information Data and Analysis (FIDA)
40449 DR-4562, February 17, 2022.

2.2.5.3 FEMA IA – Tenant Applications

Table 14: FEMA IA Tenant by County
Number of Number
Number of Number of Inspections Received Total FEMA Avg FEMA
County Applicants Inspections with Damage IHP Verified Loss Verified Loss
Clackamas 1,337 190 142 80 $747,401.32 $5,226.58
Douglas 10,950 590 505 46 $4,060,382.99 $7,977.18
Jackson 2,179 875 828 701 $4,482,376.78 $5,406.97
Klamath 146 17 17 9 $85,997.61 $5,058.68
Lane 877 255 219 173 $1,113,477.66 $5,061.26
Lincoln 323 117 105 94 $483,023.99 $4,600.23

26
 Number of Number
Number of Number of Inspections Received Total FEMA Avg FEMA
County Applicants Inspections with Damage IHP Verified Loss Verified Loss
Linn 349 80 57 44 $246,930.61 $4,332.12
Marion 894 268 208 182 $994,323.87 $4,757.53
TOTAL 17,055 2,392 2,081 1,329 $12,213,914.83 $42,420.55
Data from FIDA 40449 DR-4562, February 17, 2022.

2.2.5.4 FEMA IA – Applications by Housing Type

Table 15: FEMA IA Applications by Housing Type

Number of % Owner
Residence Type Applicants Occupied % Tenants % Unknown % Type
Apartment 240 0.4% 99.6% 0.0% 7.8%
Assisted Living Facility 14 0.0% 100.0% 0.0% 0.5%
Condo 30 33.3% 66.7% 0.0% 1.0%
House/Duplex 1,330 31.3% 68.7% 0.0% 43.1%
Mobile Home 1,153 73.2% 26.8% 0.0% 37.4%
Other 8 50.0% 50.0% 0.0% 0.3%
Townhouse 114 34.2% 65.8% 0.0% 3.7%
Travel Trailer 195 84.6% 15.4% 0.0% 6.3%
Data from FIDA 40449 DR-4562, February 17, 2022.

2.2.5.5 FEMA Real Property Damage: Owner-Occupied Units

Table 16: FEMA IA Owner-Occupied Damage Level by County
County Severe Major – High Major – Low Minor – High Minor – Low
Clackamas 7 9 0 0 114
Douglas 17 8 1 0 75
Jackson 710 62 1 1 155
Klamath 1 0 0 0 19
Lane 53 22 0 4 100
Lincoln 73 14 0 1 42
Linn 19 2 0 5 46
Marion 73 24 1 2 86
TOTAL 953 141 3 13 637
Data from FIDA 40449 DR-4562, February 17, 2022.

27
2.2.5.6 FEMA Real Property Damage: Rental Units
Table 17: FEMA IA Tenant Damage Level by County
County Severe Major – High Major –Low Minor – High Minor – Low
Clackamas 38 47 6 33 19
Douglas 348 87 18 39 17
Jackson 213 333 119 103 61
Klamath 6 4 1 2 4
Lane 55 79 18 40 28
Lincoln 19 39 11 21 15
Linn 12 14 9 13 9
Marion 54 56 19 37 43
TOTAL 745 659 201 288 196
Data from FIDA 40449 DR-4562, February 17, 2022.

2.2.6 Public Housing and Affordable Housing

Of the Oregon counties designated for FEMA IA, there is a public housing authority
(PHA) in each of the eight counties (which includes the HUD MID areas).

2.2.6.1 Housing Choice Voucher Households 22

Housing choice voucher (HCV) households are qualified low-income, senior, and/or
disabled households receiving rental assistance (a subsidy) to live in participating rental
housing (with landlords) in their communities. These eight PHAs assist 1,428 households
with public housing and 12,104 households with subsidies.

During the 2020 Wildfires, many PHA families had to temporarily evacuate while there
was a direct threat to their homes. The public housing units did not receive any
permanent impacts by the wildfires (i.e., no damages or displacements). However, four
of the eight PHAs in the designated counties reported a total of 75 displaced HCV
households. The four impacted PHAs were the Housing Authority of Lincoln County,
Homes for Good (Lane County), the Marion County Housing Authority, and the Housing
Authority of Jackson County.

Since the wildfires, 72 out of 75 displaced HCV households have been successfully
rehoused. The remaining HCV households are in Lane, Lincoln, and Marion Counties.
The PHAs continue to work through solutions for each of these participants to
accommodate their post-disaster housing and location needs.

22 Housing Impact Assessment, pp. 24–25 and consultation with PHAs in impacted counties.

28
2.2.6.2 HUD Office of Housing – Multifamily Housing
There are 165 HUD multifamily housing properties in the eight counties declared for
FEMA IA. These properties contain 8,582 units, of which 4,315 receive project-based
rental assistance. The HUD Office of Multifamily Housing Programs reported the
evacuation of more than 500 units/households on 10 properties in the wildfire-
threatened areas of Lincoln, Jackson, and Clackamas counties. By September 21, 2020,
the office reported that all evacuated residents had returned to their respective
properties.

2.2.6.3 OHCS Housing Portfolio23

OHCS maintains asset management oversight over a portfolio of 1,150 projects
statewide, totaling almost 57,000 units, consisting of projects funded with federal and
State tax credits, bonds, other federal funding (e.g. HOME and Housing Trust Funds,
and State funding. More than 1,000 projects (about 53,000 units) are residential rental,
with the balance comprising a mix of manufactured housing parks (MHPs), assisted
living and other residential facilities, transitional housing, shelters, and one lease-to-own
project. Of the total units, 75% are targeted to households at 50% to 60% of area
median income.

Within the eight disaster-declared counties with FEMA IA, there are 363 residential rental
properties that are part of the OHCS portfolio. These include 15,000 residential rental
units, 13 MHPs with a total of 745 units (in Lane, Clackamas, and Douglas counties only),
and 23 assisted-living properties totaling 1,250 units.

Of the OHCS projects, three properties in Jackson County, totaling 127 units, were
severely damaged (lost).

Table 18: OHCS Assisted Severely Damaged Housing Projects

Property Name Number of Units City/County Population
Anderson Vista 36 Talent/Jackson Farmworker
Brookside Rose Seniors or Individuals
36 Phoenix/Talent
(Rose Court) with Disabilities
Northridge Center 55 Medford/Jackson Seniors
Data from the DR-4562-OR Housing Impact Assessment – April 30, 2021.

23 Housing Impact Assessment, p. 24.

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2.2.6.4 Multi-Family HUD-Assisted Housing
Table 19: HUD Assisted Properties
Number
Number Number Number of Units Waiting
Type of Damage of Properties of Units of Units Assisted for Assistance
No Damage 157 8,066 4,092 3,974
No Utilities 2 170 50 120
Minor Damage 5 264 173 91
No Assessment 1 82 0 82
Data from the DR-4562-OR Housing Impact Assessment – April 30, 2021.

2.2.6.5 Public Housing Authorities Damaged

Table 20: Public Housing Authority Impacted Properties
County Total PHAs Total PHAs Damaged No. of Units Damaged
Clackamas 1 0 0
Douglas 1 0 0
Jackson 1 1 127
Klamath 1 0 0
Lane 1 0 0
Lincoln 1 0 0
Linn 1 0 0
Marion 1 0 0
Data from the DR-4562-OR Housing Impact Assessment – April 30, 2021.

2.2.6.6 Owner with Unmet Needs in a Floodplain

Owner-Occupied Homes in a Special Flood Hazard Area

Damage Category All Owners MHU Owners No HOI No Flood Ins
Severe 4 4 4 4
Data from FIDA 40449 DR-4562, February 17, 2022.

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2.2.6.7 Insurance Claims and Losses in Disaster-Impacted Areas
Table 21: Residential Insurance Claims by County
County No. of Claims No. of Claims Resulting in Loss Direct Incurred Losses ($)
Clackamas 3,073 2,231 51,722,214
Douglas 236 149 43,206,580
Jackson 3,896 2,975 368,785,649
Klamath 62 49 3,265,150
Lane 1,907 1,269 255,642,143
Lincoln 1,066 831 61,017,713
Linn 1,423 158 150,146,301
Marion 1,450 985 154,580,203
TOTAL: 13,113 8,647 $1,088,365,953
Data from Oregon Division of Financial Regulation 2020 Wildfire Homeowner Claims Data Call
Results. Data submitted as of 12/31/2021.

2.2.6.8 Total Home Loans Approved by the SBA

Table 22: Home Loans Approved by SBA
(a) Number of Home Loans with (b) Number of Home Loans
Cancelled Loans without Cancelled Loans
No. of Home No. of Home
Loans With Loans Without
Cancelled Cancelled
County Loans County Loans
Clackamas 40 Clackamas 20
Douglas 11 Douglas 4
Jackson 269 Jackson 147
Klamath 3 Klamath 1
Lane 54 Lane 22
Lincoln 55 Lincoln 26
Linn 24 Linn 11
Marion 84 Marion 42
TOTAL 540 TOTAL 273
Data from SBA Reports, January 2022.

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2.2.7 Social Equity, Fair Housing, and Civil Rights
2.2.7.1 The Use of Data to Make Funding Decisions to Advance Equity and
Reduce Barriers
Through its long-established policy making and program design processes, OHCS is
committed to using data, performance metrics, and qualitative and quantitative
information to ensure programs help advance equity and reduce barriers. This section
outlines the OHCS policy-making governance structure, the agency’s guiding
documents, and includes additional analysis of impacts to vulnerable populations, 24
members of protected classes under fair housing and civil rights laws, racially and
ethnically concentrated areas, concentrated areas of poverty, socially vulnerable
areas, and historically underserved communities. 25

This information provides a foundation for understanding the additional needs of

survivors and for ensuring programs are implemented equitably, or in a manner that
understands and addresses disparities and additional needs across race, ability, class,
age, ethnicity, gender, and other characteristics.

2.2.7.1.1 Housing Stability Council and OHCS Statewide Housing Plan

2.2.7.1.1.1 Housing Stability Council
All CDBG-DR Action Plans and Substantial Amendments will be presented to the
Oregon State Housing Stability Council (the Council or HSC) for review. 26

The Council provides leadership in, and reviews and sets policy for, the development
and financing of affordable housing throughout the state of Oregon. The Council, with
the advice of the Executive Director of OHCS, sets policy and approves or disapproves
rules and standards for programs, and approves or disapproves loans and grants, and
carries out the provisions of ORS 456.567; and ORS 456.571. The nine-member Council is
charged with meeting the tremendous need for the provision of affordable housing for
lower-income Oregonians. The Council members are appointed by the Governor,
subject to confirmation by the Senate under ORS 171.562 and 171.565.

24HUD defined vulnerable populations as: “A group or community whose circumstances present barriers to
obtaining or understanding information or accessing resources.”
25 HUD defines underserved communities as: “Refers to populations sharing a particular characteristic,
as well as geographic communities, that have been systematically denied a full opportunity to participate
in aspects of economic, social, and civic life. Underserved communities that were economically distressed
before the disaster include, but are not limited to, those areas that were designated as a Promise Zone,
Opportunity Zone, a Neighborhood Revitalization Strategy Area, a tribal area, or those areas that meet
at least one of the distress criteria established for the designation of an investment area of Community
Development Financial Institution at 12 CFR 1805.201(b)(3)(ii)(D)”
26 OHCS Housing Stability Council

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Per their charter, the Council: 27

• Helps establish strategic direction and a policy framework for OHCS

• Helps the Director to foster constructive partnerships with other state agencies
and key partners engaged in housing and community services
• Sets policy for and issues decisions regarding loans, grants, and funding awards
• Advises policymakers
• Informs the OHCS Director’s annual operating plan and biennial budget,
and oversees OHCS operations through regular reports from the Director
• Advocates at all levels on behalf of the Department and affordable housing

2.2.7.1.1.2 Statewide Housing Plan

The 2019-2023 Statewide Housing Plan 28 outlines six policy priorities that focuses OHCS’s
investments to ensure all Oregonians have the opportunity to pursue prosperity and live
from poverty. These priorities are:

• Equity and Racial Justice

• Homelessness
• Permanent Supportive Housing
• Affordable Rental Housing
• Homeownership
• Rural Communities

One of the six core priorities is to advance equity and racial justice by identifying and
addressing institutional and systemic barriers that have created and perpetuated
patterns of disparity in housing and economic prosperity.
To meet this priority, OHCS has developed implementation strategies, which rely on
quantitative and qualitative data. The applicable implementation strategies that OHCS
will use for the design, outreach, engagement, and implementation of its CDBG-DR
programs are described below.

• Adopt an approach to advancing equity and racial justice, informed by national

promising practices and lived experience of communities of color

27 OHCS Housing Stability Council

28 OHCS - Statewide Housing Plan 2019-2023

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• Create and maintain a system to analyze OHCS programs and practices and
remove identified barriers to access and opportunity within OHCS programs to
ensure equitable outcomes
• Improve OHCS’s ability to track, analyze, and measure performance and progress
towards equity goals through standardization of data collection and enhancing
data analysis of program utilization
• Meaningfully engage culturally specific and culturally responsive organizations and
their constituents to ensure OHCS policies, practices, systems of accountability, and
program awards are designed to advance equity and racial justice and meet the
needs of communities of color, including black, indigenous, and people of color
• Fund housing and community services programs to build inclusive communities and
prevent, mitigate, or reverse the effects of gentrification and displacement
• Increase access to fair housing resources, education, and enforcement to reduce
the occurrence and impact of housing discrimination in Oregon
• Strengthen relationships with tribal leaders and leverage resources to address
disparities in tribal housing issues

2.2.7.1.1.3 Targeted Universalism, Racial Equity Analysis Tool (REAT) and Equity Lab
OHCS will apply a targeted universalism approach to designing and implementing
CDBG-DR programs. Within a targeted universalism framework, universal goals are
established for all groups concerned. The framework then uses targeted processes and
strategies to achieve those goals, based upon how different groups are situated within
structures, culture, and across geographies to obtain the universal goal. Targeted
universalism is a platform to operationalize programs that move all groups toward the
universal policy goal, as well as a way of communicating and publicly marketing such
programs in an inclusive, bridging manner. It is an approach that supports the needs of
particular groups, including those in the majority, while reminding everyone that we are
all part of the same social and civic fabric.29 Through this process, the State will develop
specific solutions to address unmet needs, incorporating those solutions into a universal
goal-oriented framework to equitably benefit all groups involved.

As an example, the State may set a universal goal for the Homeowner Assistance and
Reconstruction Program to ensure all homeowners at or below 80% AMI move into an
affordable and secure home. This goal will account for other resources and programs
available to LMI households. The targeted strategies will account for the culturally
specific needs of different protected class groups, vulnerable populations, and
underserved communities. The strategies will include an analysis of historic and current
barriers to disaster recovery resources and will incorporate solutions to address these

29Targeted Universalism, Policy and Practice, May 2019, https://belonging.berkeley.edu/targeted-

universalism

34
barriers. Some examples of targeted processes and strategies for Latino/a/x households
and individuals living with disabilities are included below:

• Targeted strategies for addressing the recovery needs of disaster-impacted

Latino/a/x survivors include providing additional application support, legal services,
language translation and interpretation services, support managing licensed and
insured construction contractors, time constraints, access to additional funding,
providing access to housing that meets the needs of multi-generational households,
and the need to work with trusted community organizations due to a distrust of
government.
• Targeted strategies for addressing the recovery needs of disaster-impacted
individuals living with disabilities include providing additional application support,
access to housing that is designed to be accessible for their needs, legal services to
support power of attorney accommodations, ensuring housing application intake
centers are accessible, ensuring the CDBG-DR website is Section 508 compliant.
The State will publish program universal goals and targeted strategies on its final Action
Plan that will be submitted to HUD. OHCS will leverage feedback received from public
comments, the expertise of internal data and reporting team staff, partnerships with
local organizations, and the OHCS Racial Equity Ad Hoc Workgroup. This Workgroup is
in the process of finalizing a customized Racial Equity Analysis Tool (REAT) and Equity
Lab for the agency. In addition to helping inform the targeted universal goals and
strategies, the Racial Equity Analysis Tool and the Equity Lab workshop process will be
used to support thought-partnership, answer questions, and review programs to ensure
they are serving communities of color effectively.

Under the targeted universalism framework, OHCS will develop strategies that
operationalize equity, direct resources and achieve outcomes for those most impacted
by housing instability as a result of the 2020 Wildfires. Some of the additional needs that
may be specific or more prevalent amongst different protected classes, vulnerable
populations, and/or underserved communities are described in the sections below.

2.2.7.1.2 Individuals Living with Disabilities

FEMA reported that nearly 18% of the valid FEMA IA registrants self-reported having
access or functional needs. Through the course of development of the FEMA Disaster
Sheltering and Housing Strategy for DR-4562, 30 FEMA and OEM identified significant
challenges in addressing affordable and accessible recovery needs for people with
disabilities.

30https://www.oregon.gov/ohcs/get-involved/Documents/committees/ODHTF/FEMA-Disaster-Sheltering-
Housing-Strategy-DR4562.pdf

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• Issue No. 1: Affordability and Accessibility. For renters and homeowners living with a
disability, accessibility is of the utmost importance when searching for a new home.
No matter how appealing the price or location, a home is not suitable unless it
accommodates the physical needs of its tenants. This also includes access to
community services and supports, such as public transportation and paratransit
services. These additional requirements often limit a resident’s ability to identify
lower-cost housing.
• Issue No. 2: Accessible Housing Is Not Only Utilized by Households That Require
Resources. Accessible homes are undersupplied, even if we assume that they are
routinely occupied by households that have a disability. In reality, the situation is
made worse by the fact that accessible homes and individuals with disabilities are
rarely paired together. An individual without a disability will not turn down an
attractive housing option just because it has accessible features. Alternatively,
someone who develops a physical disability may prefer to continue living in their
non-accessible home rather than go through the process of moving.
• Issue No. 3: Awareness of Programmatic Waivers and Impacts on People with
Disabilities. During a disaster, organizations, including HUD, will issue waivers of
certain requirements in their programs to support the speedy recovery of disaster
survivors. These program flexibilities may free up funding to be utilized for different
purposes, may increase the amount of money that can be spent on certain types of
assistance, or might create programmatic flexibilities to speed up the process. While
these waivers are typically good for survivors because they may make more housing
available, some waivers can be detrimental to survivors with disabilities.
For example, HUD has issued a waiver to HOME property standards, which
appeared to waive the Americans with Disabilities Act and the Rehabilitation Act.
Disability integration can advise what waivers exist and how they positively or
negatively affect the response and recovery of people with disabilities.
• Issue No. 4: Including Disability Access in Hazard Mitigation Strategies. Accessible
elevation can be a barrier for people with mobility disabilities and older adults who
are aging in place. Elevated homes can disrupt community visitability and can be
daunting for individuals who need zero-step entry and egress.
Per ORS 456.510, OHCS-funded rental housing programs must follow visitability
requirements. With certain exceptions, OHCS subsidized rental housing for new single-
family or duplex dwelling with habitable space on the first floor must be designed and
constructed as “visitable” dwelling: https://www.oregonlaws.org/ors/456.510. The State
will adopt this standard in the reconstruction or new construction of all site-built housing
funded with CDBG-DR assistance. This is in addition to ensuring all multi-family housing
subsidized with CDBG-DR assistance meet ADA and accessibility requirements.
By adopting this standard across its programs, the State will help increase the
availability of accessible housing to meet current and future needs of older adults and

36
people living with disabilities. This will increase the opportunity for households to age in
place and build in increased community resiliency for individuals with disabilities.

2.2.7.1.3 Latina/Latino/Latinx Individuals and Households

The State has identified wildfire impacts and recovery barriers for Latina/Latino/Latinx
communities as a special area of need and focus. The Oregon Health Authority’s
Estimate of Migrant and Seasonal Farmworkers in Agriculture, 2018 Update, estimates
that 174,000 migrant and seasonal farmworkers and their families play a vital role in the
State’s economy. It is estimated that more than 55,000 migrant and seasonal
farmworkers and their families reside within the seven HUD-identified MID counties,
Table 23 provides a breakdown of migrant/seasonal households by impacted county.

Table 23: 2020 Wildfire-Impacted County Migrant and Seasonal Household Members
Total Migrant, Seasonal Farmworkers,
County and Household Members (estimates)
Clackamas 12,296
Douglas 2,624
Jackson 6,567
Lane 2,899
Lincoln 131
Linn 4,233
Marion 26,673

CASA of Oregon and the NOWIA Unete Center for Farm Worker Advocacy conducted
a stakeholder outreach survey of Latino/Latina/Latinx community members impacted
by the Almeda Fire (Jackson County). 31 At the onset of the fires, NOWIA Unete
supported more than 600 families by fulfilling basic needs, including food, clothing,
hotel rooms, and distance learning support for students. They are continuing to support
more than 300 families with hot meals, food vouchers, and food staples/hygiene
products, in addition to advocacy and educational services. NOWIA Unete started
surveying survivors in mid-April 2021 to offer a clearer picture of the needs of the Latino
farm worker and immigrant community they represent. Through this survey, 151 families
were interviewed, which included the following:

• 34 single-parent households
• An average family size of 3.2 members
• 30 people who identified as having a disability

31 Almeda Housing Survey, 2021.

37
• 5% older than age 62
• 24% younger than age 12
• 89% of a race and ethnicity other than white or non-Hispanic
• 89% whose primary or only language is Spanish

Of the people surveyed, more than 50% indicated that they have lived in the valley for
more than 20 years and, as such, have established roots and are anxious to return to
the communities they helped establish. The results also showed that before the 2020
Wildfires, 55% of the families were paying between $400 and $600 per month for rental
housing. In addition, the results show that 40.5% of the surveyed respondents can
comfortably afford housing payments between $300 and $600, 31% between $600 and
$800, and 19% between $800 and $1,000. The survey also gathered information on pre-
fire living arrangements, which yielded the following results:

• 57% lived in a manufactured home

• 21% lived in an apartment/other rental housing
• 18% lived in RVs
• 4% lived in other living arrangements

The respondents also provided information on their current living arrangements, which
are as follows:

• 5% had no reliable housing

• 8% had temporary housing through FEMA
• 15% had RVs
• 8% lived in hotels
• 20% lived in apartments
• 21% lived in a rented house
• 7% owned a house
• 6% lived in a trailer
• 10% lived in other living arrangements

While this information includes a limited population, it does help OHCS in the design of
their programs, their outreach and engagement strategies, and in how programs are
carried out to ensure that the diverse needs of wildfire survivors are met. For example,
OHCS is partnering and engaging with CASA of Oregon, community action agencies,
long-term recovery groups, and other community-based organizations to gather
additional information and to ensure that program design, engagement, outreach,

38
and program marketing strategies are inclusive and address the needs of those who
have been marginalized from the programs offered to date.

2.2.7.1.4 Impacts on Individuals and Households Experiencing Homelessness

Homelessness is a long-standing challenge facing Oregon that has been exacerbated
by COVID-19. According to the Oregon Statewide Shelter Study (August 2019), 32
Oregon has one of the highest homelessness rates in the country, with 50 or more
persons experiencing homelessness per 10,000 population, and an estimated need of
more than 5,800 shelter beds for both families with children and individuals experiencing
homelessness. The study found a particular need among certain groups, including
people of color, undocumented non-citizens, youth, and LGBTQ+ individuals.

Per the Oregon Community Foundation’s March 2019 report on Homelessness in

Oregon, while Oregon’s population represents 1.3% of the total U.S. population,
Oregon’s homeless population represents 2.6% of the total U.S. homeless population. In
addition, the report suggests that the State’s homelessness and housing dilemmas are
the result of two converging crises—an inadequate housing supply and rising rents that
are leaving tens of thousands of children and families in Oregon at risk of becoming
homeless, and the persistence of a smaller population of chronically homeless people
in need of intensive social services and specialized housing.33 Oregon’s long-standing
housing crisis meant that wildfire and other natural disaster survivors with the fewest
resources could not find a place to relocate, resulting in an increased need for non-
congregate sheltering after the wildfires and challenges in providing intermediate and
permanent housing solutions for wildfire survivors experiencing, or at risk of experiencing,
homelessness.

Estimating the number of homeless individuals was more difficult in 2021, as COVID-19
upended routines, reduced staffing and resources, and presented unexpected
complications. At the same time, COVID-19 caused economic disruption and the most
sudden and severe contraction in the U.S. economy in decades, resulting in millions of
individuals and households losing their jobs. Many formerly stable households found
themselves facing food shortages and the loss of their homes. While government and
the nonprofit sector addressed some of these hardships, the scale of the problem made
it difficult to help everyone.

There were many reasons to believe that the size and composition of the population of
people experiencing homelessness may have changed in 2021; however, COVID-19
made it harder to isolate the impacts from the 2020 Wildfires and the impacts from
COVID-19. The table below compares the 2019 point-in-time (PIT) count with the 2021
(sheltered and unsheltered) PIT count. All eight wildfire-impacted counties experienced

32 https://www.oregon.gov/ohcs/about-us/Documents/poverty/Oregon-Statewide-Shelter-Study.pdf
33 https://oregoncf.org/community-impact/research/homelessness-in-oregon/

39
increases in homelessness from 2019 to 2021, with the largest increases in Marion (250)
and Clackamas (247) counties.

Table 24: Point-in-Time by County

2019 2021 Increase From

County Homelessness PIT Homelessness PIT 2019 to 2021
Clackamas 419 666 247
Douglas 542 594 52
Jackson 712 831 119
Klamath 207 421 214
Lane 2,165 2,379 214
Lincoln 260 283 23
Linn 277 380 103
Marion 974 1224 250
TOTAL 5,556 6,778 1,222
Source: Oregon Statewide Homelessness Estimates 2021 Report

OHCS obtained certain available usage data from its State Homeless Assistance
Program (SHAP) to demonstrate quantitative impacts (as expressed by the number of
households served) on SHAP-funded homelessness services. However, these data do
not necessarily represent only wildfire-related impacts:

• Lane County saw an overall increase from 1,132 households served in July–August
2020, to 1,677 households served in September–October 2020, to 2,412 households
served in December 2020 – January 2021. Of the households served, 89% were
childless adults.
• Marion County saw an overall increase from 742 households served in July–August
2020, to 971 households served in September–October 2020, to 1,107 households
served in December 2020 – January 2021. More than 80% of the households served
were childless adults.
• Jackson County saw a slight decrease from 206 to 194 in the number of households
served from July–August to September–October 2020, followed by an overall
increase to 253 served in December 2020 – January 2021. Of the households served,
80% were childless adults.
Oregon state and US federal legislatures allocated hundreds of millions of dollars for
COVID-19 recovery in Oregon, specifically to be used for homelessness sheltering,
supports and prevention, including through state emergency board funds, state house
bills, the US Treasury Emergency Rental Assistance Program and Homeowner Assistance
Fund, HUD HOME-CV, and HUD ESG-CV.

40
2.2.7.1.5 Rural Housing Challenges
Oregon’s pre-disaster housing stock was concentrated near metropolitan areas. This is
because Oregon is one of the few states that has established urban growth boundaries
(UGB), 34 which promote growth in urban zones while also restricting residential
development of rural farm and forest land. Thus, the low level of pre-disaster housing
stock in rural areas has made community housing stock especially vulnerable to natural
hazards, such as wildfires, flooding, and landslides. This, in combination with the
shortage of labor and construction supplies, has added to the challenges faced by
rural communities in rebuilding and replacing destroyed housing.

These challenges are addressed in the State’s CDBG-DR program design by considering
current labor and supply costs and shortages when calculating awards and
determining cost reasonableness. The State will work with residents and local
governments to ensure homes are built in line with UGB requirements, and to standards
that make them more energy efficient and resilient to the spectrum of natural hazards
faced in the rural impacted areas – not just wildfires. The State will allow for the repair or
replacement of damaged private infrastructure - such as septic tanks and wells - in its
housing programs.

2.2.7.1.6 Underserved Communities

The State has mapped the burn scar areas from the 2020 Wildfires with the geographic
boundaries of Tribal Areas and Opportunity Zones in Figures 3 through 6 below. These
maps identify those areas that HUD has identified as underserved communities at the
census tract level (Opportunity Zones) and on the Tribal Area scale. Due to the rural
and diverse nature of the impacts from the 2020 Wildfires, OHCS also will use more
refined and focused data analysis, mapping, and community data gathered through
the Action Plan and the program design stakeholder consultation process to
understand which neighborhoods and communities have been historically
underserved. The State will also review other information that may indicate whether a
community is underserved, including those census tracts that were eligible for
opportunity zone designation and areas eligible for New Market Tax Credits.

34 https://www.oregon.gov/lcd/UP/Pages/Urban-Planning.aspx

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Figure 3: Map of Burn Scar, Tribal Boundaries, and Opportunity Zones in Jackson County

Figure 4: Map of Burn Scar, Tribal Boundaries, and Opportunity Zones in Klamath County

42
Figure 5: Map of Burn Scar, Triba l Boundaries, and Opportunity Zones in Marion County

Figure 6: Map of Burn Scar, Tribal Boundaries, and Opportunity Zones in Lincoln County

43
2.2.7.1.6.1 Tribal Areas
Tribal lands representing four American Indian Tribes are located within the impacted
areas. They are the Coquille Tribe, Cow Creek Band of Umpqua Tribe of Indians, the
Klamath Tribes, and the Confederated Tribes of Siletz Indians. 35

None of these four tribes in and/or near the wildfire impact areas have large
reservations or tracts of native-owned lands, or housing that sustained damage by the
wildfires. Rather, their enrolled tribal members live throughout the State and nationally.

• The Coquille Indian Tribe, located on the southern Oregon coast, near Coos Bay in
Coos County, has 1,100 enrolled tribal members. The Coquille Indian Tribe has a
10,000-acre tribal land base.
• The Cow Creek Band of the Umpqua Tribe of Indians, located in southwestern
Oregon in Roseburg, has 1,800 members. The Cow Creek Band of Umpqua Tribe of
Indians does not have reservation lands.
• The Klamath Tribes include the Klamath, Modoc, and Yahooskin Tribes and are in the
Klamath Basin, in southcentral Oregon, with a population of approximately 5,400.
• The Confederated Tribes of Siletz Indians consist of 27 individual tribes in the
Willamette and Umpqua Valleys in central western Oregon, with an enrolled
population of 4,084 members. The Siletz Tribes own a 5.8-square mile reservation in
Lincoln County.
• The Confederated Tribes of the Warm Springs included elements of the Warm
Springs, Wasco, and Paiute Tribes. The Tribe has over 5,000 members and a 1,019 sq
mile reservation in north-central Oregon. The reservation was directly impacted by
the 2020 Lionshead Fire. Almost 100,000 acres of timber lands on the reservation
were impacted, but no structures were lost.
American Indian/Alaska Native tribal members from outside of Oregon also reside in
and were impacted in the declared counties. Some of these tribal members
evacuated during the wildfire and returned to their reservations or tribal areas where
they were provided with shelter and services, some doubled up with other tribal
members, and some relied on the American Red Cross and State non-congregate
sheltering resources (reports received from the HUD Northwest Office of Native
American Programs and FEMA Tribal Liaison) for sheltering and food needs.

This is significant when it comes to resources as there may be additional potential

resources for Tribal members seeking disaster assistance, although these funding
sources may have been insufficient to meet long-term recovery unmet needs.

35 HUD Housing Impact Assessment, DR-4562-OR, pp. 29–30.

44
2.2.7.1.6.2 Opportunity Zones
Opportunity Zones were created under the Tax Cuts and Jobs Act of 2017. They are
low-income communities and certain neighboring areas, defined by population census
tract, that were nominated by states for the designation, then certified by the
U.S. Department of the Treasury. Their purpose is to spur economic growth and job
creation in low-income communities while providing tax benefits to investors. 36
As demonstrated in the maps above, the 2020 Wildfire-impacted areas that are either
within or border Opportunity Zones fall in the following counties:

• Jackson County
• Klamath County
• Lincoln County
• Marion County

2.2.7.1.6.3 Social Vulnerability Index and Disadvantaged Communities

In 2021, President Joe Biden signed Executive Order 14008, Tackling the Climate Crisis at
Home and Abroad. The Executive Order states that “40 percent of the overall benefits”
of federal investments from covered programs should flow to disadvantaged
communities. 37 This is to ensure that any federal funds directed toward climate
mitigation and adaptation largely benefit historically underserved communities. One of
the ways that agencies and covered programs benefit disadvantaged communities is
by identifying target populations with the Centers for Disease Control and Prevention’s
(CDC) Social Vulnerability Index.

The CDC’s Agency for Toxic Substances and Disease Registry’s (ATSDR) Social
Vulnerability Index (SVI) ranks counties and census tracts on 15 social factors, including
unemployment, minority status, and disability, and then further groups them into four
related themes. The SVI ranking variables for the four themes include Socioeconomic
Status, Household Composition & Disability, Minority Status & Language, and Housing
Type & Transportation. These indicators help support analysis on the relative vulnerability
of a given census tract and help identify communities that will need continued support
to recover following an emergency or natural disaster. The attached map shows the
overall ranking (RPL_Themes), which is a percentile ranking that represents the
proportion of tracts that are equal to or lower than a tract of interest in terms of social
vulnerability. For example, a CDC/ATSDR SVI ranking of 0.60 signifies that 60% of tracts in
the State or nation are less vulnerable than the tract of interest and 40% of tracts in the
State or nation are more vulnerable.

36 https://www.irs.gov/credits-deductions/businesses/opportunity-zones
37 https://www.whitehouse.gov/wp-content/uploads/2021/07/M-21-28.pdf

45
Both Klamath and Marion counties have an SVI percentile of more than 0.8 (0.91 and
0.88, respectively), indicating that their populations are more vulnerable than 80% of
other counties in the United States. In addition, Jackson, Douglas, Lane, and Linn
counties all have an SVI percentile above 0.5 (0.71, 0.68, 0.54, and 0.57, respectively).
At the finer level of detail provided by the census tract map, it is clear that the 242 Fire
(Klamath County), Almeda Fire (Jackson County), and Archie Creek Fire (Doulas
County) took place in census tracts with high SVI.

Figure 7: Overall Social Vulnerability Index Percentile in Oregon Counties

46
Fgure 8: Social Vulnerability Index Percentile by Census Tract and Burn Scar Areas

2.2.7.1.7 Coordination and Engagement

There have been multiple regional, local, and statewide planning efforts undertaken
prior to and since the 2020 Wildfires that either directly or indirectly inform the State’s
recovery to date and which serve as the foundation for the CDBG-DR Public Action
Plan. Through the data analysis carried out in the Unmet and Mitigation Needs
Assessments and drawing from the planning and strategy coordination described
below, the State has outlined the following guiding principles for CDBG-DR program
decision making. The State of Oregon is committed to the following:

• Advancing equity and racial justice and supporting vulnerable populations and
underserved communities.
• Rebuilding homes and communities so that they are more resilient to current and
projected hazards.

2.2.7.1.7.1 Oregon’s Commitment to Increased and Ongoing Coordination and Engagement to Provide
Equal Opportunities for Disaster Assistance
OHCS is working closely with various local organizations, including local elected officials,
recovery groups, community action agencies and culturally specific organizations and
community-based organizations. OHCS and other state agencies have been
collecting information from local partners since the early days of the recovery, and

47
there are many themes that have emerged from those working with individuals with
lived disaster experiences.

• Across the impacted areas, there are many residents who were living in less
traditional housing situations who have not yet been able to access recovery
assistance. This has been a particular barrier for the Latina/o/x community.
This includes individuals and households living in recreational vehicles, multi-
generational families living on a single-property, living in sheds on rural properties,
and/or other doubled-up situations.
• Rural communities that were impacted were already facing a significant housing
crisis and the relative loss of housing to the pre-disaster housing stock has
devastated many communities. Many communities are concerned their residents
will not return because the town has been destroyed, due to lack of housing, lack of
employment opportunities, and/or because they have resettled elsewhere.
• Local and private infrastructure that was there before the disaster was outdated
and needs to be replaced with infrastructure that meets code and accommodates
rebuilding affordable and resilient housing
• Land availability and costs are some of the biggest barriers to recovering in a
manner that is affordable, particularly in Southern Oregon
• There is insufficient affordable housing stock available for people to rent while they
work to complete their recovery
• Many homeowners continue to struggle with receiving assistance from their
insurance companies for eligible damages
• Most homeowners – including site-built and manufactured homeowners – were
underinsured, if they had any homeowner’s insurance
As described in the program sections of this Action Plan, OHCS will ensure its CDBG-DR
programs are designed to address the diverse and unique needs faced by different
communities across the 2020 Wildfires.

2.2.7.1.7.2 Regional Housing Needs Assessment

Oregon’s State legislature passed House Bill (HB) 2003 in 2019, establishing a
transformative approach to planning and programming to resolve the ongoing
affordable housing crisis. A portion of HB 2003 directed OHCS to create a methodology
to conduct Oregon’s first statewide Regional Housing Needs Analysis (RHNA). The goal
of the report was to standardize a housing forecasting methodology so that cities could
have a clearer image of the affordable housing production goals that they need to
meet. This would ensure that cities could take responsibility for contributing to statewide
housing goals. After OHCS developed the initial report, DLCD was tasked with reviewing
the RHNA to determine whether the RHNA provides a realistic affordable housing goal
for Oregon’s regions. DLCD reviewed the report and strongly recommended that the

48
State legislature adopt the RHNA and task OHCS and DLCD to begin its implementation
and use. 38 On March 1, 2021, OHCS submitted and presented their report to the State
legislature along with DLCD’s assessment.

Key takeaways from OHCS’s RHNA methodology include the following:

• Over the next 20 years, Oregon will need to build about 584,00 new homes. 39
– This means that Oregon’s developers will need to build 30,000 to 40,000 units
every year.
– The Portland metropolitan area, Deschutes County, and the Willamette Valley
will experience the greatest amount of production pressure.
• Nearly a quarter of these homes are currently needed to address current housing
shortages.
OHCS’s RHNA was conducted with extensive stakeholder outreach and coordination.
The methodology used to determine overall regional need consisted of estimates for
projected need, current underproduction, and housing for people experiencing
homelessness. Using this methodology, OHCS was able to estimate the number of future
housing needs by unit type and income level. OHCS was able to create a regional fair
share approach to affordable housing planning across the State.40

Currently, OHCS and DLCD are working with stakeholder groups and the State
legislature to create an RHNA implementation plan. OHCS has created regular
legislative reports and is working with the RHNA working group to publish a final RHNA
report by the end of 2022.41

2.2.7.1.7.3 OHCS and the Oregon Disaster Recovery Housing Task Force
The Oregon Disaster Recovery Plan was developed by the Oregon Military Department
and OEM and published in March 2018. 42 The plan is an all-hazards document that
gives the State a scalable recovery organization that can be implemented for incidents
of varying levels of complexity. This plan guides the State’s recovery operations while
complementing and supporting the response and recovery plans and procedures of
responding agencies; local and tribal governments; special districts; and other public,
nonprofit/volunteer, and private sector entities.

38 https://olis.oregonlegislature.gov/liz/2021r1/Downloads/CommitteeMeetingDocument/244208
39 https://www.oregon.gov/ohcs/about-us/Documents/RHNA/RHNA-Technical-Report.pdf
40 https://www.oregon.gov/ohcs/about-us/Documents/RHNA/02-21-2021-ECONW-OHCS.pdf
41 https://www.oregon.gov/lcd/UP/Documents/20211028_RHNA_WorkGroup_Mtg1.pdf
42 https://www.oregon.gov/oem/Documents/OR_RECOVERY_PLAN_MARCH_2018.pdf

49
The plan outlines seven State Recovery Functions (SRFs), which serve as the State’s
organizing structure for coordinating a recovery and supporting local and tribal
recovery organizations. Each SRF has defined responsibilities; however, the SRFs are
designed to work together to rebuild housing in Oregon, recognizing the nexus of
housing recovery and all SRFs. Oregon’s SRF framework aligns with federal Recovery
Support Functions to facilitate and accelerate communication, whole community
coordination, and delivery of resources. Each SRF is led by a coordinating agency or
team (see the table below).

Table 25: State Recovery Function by Agency

State Recovery Function (SRF) Coordinating Agency or Team
1 – Community Planning Oregon Department of Land Conservation and
and Capacity Building Development
2 – Economic Recovery Business Oregon
3 – Health Services Oregon Health Authority
4 – Social Services Oregon Department of Human Services
5 – Disaster Housing Oregon Housing and Community Services
6 – Infrastructure Systems Oregon Department of Administrative Services, Oregon
Department of Energy, Oregon Department of
Transportation, Public Utility Commission of Oregon
7 – Natural and Cultural Oregon Department of Environmental Quality
Resources

OHCS is the designated lead agency for SRF 5, which is responsible for addressing pre-
and post-disaster housing issues; facilitating the delivery of State resources to assist local
and tribal governments in the rehabilitation and reconstruction of destroyed and
damaged housing; and developing new accessible, long-term housing options. 43 As an
organization, OHCS is committed to ensuring that all Oregonians have the opportunity
to pursue prosperity and live free from poverty, with an agency mission of providing
stable and affordable housing and engaging leaders to develop and integrate a
statewide policy that addresses poverty and provides opportunities for Oregonians.

In the course of responding to the 2020 Wildfires through SRF5, OHCS and coordinating
agencies created the Oregon Disaster Housing Task Force, which includes multiple
State, federal, regional, local, and nonprofit organizations. In the beginning days of the
recovery, the Task Force committed to focusing on equity and racial justice in disaster
recovery, following the State of Oregon Equity Framework,44 which defines the following
historically and currently underserved communities:

43 https://www.oregon.gov/oem/Documents/OR_RECOVERY_PLAN_MARCH_2018.pdf
44 State of Oregon Equity Framework in COVID-19 Response and Recovery.

50
• Native Americans, members of Oregon’s nine federally recognized tribes; American
Indians; Alaska Natives
• Black, Africans, African Americans
• Latinx, Hispanic
• Asian, Pacific Islanders
• Immigrants, refugees, asylum seekers
• Undocumented, DREAMers
• Linguistically diverse
• People with disabilities
• LGBTQ+
• Aging/Older adults
• Economically disadvantaged
• Agricultural workers, migrant workers
• Those living in rural parts of the State

Through the course of their work, the Task Force developed the following goals and
strategies for the State’s recovery, which have been further detailed in the State’s
Disaster Housing Recovery Action Plan, completed in June 2021. These goals include
strategies focusing on equity and racial justice.

• Goal 1: Create intermediate housing solutions. Provide short-term living solutions for
wildfire survivors to meet basic needs with a focus on providing the support and
services necessary to find and secure longer term housing.
• Goal 2: Bolster local capacity. Increase local capacity to promote an intermediate
and permanent housing supply.
• Goal 3: Expedite the delivery of permanent housing solutions. Provide cross-cutting
strategies that facilitate all housing types, tenures, and income levels that result in
new construction and reconstruction in wildfire-impacted counties by 2025.
• Goal 4: Build community and family resilience. Ensure that, as families and
communities rebuild, they can incorporate lessons from the 2020 Wildfires and
strengthen their ability to withstand future natural disasters with minimal disruption.

The Disaster Housing Recovery Action Plan serves as a foundational document for the
work that OHCS has carried out through the development of the CDBG-DR Action Plan.

51
2.2.7.1.7.4 Governor’s Wildfire Economic Recovery Council
Oregon Governor Kate Brown established the Wildfire Economic Recovery Council
(WERC) in October 2020 to evaluate the economic and community needs of
Oregonians statewide following the 2020 wildfire season. Membership included more
than 40 leaders from across the State, including elected officials, business and nonprofit
representatives, philanthropy community leaders, tribal leaders, federal delegation
representatives, State agencies, and the Office of the Governor. WERC also established
a regional response team that included representatives from FEMA, Regional Solutions,
and key State and local agencies. The eight Regional Solutions coordinators served as
a key interface between State and local recovery efforts, including standing up
regional councils and elevating issues to the Governor’s Council. 45

WERC published a report 46 of its findings and key recommendations to provide direction
to State agencies as they set out to implement the actions enumerated in the SRFs. The
report also suggested specific investments to the Oregon state legislature. The report
includes 23 recommendations centered on housing and sheltering, debris and cleanup,
and recovery and rebuilding. The recommendations that are key to recovery and
rebuilding are as follows:

• Focus on equitable delivery of emergency preparedness and recovery programs to

ensure that underrepresented community members have a voice.
• Leverage public investment to rebuild the housing units that were lost in the
impacted communities.
• Bolster community support and workforce development so that communities are the
authors of their own recovery.
• Use State funds to fully leverage FEMA’s Hazard Mitigation Grant Program to reduce
future wildfire and associated risks, prioritizing the communities impacted by the
2020 Wildfires.
• Ensure that FEMA mitigation funds are considered for all FEMA Public Assistance
Program repair or replacement projects.
• Address utility issues related to sewer systems, broadband, water quality, and power
lines.

45 Governor’s Wildfire Economic Recovery Council Wildfire Report

46 Governor’s Wildfire Economic Recovery Council Wildfire Report

52
2.2.7.1.7.5 HB 2100: Task Force on Homelessness and Racial Disparities in Oregon
In June 2021, the 81st Oregon Legislative Assembly passed House Bill 2100. One
component of this bill was the establishment of a 19-member Task Force on
Homelessness and Racial Disparities in Oregon. This group was tasked with developing a
report to identify and investigate methods by which the State could decrease the rates
of racial disparity among people experiencing homelessness and propose
recommendations to the State legislature for potential changes to funding structures,
methods for distributing information about needed services, and methods to modify
contracting processes and eligibility for the providers of services for individuals
experiencing homelessness and housing insecurity.

The Task Force published their report in January 2022.47 To develop meaningful
recommendations, the Task Force investigated existing datasets, both looking at
national statistics and Oregon-specific information. What the data demonstrated is that
the percentage of homelessness is greater than the percentage of the population in
Oregon for Black, American Indian or Alaska Native, and Native Hawaiian or Other
Pacific Islander (in some cases, as much as four times more homelessness than their
share of the total State population).

In addition to data analytics, the Task Force conducted surveys, interviews, and working
groups. Ultimately, the Task Force generated 35 recommendations to address the four
goals laid out in HB 2100. Many of these recommendations focus on aligning State
activities and federal programs administered by the State in a way that takes
measurable steps toward prioritizing equity and inclusion, such as more meaningful
engagement with people with lived experiences to move them from below the radar in
planning processes to acting as influencers.

As the work of this Task Force has occurred during the critical time between the disaster
event and the establishment of meaningful housing programs with CDBG-DR resources,
through close coordination and management from OHCS, the State is well positioned
to act on these recommendations and the data collected through this process.

47Findings and Recommendations of the Task Force on Homelessness and Racial Disparities in Oregon,
House Bill 2100.

53
2.2.7.2 Statewide Demographics and Disaster-Impacted Populations
Table 26: Race and Ethnicity
Disaster Disaster
State State Declaration Declaration MID MID
Demographic Estimates Percentage Estimates Percentage Estimates Percentage
Total 4,237,256 100% 3,842,459 100% 1,733,170 100%
Population
Single Race 3,793,917 89.54% 3,439,278 89.51% 1,553,598 89.64%
White or 3,169,096 74.79% 2,864,143 74.54% 1,299,935 75.00%
Caucasian
Minority 624,821 14.75% 978,316 25.46% 191,169 11.03%
Black or 82,655 1.95% 1.43% 16,389 0.95%
African
American 54,857
American 62,993 1.49% 4.94% 23,273 1.34%
Indian and/or
Alaska Native 189,929
Asian 194,538 4.59% 79,980 2.08% 44,573 2.57%
Native 19,204 9.87% 0.47% 7,374 0.43%
Hawaiian and
Other Pacific
Islander 17,897
Some Other 265,431 6.26% 6.05% 99,560 5.74%
Race 232,472
Two or More 443,339 10.46% 10.49% 172,653 9.96%
Races 403,181
Hispanic 588,757 13.89% 520,224 13.54% 228,337 13.17%
or Latino
Source: 2020 Decennial Census Redistricting Data.

54
Table 27: Age and Sex
Disaster Disaster
State State Declaration Declaration MID MID
Demographic Estimates Percentage Estimates Percentage Estimates Percentage
Total 4,129,803 100% 3,751,199 100% 1,622,727 100%
Population
Under Age 5 230,557 5.60% 208,584 5.56% 90,317 5.57%
Under Age 18 867,943 21.00% 783,754 20.89% 345,288 21.28%
Over Age 65 709,555 17.20% 634,413 16.91% 305,035 18.80%
Male 2,047,388 49.60% 1,856,102 49.48% 799,955 49.30%
Female 2,082,465 50.40% 1,895,097 50.52% 822,772 50.70%
Source: ACS 5-Year Estimates (2015–2019).

Table 28: Social Vulnerability and Protected Classes

Disaster Disaster
State State Declaration Declaration MID MID
Demographic Estimates Percentage Estimates Percentage Estimates Percentage
Total 4,081,943 100% 3,707,150 100% 1,603,564 100%
Population
Persons with 584,576 14.32% 275,830 7.44% 246,377 15.36%
Disabilities
Single-Parent 125,899 3.08% 62,093 1.67% 52,077 3.25%
Households
Speaks 114,957 2.82% 68,004 1.83% 34,609 2.16%
English “Less
Than Well”
Foreign-Born 405,821 9.94% 255,971 6.90% 121,139 7.55%
Source: ACS 5-Year Estimates (2014–2018).

55
2.2.7.3 Education Demographics
Table 29: Education Demographics
Education
(population Disaster Disaster
age 25 and State State Declaration Declaration MID MID
older) Estimates Percentage Estimates Percentage Estimates Percentage
High School 659,085 22.70% 585,653 15.61% 282,478 6.84%
Graduate or
Equivalent
Some 737,003 25.40% 666,484 17.77% 310,875 7.53%
College, No
Degree
Associate’s 257,692 8.90% 233,202 6.22% 105,324 2.55%
Degree
Bachelor’s 975,920 33.70% 687,916 18.34% 322,503 7.81%
Degree or
Higher
Source: ACS 5-Year Estimates (2015–2019).

2.2.7.4 Income Demographics

Table 30: Income
Income/Economic Counties Impacted
Demographics Statewide by Disaster MIDS
Median Household Income $62,818 $55,250 $56,713
Per Capita Income $33,763 $95,214 $30,067
Persons with Income Below the 951,718 482,659 217,235
Poverty Level in the Past 12
Months
Source: ACS 5-Year Estimates (2015–2019).

2.2.7.5 LMI Analysis – Statewide

Table 31: Statewide LMI
Category Total LMI Persons Total Population Percentage of LMI
Statewide 644,694 4,129,803 15.61%
Source: ACS 5-Year Estimates (2015–2019).

56
2.2.7.6 LMI Analysis – Federally Declared Disaster Areas
Table 32: LMI by County
Non-MID Non-MID Non-MID MID Total MID
Total LMI Total Percentage LMI MID Total Percentag
County Persons Population LMI Persons Population e of LMI
HUD and Grantee MIDs
Clackamas – – – 136,390 389,438 35.02%
Douglas – – – 44,055 107,194 41.10%
Jackson – – – 86,430 208,363 41.48%
Klamath 28,160 65,972 42.68% – – –
Lane – – – 150,985 357,060 42.29%
Lincoln – – – 18,145 46,347 39.15%
Linn – – – 49,164 118,971 41.32%
Marion – – – 131,365 323,259 40.64%
Other Impacted Counties
Benton 39,545 86,495 45.72% – – –
Columbia 22,685 49,389 45.93% – – –
Coos 26,330 62,775 41.94% – – –
Deschutes 64,224 166,622 38.54% – – –
Jefferson 8,795 22,061 39.87% – – –
Josephine 37,925 83,409 45.47% – – –
Lake 3,675 7,842 46.86% – – –
Multnomah 360,560 768,418 46.92% – – –
Tillamook 9,735 25,430 38.28% – – –
Wasco 9,409 25,492 36.91% – – –
Washington 208,570 556,210 37.50% – – –
Yamhill 47,315 101,119 46.79% – – –
Source: ACS 5-Year Estimates (2011–2015).

57
2.2.7.7 Manufactured Homes Impacted by Disaster
Table 33: Manufactured Homes
County No. of Units Percentage of Total Units in County
Clackamas 19 7.0%
Douglas 32 5.2%
Jackson 938 53.4%
Klamath 4 10.8%
Lane 84 21.1%
Lincoln 126 53.6%
Linn 24 18.6%
Marion 76 19.2%
Source: FIDA 40449 DR-4562, February 17, 2022.

2.2.7.8 SNAP and D-SNAP Applicants Impacted by Disaster

Table 34: SNAP and D-SNAP Applicants Impacted by Disaster

# SNAP # SNAP # Households # Individuals

County Households Individuals Issued D-SNAP Issued D-SNAP
HUD and Grantee MIDs
Clackamas Data pending Data pending 40 Data pending
Douglas Data pending Data pending 207 Data pending
Jackson Data pending Data pending 417 Data pending
Klamath Data pending Data pending 36 Data pending
Lane Data pending Data pending 181 Data pending
Lincoln Data pending Data pending 160 Data pending
Linn Data pending Data pending 93 Data pending
Marion Data pending Data pending 416 Data pending
Source: ODHS DCM Profile Report
2.2.7.9 Limited English Proficiency Breakdown
Table 35: Breakdown of Limited English Proficiency
Estimate Speaking English Percentage Speaking English
County Less Than “Very Well” Less Than “Very Well”
Clackamas 6,971 1.80%
Douglas 554 5.00%
Jackson 3,675 1.80%
Klamath 1,095 1.80%

58
Lane 3,923 1.10%
Lincoln 296 6.00%
Linn 1,452 1.30%
Marion 17,738 5.70%
Source: ACS 5-Year Estimates (2014–2018).

59
2.2.7.10 Languages Spoken Within the State

Table 36: Languages Spoken within the State

Estimate Percentage
Languages Spoken Number Population of Population County
Spanish 8,523 2.08% Clackamas
Chinese 1,713 0.42% Clackamas
Russian 1,447 0.35% Clackamas
Spanish 862 0.79% Douglas
German 56 0.05% Douglas
Other Pacific Islander 46 0.04% Douglas
Language
Spanish 5,734 2.65% Jackson
French 190 0.09% Jackson
Other Pacific Islander 177 0.08% Jackson
Language
Spanish 1,442 2.15% Klamath
Tagalog 36 0.05% Klamath
Thai 35 0.05% Klamath
Spanish 5,872 1.57% Lane
Chinese 1,566 0.42% Lane
Hungarian 469 0.13% Lane
Spanish 1,164 2.40% Lincoln
Tagalog 37 0.08% Lincoln
German 30 0.06% Lincoln
Spanish 1,714 1.37% Linn
Tagalog 87 0.07% Linn
Vietnamese 66 0.05% Linn
Spanish 27,117 7.98% Marion
Russian 1,695 0.50% Marion
Chinese 594 0.17% Marion
Source: ACS 5-Year Estimates (2015–2019).

60
2.2.7.11 Affected Continuum of Care Entities
Table 37: Affected Continuum of Care Entities
CoC Impacted Homeless
Number CoC Entity County Count
Clackamas Clackamas 492
OR-507 County
Continuum
Rural Douglas 197
OR-505 Oregon
Continuum
Jackson Jackson 766
OR-502 County
Continuum
Rural Klamath 261
OR-505 Oregon
Continuum
Lane Lane 2317
OR-500 County
Continuum
Rural Lincoln 36
OR-505 Oregon
Continuum
Rural Linn 320
OR-505 Oregon
Continuum
Source: Oregon Statewide Homelessness Estimates 2021 Report, includes sheltered and
unsheltered individuals

2.2.7.12 Point-in-Time Count – Type of Shelter

Table 38: Point in Time County – Type of Shelter

Emergency Transitional Unsheltered Total Known

Scale of Data Shelter Housing Homeless Homeless
Clackamas N/A 191 301 492
Douglas N/A 197 0 197
Jackson N/A 342 424 766
Klamath N/A 23 238 261
Lane N/A 327 1990 2317
Lincoln N/A 36 0 36
Linn N/A 238 82 320
Source: Oregon Statewide Homelessness Estimates 2021 Report

61
2.2.7.13 Point-in-Time Count – Impacted by Disaster
Table 39: Point-in-Time Count – Impacted by Disaster
Emergency Transitional Unsheltered Total Known
Scale of Data Shelter Housing Homeless Homeless
Clackamas 0 191 301 492
Douglas 1 197 0 198
Jackson 248 342 424 1,014
Klamath 6 23 238 267
Lane 88 327 1990 2,405
Lincoln 59 36 0 95
Linn 0 238 82 320
Source: Oregon Statewide Homelessness Estimates 2021 Report and Non-Congregate Shelter
Data from ODHS (April 2022)

2.2.7.14 HUD-Assisted Housing Impacted by Disaster

Table 40: HUD-Assisted Housing Impacted by Disaster
Total Total
Impacted- Impacted
Total Housing Total Public Public
Housing Choice Total Total Housing Housing
Choice Voucher LIHTC* Impacted Dwelling Dwelling
County Vouchers Units Units LIHTC Units Units Units
TOTAL 12,104 75 3,020 0 8,582 0
(Clackamas,
Douglas,
Jackson,
Klamath,
Lane,
Lincoln, Linn,
and Marion)
* LIHTC – Low-Income Housing Tax Credit Program

62
2.3 Infrastructure Unmet Needs
2.3.1 Statewide Infrastructure Loss and Damages
FEMA, Oregon State agencies, and local communities have identified considerable
impacts on public facilities and infrastructure from the 2020 Wildfires. While FEMA has
determined more than $581 million in damages to be eligible under its Public Assistance
Program, that number does not reflect the entirety of the 2020 Wildfires’ impact. Not
only was the damage considerable in scale, but the wildfires also impacted a wide
range of facility types, including public buildings, roads and bridges, utilities, and parks.

2.3.1.1 Roads and Bridges

Many roads and bridges were damaged and/or forced to close as a result of the
2020 Wildfires, many for an extended period of time. At least nine State highways and
two interstate highways were forced to close due to fire hazards and many remained
closed until the damage could be repaired. Several towns in Jackson County, including
Phoenix and Talent, suffered significant damage to roads, street signs, and guardrails.
Many roads suffered further damage from unusually-high usage by heavy equipment
during clean-up, debris removal and hazard debris removal phases of recovery.

2.3.1.2 Buildings and Equipment

The 2020 Wildfires also had a devastating impact on buildings and equipment in the
State—at least 923 nonresidential buildings across seven counties were damaged or
destroyed, including fire stations in McKenzie Bridge, White City, and Phoenix. Jackson
County also lost several vehicles, outbuildings, tools, and equipment. Also, in Phoenix,
the Southern Oregon Education Service District lost its entire campus.

2.3.1.3 Utilities
Perhaps the costliest infrastructure damage occurred to utilities, including power
generation and distribution, water treatment and distribution, and communications.
In Lane County alone, more than 40 miles of electrical infrastructure required complete
replacementas did significant public safety communications infrastructure. Several
citizens did not receive evacuation notices after a communications tower on Mt.
Hagen was destroyed.

A total of 146 public water systems were affected by the 2020 Wildfires, including 50
with surface water sources and 96 with groundwater source areas within the wildfires’
perimeters. The initial wildfire impacts interrupted electrical power and limited access to
water treatment plants, prompting many water systems to issue boil water notices due
to a loss of system pressure. In addition to water quality issues, some water systems, such
as the Blue River Water District, suffered damage to their delivery system, which resulted
in a loss of the potable water function. Over the long term, changes in watersheds

63
caused by the 2020 Wildfires may increase treatment costs, diminish reservoir capacity,
and even result in the need for alternative water sources.

In addition to the destruction to existing public water systems, many rural residents,
businesses, and local governments were on private septic and well systems. Prior to the
wildfires, many communities were contemplating the timing, cost analysis, and need for
municipal water and wastewater treatment systems. With the destruction from the
wildfires and new Oregon building codes, many residential properties repairs can no
longer be grandfathered into allowing for pre-disaster infrastructure replacement.
Based on initial estimates from local governments across the impacted areas, there are
over $300 million in post-disaster municipal water and sewerage system needs to
comply with current more resilient standards. These costs are not eligible under FEMA PA
because the needed infrastructure did not exist prior to the disaster.

2.3.1.4 Parks, Recreation, and Other Facilities

The 2020 wildfire season also had a significant impact on the State’s public recreation
facilities and natural resources, resulting in the closure of many Oregon Department of
Forestry, Oregon Parks and Recreation, U.S. Bureau of Land Management, U.S. Forest
Service National Forests and Scenic Areas, and U.S. Army Corps of Engineers recreation
areas, some of which remained closed for extended periods. . The Labor Day fires
burned more than 16,000 acres of the Santiam State Forest, including several popular
recreation sites, roads, and natural resources, some of which remain closed as of this
writing. Numerous recreation sites were also impacted along the North Umpqua River
by the Archie Creek Fire. Highway 224, which leads to a popular recreation corridor
along the Clackamas River, remained closed for over a year after the fire.48 In addition
to the emergency work and permanent costs that resulted from these damages, the
State also lost considerable revenue from tourism, recreation, and visitation, upon which
its economy relies.

2.3.1.5. Local Capacity Challenges for Navigating Post-Fire Complexities

Many local government officials and nonprofit leaders in MID areas have reported that
they do not have the capacity or resources to support the effort necessary to address
the many remaining overwhelming needs.
Their tax bases have also been diminished. From the community perspective, they need
resources to be able to continue the rebuilding process.49

48https://www.wweek.com/outdoors/2022/01/28/highway-224-in-the-fire-damaged-clackamas-river-
corridor-is-one-step-closer-to-reopening/
49 Governor’s Wildfire Economic Recovery Council, p. 13.

64
2.3.2 FEMA Programs
FEMA’s Public Assistance Program (PA) provides supplemental grants to State, tribal,
territorial, and local governments, and certain types of private nonprofits so that
communities can quickly respond to and recover from major disasters or emergencies.
FEMA also encourages the protection of these damaged facilities from future events by
providing assistance for hazard mitigation measures during the recovery process.

To access FEMA PA funds, eligible applicants must submit a request for grant funds to
the PA primary grant recipient, which in the case of Oregon is the Office of Emergency
Management, which evaluates eligibility for PA with FEMA. For DR-4562, FEMA is
authorized to reimburse not less than 75% of the eligible costs of specific types of
disaster response and recovery work undertaken by eligible applicants. FEMA may
recommend that the President increase the federal cost share, where warranted.
Oregon has requested an increase in the federal share for DR-4562; however, this
request was not approved. However, see below, the cost share was later adjusted
nationally.

FEMA PA-eligible activities include short-term emergency work and long-term

permanent work. Emergency work is divided into two categories: Debris Removal
(Category A) and Emergency Protective Measures (Category B). Direct assistance for
debris removal is provided if FEMA determines that such work is in the public interest.
Permanent work is broken down into five categories: Roads and Bridges (Category C);
Water Control Facilities (Category D); Buildings and Equipment (Category E); Utilities
(Category F); and Park, Recreational, Railway, Beaches, Piers, Ports, and Harbors
(Category G). Permanent work may only be authorized under a major disaster
declaration.50 Table 41 outlines which counties qualified for which FEMA PA categories
under DR-4562. For the purposes of the needs assessment, HUD only considers needs
associated with categories C through G (Permanent Work).

On March 18, 2022, FEMA announced that additional disaster funding is available to all
states, tribal nations, and territories with Presidential major disaster and emergency
declarations occurring in 2020. Through the March 15, 2022 H.R. 2471, Consolidated
Appropriations Act, 2022, Congress granted a minimum 90% federal cost share for
disasters that include DR-4562. This applies to Public Assistance and Hazard Mitigation
Grant Program.

The figures below reflect a non-federal cost share of 25%. The State will update the
Unmet Needs assessment in the next Action Plan amendment, after OEM receives
additional guidance from FEMA on how to apply the revised cost share down to 10%.

50 Congressional Research Report, pp. 1–2.

65
At present, it is anticipated the non-federal cost share need will be reduced by $115
million.

Table 41: DR-4562: FEMA PA-Eligible Counties

County Cat A Cat B Cat C Cat D Cat E Cat F Cat G

Benton X
Clackamas X X X X X X X
Columbia X
Coos X
Deschutes X
Douglas X X X X X X X
Jackson X X X X X X X
Jefferson X
Josephine X X X X X X
Klamath X X X X X X X
Lake X
Lane X X X X X X X
Lincoln X X X X X X X
Linn X X X X X X X
Marion X X X X X X X
Multnomah X
Tillamook X X X X X X X
Wasco X
Washington X
Yamhill X

At the time of publication of this Action Plan, OEM has assessed eligible projects in the
FEMA PA categories listed below across the impacted areas, as summarized in the
tables below. Initially, PA focused on emergency work and debris removal; however,
multiple amendments to the federal declaration authorized permanent repair and
replacement work. The expenditure of permanent work funding is subject to the State
and local governments providing the non-federal cost share; this State and local share
is an eligible use of CDBG-DR funding. This PA-funded permanent work often takes years
after a disaster event to be fully assessed and completed.

66
2.3.3 Hazard Mitigation Grant Program
FEMA’s Hazard Mitigation Grant Program (HMGP) provides funding to State, local, tribal,
and territorial governments so that they can rebuild in a way that reduces, or mitigates,
future disaster losses in their communities. HMGP assists communities in rebuilding in a
better, stronger, and safer manner to become more resilient to future natural disaster
events. This grant funding is available after a presidentially declared disaster and can
fund a wide variety of mitigation projects.

HMGP can be used to fund projects to protect either public or private property, as long
as the project fits within State and local government mitigation strategies to address
areas of risk and complies with HMGP guidelines. 51

FEMA conducts a final eligibility review to ensure compliance with federal regulations.
HMGP projects must comply with federal environmental laws and regulations, be
cost-effective, and be technically feasible. Federal law requires that States and local
jurisdictions have a mitigation plan prior to receipt of HMGP funds. The plan identifies
hazards, assesses community needs, and describes a communitywide strategy for
reducing the risks associated with natural disasters

OEM conducted a call for projects and the submission of grant applications to the
State from eligible entities for projects that could reduce property damage from future
disasters. American Indian tribes and certain nonprofit organizations also may apply,
and local governments may apply for assistance to benefit individual property owners
and businesses. For DR-4562, OEM received more than $237 million in potentially eligible
applications, over $100 million more than what was available through HMGP
($129.2 million), and therefore they have activated the Interagency Hazard Mitigation
Team 52 to review eligible projects for approval by FEMA. It is anticipated that it will take
an additional 6–8 months to complete the review process and determine final projects
for HMGP.

The table below indicates the amount of FEMA HMGP funding and need based on the
eligible applications received to date, as described above. It includes all projects that
are still under review but reflects more funding than what is available through the FEMA
HMGP for DR-4562. It is anticipated this number may change once the State and FEMA
recalculate the cost share following the changes from H.R. 2471, Consolidated
Appropriations Act, 2022, which granted a minimum 90% federal cost share for DR-4562,
including for HMGP. The table below reflects a projected 90% federal cost share and
10% non-federal cost share.

51 https://www.oregon.gov/oem/Documents/DR4258_Brochure.pdf
52 https://www.oregon.gov/oem/Councils-and-Committees/Pages/IHMT.aspx

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2.3.4 FEMA Public Assistance Program
Table 42: FEMA PA Award Amounts by Category

No. of Sum of Sum of Non-

Damaged Sum of Federal Share Federal Share
PA Category Sites Approx. Cost Cost Cost
A – Debris Removal 58 $304,173,430 $273,756,087 $30,417,343
B – Emergency Protective $164,032,248 $147,629,023 $16,403,225
259
Measures
C – Roads and Bridges 41 $2,692,195 $2,422,976 $269,220
D – Water Control Facilities 7 $294,838 $265,354 $29,484
E – Buildings and Equipment 137 $23,319,260 $20,987,334 $2,331,926
F – Utilities 46 $74,875,694 $67,388,125 $7,487,569
G – Parks, Recreational 57 $12,325,071 $11,092,564 $1,232,507
Facilities, and Other Items
Z – Management Costs 99 $28,049,254 $25,244,329 $2,804,925
TOTAL 704 $609,761,990 $548,785,791 $60,976,199
Data from OEM FEMA PA Report, February 16, 2022, updated with 10% non-federal cost share
calculation.

2.3.5 Total Cost and Need by PA Category

Table 43: FEMA PA Unmet Need by Category
Total Need
Estimated 15% (Match +
PA Category PA Cost Match Cost Resiliency Resiliency)
C – Roads and Bridges $2,692,195 $269,220 $403,829 $673,049
D – Water Control Facilities $294,838 $29,484 $44,226 $73,710
E – Buildings and Equipment $23,319,260 $2,331,926 $3,497,889 $5,829,815
F – Utilities $74,875,694 $7,487,569 $11,231,354 $18,718,923
G – Parks, Recreational $12,325,071 $1,232,507 $1,848,761 $3,081,268
Facilities, and Other Items
TOTAL $609,761,990 $11,350,706 $17,026,059 $28,376,765
Data from OEM FEMA PA Report, February 16, 2022, updated with 10% non-federal cost share
calculation.

68
2.3.6 Approximate Recovery Cost per Agency
Table 44: Unmet Needs by Organization Type

Agency Approximate Cost

City or Township Government $13,533,937.58
County Government $32,122,433.06
Independent School District $2,581,024.05
Nonprofit with 501(c)(3) IRS Status $68,917,083.33
Nonprofit without 501(c)(3) IRS Status $249,530.42
Public/State-Controlled Institution of Higher Education $571,137.07
Regional Government Organization $313,832.87
Special District Government $11,552,201.68
State Government $666,888,055.82
TOTAL $796,729,235.88
Data from OEM FEMA PA Report, February 16, 2022.

2.3.7 Hazard Mitigation Needs per County or Known Project

Table 45: Hazard Mitigation Needs by County
Unmet Need
Project Cost Funding Source (10% local match)
Benton County $520,400 FEMA $52,040
Clackamas County $2,485,670 FEMA $248,567
Douglas County $17,862,938 FEMA $1,786,294
Jackson County $4,535,838 FEMA $453,584
Josephine County $1,085,000 FEMA $108,500
Lane County $37,879,286 FEMA $3,787,929
Lincoln County $31,143,877 FEMA $3,114,388
Marion County $200,000 FEMA $20,000
Multnomah $2,879,355 FEMA $287,936
Regional $13,575,819 FEMA $1,357,582
Umatilla County $2,500,000 FEMA $250,000
Wasco County $331,443 FEMA $33,144
Washington County $15,854,835 FEMA $1,585,484
Clatsop County $665,613 FEMA $66,561
Coos/Curry County $986,357 FEMA $98,636
Klamath County $217,576 FEMA $21,758
TOTAL $132,724,006 FEMA $13,272,401
Data from OEM HMGP Report, February 15, 2022, updated with 10% non-federal cost share
calculation.

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2.4 Economic Revitalization Unmet Needs
2.4.1 Disaster Damage and Impacts
The economic destruction from the 2020 Wildfires also was significant. Many people
were displaced, including a large population of undocumented workers with limited
English proficiency. Businesses that employed thousands of Oregonians were wiped out,
leaving some Oregonians unemployed. Private industry structures, including restaurants,
shops, grocery stores, and other businesses, were destroyed. The impact varied from
community to community, and community-based organizations quickly became
overwhelmed.53 There also were significant wildfire flame and smoke damage to
agricultural crops and livestock operations.

2.4.1.1 Unemployment
2.4.1.1.1 Unemployment Claims
Prior to onset of Oregon’s 2020 Wildfires, the State was already experiencing a
significant economic downturn due to the COVID-19 pandemic. In September 2020,
the Oregon Office of Economic Analysis found that the State had already lost 14% of
existing jobs as a result of the pandemic. While all classes of workers suffered large
losses, low-wage workers bore the brunt of the economic impacts from COVID-19. 54

A more accurate indicator of impacts on jobs due to the 2020 Wildfires is the number of
new unemployment insurance and Disaster Unemployment Assistance (DUA) claims.
The DUA is funded by FEMA and is administered by the Oregon Employment
Department. This program aims to provide temporary unemployment benefits to jobless
workers or self-employed individuals who have lost their job or access to work as a
direct result of the 2020 Wildfires.

As noted in FEMA’s IA Program, there are many reasons why individuals may not apply
for this voluntary assistance; however, the DUA program was authorized for this disaster
event and the following table outlines the claims that occurred as a result of the
ongoing event at that time.

53 Wildfire Economic Recovery Council Report, p. 10.

54 Oregon Employment, September 2020, Oregon Office of Economic Analysis.

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Table 46: Disaster Unemployment Assistance Claims
Disaster Unemployment Assistance Claims
Start of Week No. of Claimants Claiming a Week of Benefits
August 30, 2020 0
September 6, 2020 19
September 13, 2020 133
September 20, 2020 120
September 27, 2020 102

Table 47: Unemployment Insurance Increase Estimates

Unemployment Insurance Increase Estimates

Non-Fire-Impacted
Counties Fire-Impacted Counties
Increase in the
Expected Number of Number of Claimants
Number Claimants to Claim Who Claimed a
of Number of the Week (assuming Week, Possibly Due
Claimants Claimants no fire) to the Fire
August 30, 2020 174,097 95,052
September 6, 2020 175,580 100,883 95,862 5,021
September 13, 2020 173,718 98,056 94,845 3,211
September 20, 2020 166,383 92,168 90,840 1,328
September 27, 2020 162,602 89,937 88,776 1,161
Source: Oregon Employment Department.

Per the Oregon Employment Department, an increase in expected claims can be

correlated to an event that causes unemployment with a moderate to high level of
confidence, in this case, the 2020 Wildfires. Workers are displaced and businesses must
close so an increase in unemployment claims is an expected outcome. However, the
further the data is from an event that is likely to cause unemployment, the weaker the
correlation to the event becomes.

2.4.1.1.2 Impacts on Seasonal and Agricultural Workers

CASA of Oregon and the NOWIA Unete Center for Farm Worker Advocacy conducted
a stakeholder outreach survey of Latino/Latina/Latinx community members impacted
by the Almeda Fire. In 2021, they published a study showing the disproportionate
impact on minority community members, finding that 44% of families relied on seasonal
work as their primary source of income. The survey also indicated that 88% of families
impacted were, in some way, connected to agriculture within the past 7 years, with

71
42% working in orchards, 36% in vineyards, 31% in hemp, 13% in forestry, 15% in
dairy/livestock, and 34% in food processing. The survey also found that the median
income of survey participants was $30,000, which is just over half of Jackson County’s
median household income of $53,412. 55, 56 The results from this survey indicate that there
was a disproportionate impact on agricultural workers during and after the fires.

2.4.1.2 Agricultural Impacts

At the time of publication, there was no comprehensive assessment of the value of the
loss to the agricultural industry by the Oregon Department of Agriculture from the
2020 Wildfires. However, the 2020 Wildfires did have significant impacts on the
agricultural, food, and fiber sectors in Oregon. The crops and livestock most affected
included wine vineyards, hemp, hops, recreational marijuana, tree fruit, and cattle.

2.4.1.2.1 Crop Loss

The U.S. Department of Agriculture (USDA) identified 3,975 acres of pasture/hay,
773 acres of tree crops, 1,604 acres of grapes, 75 acres of onions, and 180 acres of
sweet corn within the 2020 Wildfire perimeters. Most of the tree crops were contained
within the perimeters in Jackson County. The crop insurance payouts that USDA made
related to the 2020 Wildfires were $5,844,055.

A map of the impacts based on USDA crop loss data is included in Figure 9.

Figure 9: Map of Damaged Crops and Burn Scar Areas

55 U.S. Census Bureau.

56 Almeda Housing Survey, 2021.

72
Aside from direct crop loss due to burned farmland, farmers also experienced losses
due to wildfire-related byproducts, such as smoke damage and contamination by ash.
The Oregon State University Global Hemp Innovation Center investigated how wildfires
impacted the 2020 hemp crop. In Jackson County, for example, there are 6,300
registered hemp acres that the Oregon Department of Agriculture estimates might
have been affected by smoke tainted with heavy metals from burning houses, such as
chromium and arsenic. 57

Based on interviews with the Oregon Department of Agriculture, wine vineyards in

Oregon have a long history of sharing knowledge, which was especially helpful in
addressing the effects of the wildfires. Some of the crop was discarded and some
required additional funds in order to produce the wine (e.g., the additional cost of
carefully extracting the juice without the skins). New filtering techniques were
developed and some wineries purchased grapes grown away from smoke-affected
regions in order to supplement their production. Novel ways of marketing that could
meet COVID-19 precautions, such as virtual tastings, helped offset some of the
COVID-19 losses. Still, the Oregon Wine Board estimates an approximately 20% decline
in wine industry revenues due to the pandemic and wildfires.

1.4.1.1.1 Livestock
Wildfires burned both private and public grazing land east of the Cascade Mountains in
2020. These eastern region fires were generally earlier than the devastating Labor Day
fires in western Oregon. Ranchers in central and eastern Oregon have a long history of
managing wildfire threats. While there were very large fires in 2020 (e.g., Lionshead in
Jefferson County burned more than 200,000 acres), for most of the eastern counties,
it was a normal fire year. “Normal” means that every year wildfires burn not only private
range land but also public land. Grazing permits on public land, both open range and
forested areas, are an integral part of many cattle ranch operations.

West of the Cascades, there was an abnormally high number of large fires that
affected not only beef cattle and dairy cattle but also other livestock. Many of the
farmer/ranchers who were impacted had relatively small operations and, in many
cases, they were able to move their livestock out of the path of the fires. At the same
time, they often lost facilities, equipment, and very productive grazing land. Not only
will they need to replace facilities, they will also need to lease land and/or purchase
feed throughout normal grazing times and may be forced to sell their livestock earlier
than planned.

The Oregon Department of Agriculture reports that livestock also were taken in at local
community shelters, along with their farmers/ranchers. This burden was placed on local
governments as FEMA shelters/funding does not cover livestock. Local governments

57 Oregon Agriculture, Food and Fiber: An Economic Analysis, Oregon State University.

73
helped provide farmers/ranchers with temporary shelter, as well as food and care of
livestock during the wildfires.

2.4.1.3 Small Business Administration (SBA) Commercial Losses

The SBA offers Economic Injury Disaster Loans and Business Disaster Loans to businesses
to repair or replace disaster-damaged property owned by the business, including real
estate, inventories, supplies, machinery, equipment, and working capital until normal
operations resume. Businesses of all sizes are eligible. Private, nonprofit organizations,
such as public service, faith-based, and private universities, also are eligible. The law
limits business loans to $2 million and the amount cannot exceed the verified uninsured
disaster loss.

There were 136 SBA business loan applications from impacted counties, totaling an
estimated $32 million in verified losses. Of these applications, only 15 loans were
approved, representing $3.3 million in total verified losses (only 11% of the applications
and 9% of total verified losses). In total, around $2 million were loaned to impacted
businesses.

These data do not reflect the full population of impacted businesses as the State has
assessed damages to at least 900 commercial structures and many business owners
were operating out of their disaster-impacted homes. The State will continue to work
with local governments, chambers of commerce, state agencies, and other groups to
understand the remaining needs of small businesses that were impacted by the
Wildfires.

2.4.2 Total Business Loans Approved by the SBA

Table 48: Total Business Loans Approved by SBA
(a) Total Loans, Including Loans Cancelled by Applicants

County Business Code/Category Business/EIDL* Loans

Clackamas Real Estate and Rental & Leasing 1
Columbia Wholesale Trade 1
Accommodation and Food Services 1
Administrative and Support and Waste Management 1
Construction 2
Health Care and Social Assistance 2
Jackson
Manufacturing 2
Other Services 1
Real Estate and Rental & Leasing 8
Retail Trade 2

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 County Business Code/Category Business/EIDL* Loans
Real Estate and Rental & Leasing 2
Lane
Retail Trade 1
Lincoln Real Estate and Rental & Leasing 1
Linn Construction 1
Professional, Scientific, and Technical Services 1
Marion
Real Estate and Rental & Leasing 2
TOTAL All Categories 29
* EIDL – Economic Injury Disaster Loan

(b) Total Loans, Excluding Loans Cancelled by Applicants

County Business Code/Category Business/EIDL* Loans

Columbia Wholesale Trade 1
Administrative and Support and Waste Management 1
Construction 1
Manufacturing 2
Jackson
Other Services 1
Real Estate and Rental & Leasing 3
Retail Trade 2
Lane Retail Trade 1
Linn Construction 1
Professional, Scientific, and Technical Services 1
Marion
Real Estate and Rental & Leasing 1
TOTAL All Categories 15
* EIDL – Economic Injury Disaster Loan

2.4.3 SBA Applicant Breakdown

Table 49: SBA Loan Breakout by Applicant

Application Type No. of Applications Percentage

Business/EIDL* 136 10.2%
Home 1,186 89.8%
TOTAL 1,322 100.0%
* EIDL – Economic Injury Disaster Loan

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2.4.4 Estimating Business Losses
Table 50: Estimated Business Operations Losses

Operational Loss No. of Businesses Average Estimated Additional

Category with Verified Losses Verified Loss Losses to Businesses
Furniture 76 $20,139 $1,530,551
Machinery 88 $24,319 $2,140,067
Inventory 36 $25,658 $923,686
Leasehold Improvements 10 $14,681 $146,814

2.4.5 Increased Occupation Demands

Data not available based on unemployment claims

2.5 Mitigation Only Activities

2.5.1 Overview
The Mitigation Needs Assessment is a risk-based assessment that summarizes the natural
and human-caused threats and hazards in the eight counties most affected by the
2020 Oregon wildfires (DR-4562). The Mitigation Needs Assessment was undertaken to
inform the use of the State’s 15% CDBG-DR mitigation set-aside and to help build
resilience and mitigation measures into recovery programs and projects.

Importantly, this assessment not only looks at wildfire risk, but also the risk of any natural
hazard likely to threaten the MID areas, including flooding, volcanic, landslide, and
earthquake. These hazards were identified in Oregon’s Office of Emergency
Management FEMA-approved Natural Hazards Mitigation Plan, 2020 (NHMP). Given
that the plan was only recently approved and is not due to be updated for 3 years, it
provides an accurate reflection of the most current hazards posed to the State.

In addition to current hazards, the Mitigation Needs Assessment considers future threats,
particularly as severe weather events become more frequent and severe. In this
manner, the State can ensure that it minimizes the vulnerability to the impacts of future
extreme events through its recovery and mitigation projects and programs.

This assessment not only will help connect mitigation projects to current and future
mitigation needs but will inform all projects undertaken through CDBG-DR such that,
at a minimum, they do not exacerbate natural hazard threats and make use of scarce
resources for recovery and mitigation.

As part of this assessment, the State also sought to identify and address risks to
indispensable services, or those services that enable continuous operation of critical

76
business and government functions and/or are critical to human health and safety
and economic security.

2.5.2 Mitigation Needs Assessment Data and Methodology

The Mitigation Needs Assessment utilizes the findings of the NHMP, regional and local
mitigation plans, and data and research from additional resources, including, but not
limited to, the following:

• American Community Surveys, 2011–2015, 2015–2019, and 2020

• Centers for Disease Control (CDC) Social Vulnerability Index
• Oregon Disaster Housing Recovery Action Plan
• Oregon Department of Geology and Mineral Industries
• Fourth Oregon Climate Assessment Report
• Oregon Multi-Jurisdictional Hazard Mitigation Plans: Clackamas, Douglas, Jackson,
Klamath, Lane, Lincoln, Linn, and Marion Counties
• Oregon Office of Economic Analysis
• U.S. Department of Agriculture, Forest Service
• Initial After-Action Review (AAR) of the June 2021 Excessive Heat Event
• Spatial Hazard Events and Losses Database for the United States
• State Natural Hazards Mitigation Plan (NHMP)

Oregon’s state-level natural hazards mitigation planning efforts are led by the Oregon
DLCD. The mission and vision of Oregon’s planning efforts in this area are to create a
disaster-resilient State of Oregon such that natural hazard events result in no loss of life,
minimal property damage, and limited long-term impacts on the economy.
Oregon’s Natural Hazards Mitigation Plan provides statewide and regional information
on the natural hazards most likely to occur in the State. The NHMP also reports on the
potential impacts of natural hazards on people, property, and the environment, and
establishes a mitigation strategy to reduce those impacts. The first Oregon NHMP was
completed in 1992.

Each 5-year update to Oregon’s NHMP must be approved by FEMA in order for the
State to receive federal funds to carry out mitigation planning and projects.
Oregon’s latest NHMP was approved on September 24, 2020, as a standard plan.
It will be updated and re-approved in 2025. The State intends to take action to regain
enhanced plan status during the effective life of the current NHMP.

77
Although the NHMP is led by DLCD, the planning process is supported by the
State Interagency Hazard Mitigation Team (State IHMT), which includes staff from State
agencies and universities involved in hazard mitigation. It provides broad oversight and
policy direction for hazard mitigation in Oregon, including updating and maintaining
the Oregon NHMP. OEM supports the State IHMT and manages some of the disaster
mitigation funding that the State receives from the federal government.

The purpose of the Oregon NHMP Risk Assessment is to identify and characterize
Oregon’s natural hazards, determine which jurisdictions are most vulnerable to each
hazard, and estimate potential losses to vulnerable structures and infrastructure and to
State facilities from those hazards. Assessing the State’s level of risk involves three
components: characterizing natural hazards, assessing vulnerabilities, and analyzing risk.
Characterization involves determining causes and characteristics, documenting historic
events, and evaluating the future probability of occurrence while accounting for the
potential shifts in probability and presentation that may manifest as Oregon’s climate
changes.

Regional risk assessments begin with a description of the region’s natural environment,
demographics, economy, infrastructure, and built environment, followed by a region-
specific hazard characterization, vulnerability assessment, and risk analysis. 58

Oregon conducts a vulnerability assessment that combines information from the hazard
characterization with an inventory of the existing (or planned) property and population
exposed to a hazard and attempts to predict how different properties and population
groups will be affected by each hazard.

Oregon also conducts a risk analysis that involves estimating the damages, injuries, and
costs likely to be incurred in a geographic area over a given period. Risk analysis has
two measurable components: (1) the magnitude of the harm that may result, defined
through vulnerability assessments, and (2) the likelihood or probability of the harm
occurring. For the 2020 Oregon NHMP update, the State risk assessment has been
reorganized to flow from the discussion of hazards directly into the discussion of
vulnerability, and then, for the first time, for the two to culminate in a brief discussion of
risk.59

The State uses a scoring worksheet during the risk assessment of natural disasters,
referred to as the OEM-FEMA Hazard Analysis Methodology.

58 Oregon OEM, Natural Hazards Mitigation Plan, p. 68.

59 Ibid.

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Based on the above scoring worksheet, natural disaster hazards are ranked based on
probability, impact, and community vulnerability. The following table provides the risk
assessment of disaster types in the 2020 disaster-impacted counties:

Table 52: Local and State Vulnerability Ranking by County

Notes for Table:

Local = Local Hazards Mitigation Plan; H = High vulnerability, M = Moderate vulnerability, and L =
Low vulnerability

State = State Natural Hazards Mitigation Plan; VH = Very high vulnerability, H = High vulnerability,
M = Moderate vulnerability, L = Low vulnerability, and VL = Very low vulnerability

79
 Linn Lincoln Lane – Lane – Klamath Jackson Douglas – Douglas – Clackamas County
Coastal Central Coastal Central

L
L
L
L
L

–
H

M
M
Local Drought

H
H
H
H

M
M
M
VL
State

VH

H
H
H
H
H
H
H

M
Local
Earthquake

L
H
H
VL
State

VH
VH
VH
VH
VH

L
L
L

–
–
–

M
M
M
Local
Volcanic

L
L
L

H
H
H
M
M
M
State

L
L
L
L

H
M
M
Local
Landslide

H
H
H
H
H
H

M
M
State

VH
L
–
H
H

M
M
M
M
M

Local
Wildfire

H
H

State

M
M
M
M
VL

VH

–
H

M
M
M
M
M
M
M

Local
Flood

L
H
H
H

M
M
M
VL

VH State
L

–
–

H
H
H

M
M
M

Local
Windstorm
L

H
H
H

M
M
M
M

State
L

H
H

M
M
M
M
M

Local Winter
Storm

H
H
H

M
M
M

State

Local Extreme
Heat
L

H
H
H
H

M
M

State

80
 Earthquake

Windstorm
Landslide
Volcanic

Extreme
Drought

Wildfire

Winter
Flood

Storm

Heat
County

Local

Local

Local

Local

Local

Local

Local

Local

Local
State

State

State

State

State

State

State

State

State
H VH H VH L VH H H M VH H H L H H H M H
Marion

Sources: Hazard lead agencies, local hazard vulnerability analyses, and state NHMP.

While the NHMP identifies 11 natural hazards threatening the State as a whole, the risk
of many, including tsunami and coastal hazards, vary widely throughout the State.
For this reason, this Action Plan will focus on the top nine hazards in the eight affected
counties. These include wildfire, flooding, earthquake, winter storm, landslide, drought,
volcanic, windstorm, and extreme heat. Because of the location of the burn scar areas
in the MID areas, the State did not include coastal erosion and volcanic hazards in its
Mitigation Needs Assessment.

2.5.2.2 Local Hazards Mitigation Plans

Local hazards mitigation plans identify the most likely and impactful hazards in each
community, as well as appropriate emergency actions in the event of a significant
disaster event and mitigation measures to lessen the impact of future disasters.

In Oregon, most counties are required to update their Natural Hazards Mitigation Plan
every 5 years, whereas multi-jurisdictional natural hazards mitigation plans use a
different methodology, based on the local conditions and needs of their community.
Some plans use a qualitative rating system based on past natural hazard data and
future projections, while other natural hazards mitigation plans rely more heavily on
qualitative data compiled from geological surveys, public engagement sessions, and
on-the-ground observations.

Table 53 provides links to the most recent county hazards mitigation plans for the
eight impacted counties. Each of these local hazards mitigation plans was current at
the time of the 2020 Wildfires.

81
Table 53: Local Hazard Mitigation Plans
Hazard Mitigation Plan (HMP) Link to Local Plan Date
Douglas County Local NHMP, Volume II Douglas 2016
Marion County Multi-Jurisdictional HMP Marion 2017
Jackson County Multi-Jurisdictional NHMP Jackson 2018
Linn County Multi-Jurisdictional NHMP Linn 2017
Lincoln County Multi-Jurisdictional NHMP Lincoln 2020
Lane County Multi-Jurisdiction HMP Lane 2018
Clackamas County Multi-Jurisdictional HMP Clackamas 2019
Klamath County Multi-Jurisdictional NHMP Klamath 2017

Most counties include a risk assessment in their Natural Hazards Mitigation Plan to
identify disaster types by the level of risk, from high risk to low risk. This assessment is
generally based on the frequency and impact of disaster events. In Table 54, you can
see the most common categorizations of disaster type by risk level in the MID areas.

Table 54: Oregon Hazards Data Table by Threat Tier

High-Risk Threat Medium-Risk Threat Low-Risk Threat

Wildfire Landslide Volcanic
Earthquake Drought Tsunami
Winter Storm Windstorm Coastal Erosion
Flooding

Furthermore, counties prioritize the probability of disaster event occurrence and

vulnerability of the community to that hazard. Table 55 categorizes all disaster types
by their risk rating based on probability and vulnerability by county.

82
Table 55: Hazard Threat Level, by County
Hazard
County Wildfire Earthquake Winterstorm Flood Landslide Drought Windstorm Volcanic
Douglas High High Moderate High Low High Very Low Very
Low
Marion Moderate High Low High Moderate High Low Low
Jackson High High High Moderate Low Moderate Moderate Low
Linn Moderate High High High Moderate Low Moderate Medium
Lincoln Moderate Moderate High Moderate High Low High Low
Lane High Moderate High High Moderate Low High Low
Clackamas High High High Moderate Low Moderate Moderate Medium
Klamath High High Low High Moderate High Very Low 60 Medium

2.5.3 Top Risks Impacting the HUD Most Impacted and Distressed
Areas
Of the 11 hazard types impacting the State according to the NHMP, nine have been
deemed as posing the most significant risk to the MID counties. These include wildfire,
flood, earthquake, winter storm, landslide, drought, volcanic, windstorm, and extreme
heat. Coastal hazards were excluded from this analysis as the burn scar areas and MID
areas have zero or low risk of coastal flooding. Likewise, volcanic hazards were
excluded as only Lane, Lincoln, and Marion counties are among the counties deemed
vulnerable by the Oregon Department of Geology and Mineral Industries (DOGAMI).

The sections below provide an overview of the natural hazards affecting the MID
counties, including information related to previous occurrences and their magnitude
and impacts, as well as the probability of future hazard events, usually expressed in
recurrence intervals.

Wildfires
A wildfire is an uncontrolled burning of grasslands, brush, or woodlands. The potential for
wildfires depends on the surface fuel characteristics, recent climate conditions, current
meteorological conditions, and fire behavior. Hot, dry summers and dry vegetation
increase the susceptibility to fire in the fall, which is a particularly dangerous time of
year for wildfires.

Fire is an essential part of Oregon’s ecosystem but it also can pose a serious threat to
life and property, particularly in the State’s growing rural communities. Wildfires can be
divided into three categories: interface, wildland, and firestorms. Wildland–urban
interface (WUI) communities are areas where structures and other human development

60 Oregon Natural Hazards Mitigation Plan.

83
meet or intermingle with natural vegetative fuels. The increase in residential
development in WUI areas has resulted in greater wildfire risk. Fire has historically been a
natural wildland element and can sweep through vegetation that is adjacent to a
combustible home.

Oregon experienced its most devastating series of wildfires in recorded history in early
fall 2020. On September 15, 2020, a federal disaster declaration was declared for
Clackamas, Douglas, Jackson, Klamath, Lane, Lincoln, Linn, and Marion counties.
Oregon OEM reported that more than 4,200 homes were destroyed, including 1,795
manufactured housing units, based on damage assessments that the agency collected
from each of the eight FEMA IA-declared counties (DR-4562).

The 2020 and 2021 Oregon wildfires across the State may prompt Klamath, Lincoln, Linn,
and Marion counties to elevate wildfires to a high-level threat in their next NHMP
update. In 2020, the Beachie Creek and Lionshead wildfires in Marion County destroyed
633 homes, accounting for nearly 40% of the annual residential building permits from
2019; in Lincoln County, the Echo Mountain Complex Fire destroyed 288 homes or 88%
of the 2019 residential building permits. The extensive wildfire destruction and damage
across all eight counties exacerbated the existing housing shortage in Oregon.

Table 56: Recent History of Wildfires in Oregon

Year County Fire/Disaster Name Damage Summary

2002 Josephine Biscuit Fire Destroyed four homes and
10 additional structures.
2010 Jackson Oak Knoll Fire Destroyed 11 structures.
2014 Wallowa Buzzard Complex Primarily impacted rangeland and
cattle farms.
2014 Grant South Fork Complex Burned 62,476 acres.
2015 Grant Canyon Creek Complex Destroyed 43 homes and almost
100 other structures.
2015 Wallowa Grizzly Bear Complex Destroyed two homes and dozens
of other structures.
2020 Multiple Counties Multiple Names/DR-4562 Destroyed more than 4,300 homes.
2021 Multiple Counties Patton Meadow and Destroyed more than
Bootleg Fires 400 structures.

84
According to the Figure 10: Oregon’s Relative Wildfire Risks to Homes
USDA Forest Service,
populated areas in
Oregon have, on
average, a greater
wildfire risk to homes
than nearly 70% of
other states
(see Figure 10). This
presents multiple
challenges for the
State, including rising
insurance costs,
increasing State
government outlays
for recovery, and
damages to
underlying public
infrastructure.61

The level of fire

activity is strongly
correlated to summer Source: USDA, Forest Service, Wildfire Risk to Communities,
climate as the largest 2021.
fires generally occur
during warm and dry summers. Oregon’s increasing wildfire risk in the face of climate
change has caused an increase in catastrophic fires over the past several years.
According to the Fourth Oregon Climate Assessment Report (2019), in a changing
climate, fire activity in Oregon will continue to be influenced by warming temperatures
and longer fire seasons. More frequent and intense wildfires are likely to damage larger
areas, posing a greater risk to Oregon’s housing stock. Increased extreme heat in urban
areas also poses a risk to human health and safety, especially for those living and
working in urban heat islands. People living outdoors, in energy-inefficient
manufactured homes, or on the upper floors of multifamily housing units may be
particularly vulnerable. 62

Immediately following the fires, Oregon State agencies and federal partners created
erosion threat reports related to the 2020 Wildfires. The Erosion Threat Assessment and
Reduction Team (ETART) is a multi-jurisdictional and multi-agency team, led by FEMA
and the State of Oregon, charged with the assessment of potential erosion risks and

61 USDA Forest Service, Wildfire Risk to Communities, 2021.

62 Fourth Oregon Climate Assessment Report: State of Climate Science, 2019.

85
providing control treatment recommendations. This group of subject matter experts
coordinated with federal, State, and local fire response teams as an early statewide
recovery action.

This ETART team identifies risks and threats such as soil erosion, flooding potential, hazard
trees, and ecological impacts associated with each fire. Local and State jurisdictions
will evaluate the findings through the filters of need, feasibility, and cost to prioritize
recovery projects and inform funding decisions.

ETART summaries and full reports for the Beachie Creek, Archie, Holiday Farm,
and Riverside fires are available at https://wildfire.oregon.gov/NCrecovery.

2.5.3.1 Flooding
Flooding is the most common environmental hazard affecting the United States, likely
due to the widespread geographical distribution of river valleys and coastal areas and
the attraction of human settlements to these areas. The most recent presidentially
declared disasters have been associated with flash floods and general flooding.

Flooding is a localized hazard that generally results from excessive precipitation. Floods
are generally considered to fall into one of two categories: flash floods that are the
product of heavy localized precipitation occurring within a short period of time at a
given location and general floods caused by large-scale weather systems that
generate prolonged rainfall or rain-on-snow events that result in large amounts of runoff
over a longer period across one or more river basins.63 Other sources of flooding include
flash floods associated with locally intense thunderstorms, channel migration, ice, or
debris jams, and, much less frequently, dam failures.

Floods are a common and widespread natural hazard in Oregon as evidenced by the
State’s extensive history of flooding. Oregon’s deadliest recorded flood occurred in
Heppner in 1903 when a June 14 storm dropped 1.5 inches of rain within a 20-minute
period. The storm was centered in the headwaters area of Willow Creek above
Heppner in northeastern Oregon. Within minutes, a 5-foot wall of water and debris
poured through Heppner, ripping homes from their foundations and resulting in 247
deaths.

Another late spring flood in 1948 is best remembered for destroying the entire city of
Vanport (now Delta Park). Record flow levels on the Columbia River caused the
structural failure of a dike, leaving the entire town of almost 19,000 homeless.

63 Oregon OEM, Natural Hazards Mitigation Plan, p. 173.

86
Additional floods of record in Oregon occurred in December 1964 and January 1965
during the “Christmas Flood.” Damage from these floods totaled more than $157 million
and resulted in 20 deaths. From December 20 through 24, 1964, the most severe
rainstorm to occur in central Oregon and one of the most severe west of the Cascades
left many areas with two-thirds of their normal annual rainfall in just 5 days. The ensuing
floods destroyed hundreds of homes and businesses, forced the evacuation of
thousands of people, destroyed at least 30 bridges, and washed away hundreds of
miles of roads and highways.

A similar flood event occurred in February 1996. Following an extended period of

unseasonably cold weather and heavy snowfall in the Pacific Northwest, warming
temperatures and rain began thawing the snowpack and frozen rivers throughout
Oregon. On February 6, a strong subtropical jet stream or “Pineapple Express” reached
Oregon. This warm, humid air mass brought record rainfall amounts, quickly melting the
snowpack and swelling at least 25 rivers to flood stage. Many channels reached flood
levels comparable to those reached during the 1964 flood. Of Oregon’s 36 counties,
27 were eventually covered by a presidentially declared disaster due to this event, with
statewide damages totaling more than $280 million.64

Table 57 provides information on recent flooding events in the MID counties.

Table 57: Recent Flooding Events in the Most Impacted and Distressed Counties
Date Location Event
October 2017 Clackamas A potent atmospheric river brought strong winds to the
County north Oregon coast and coast range on October 21,
causing heavy rain for some locations along the north
Oregon coast and coast range, with Lees Camp receiving
upwards of 9 inches. Runoff prompted the earliest
significant Wilson River flood on record, as well as flooding
on several other rivers in the area.
June 2018 Lane County In Lane County, an upper-level trough moved across the
area from the southwest, generating strong thunderstorms
that produced locally heavy rainfall, lightning, hail, and
gusty winds. Thunderstorms with heavy rainfall developed
over southwest Baker County on June 20, leading to flash
flooding and debris flow on the areas left burn scarred by
the Rail and Cornet-Windy Ridge fires.
February 2019 Douglas and DR-4432: Very heavy rain, along with the melting of recent
Lane Counties snowfall, caused flooding at several locations in southern
Oregon in late February. Deer Creek at Roseburg, the South
Fork of the Coquille at Myrtle Point, the North Fork of the

64 Oregon OEM, Natural Hazards Mitigation Plan, p. 255.

87
 Date Location Event
Coquille at Myrtle Point, the Coquille River at Coquille, and
the Rogue River at Agness all exceeded flood stage. 65

As severe weather events become more frequent and severe, western Oregon basins,
in particular, are projected to experience increased precipitation, including extreme
precipitation, which is likely to result in increased extreme river flows in future decades.
It is very likely (> 90%) that Oregon will experience an increase in the frequency of
extreme precipitation events (high confidence). It also is very likely that Oregon will
experience an increase in the frequency of extreme river flows (high confidence).

2.5.3.2 Earthquakes
An earthquake is a vibration or shaking of Earth’s surface due to an underground
release of energy. They can be caused by various conditions, such as sudden
movements along geological faults or volcanic activity. Earthquake magnitudes,
or severity, are recorded on the Richter scale with seismographs. Some may be so minor
that they are virtually unnoticed, while others can destroy entire cities. Seismology, the
study of earthquakes, helps scientists understand what areas are more prone to
experiencing earthquakes, such as along active fault lines and along the Pacific coast;
however, earthquakes are generally unpredictable. 66

Earthquakes are infrequent and unpredictable. In Oregon, the Cascadia Subduction

Zone may produce an earthquake of 8.0 magnitude or higher. And while there has not
been a major Cascadia Subduction Zone earthquake in Oregon in more than four
centuries, an earthquake’s size, force, suddenness, and potential to cause catastrophic
damage and disruption make for a potent natural hazard.

The table below, based on data gathered in the State’s Natural Hazards Mitigation
Plan, presents the frequency, location, and magnitude of seismic events in Oregon.
The most recent such event occurred in 2001 in Nisqually, Washington.

Table 58: Frequency, Location, and Magnitude of Seismic Events in Oregon

Date Location Magnitude (M)
Approximate Years: Offshore, Cascadia Probably
1400 BCE, 1050 BCE, 600 BCE, 400, 750, 900 Subduction Zone 8.0–9.0
January 1700 Cascadia Subduction Zone About 9.0
October 1877 Portland Area, Oregon 5.2

65 Oregon OEM, Natural Hazards Mitigation Plan, p. 262.

66 Oregon OEM, Natural Hazards Mitigation Plan, p. 487.

88
 Date Location Magnitude (M)
February 1892 Portland Area, Oregon 5.0
December 1941 Portland Area, Oregon 4.5
April 1949 Olympia, Washington 7.1
December 1953 Portland Area, Oregon 4.5
November 1961 Portland Area, Oregon 5.0
November 1962 Portland Area, Oregon 5.5
December 1963 Portland Area, Oregon 4.5
March 25, 1993 Scotts Mills, Oregon 5.6
February 2001 Nisqually, Washington 6.8 67

The Oregon Department of Geology and Mineral Industries (DOGAMI) developed two
earthquake loss models for Oregon based on the two most likely sources of seismic
events: (1) an M6.5 arbitrary crustal event, and (2) a 2,500- year mean return period
probabilistic earthquake scenario (2,500-year Model). Both models are based on
Hazus-MH, software currently used by the Federal Emergency Management Agency
(FEMA) as a means of determining potential losses from earthquakes and other hazards.

The arbitrary crustal event is based on a potential M6.5 earthquake generated from an
arbitrarily chosen fault using the Hazus software, and assuming a worst-case scenario.
The 2,500-year crustal model does not look at a single earthquake (as in the CSZ
model); it encompasses many faults, each with a 2% chance of producing an
earthquake in the next 50 years. The model assumes that each fault will produce a
single “average” earthquake during this time.

DOGAMI investigators caution that the models contain a high degree of uncertainty
and should be used only for general planning purposes. Despite their limitations, the
models do provide some approximate estimates of damage 68.

The following image depicts the 2020 Oregon Earthquake Probability Ranking Based on
Mean County Value of the Probability of Damaging Shaking and Presence of Newly
discovered faults:

67 Oregon OEM, Natural Hazards Mitigation Plan, p. 220.

68 Oregon OEM, Natural Hazards Mitigation Plan, p. 223.

89
Figure 11: 2020 Oregon Earthquake Probability Ranking 69

As the graphic indicates, each of the seven MID counties have at least a 32% chance
of damaging shaking during the next 100 years. Note that counties with hatching had
their probability category increased one step due to newly discovered faults.

2.5.3.3 Winter Storms

Winter storms are characterized by ice accumulation and freezing rain, heavy snowfall,
and/or extreme cold and wind chill conditions. Impacts are determined by factors such
as the amount and extent of snow or ice, air temperature, wind speed, event duration,
and day and time. These hazard events typically create a disruption of regional
systems, such as public utilities, telecommunications, and transportation routes.

An ice storm is used to describe occasions when ice accumulations damage trees and
aboveground utility lines and affect travel surfaces. Heavy snowfall can cause
extended periods of travel disruption and damage to structures. Exposure to the
extreme cold and wind chill associated with winter storms can be life threatening and
plumbing pipes can freeze or burst.

69 DOGAMI, 2020.

90
Winter storms, while more frequent than other hazards, also are more concentrated,
with fewer statewide or regional events. The following table describes recent winter
storm events from 2010 to the present.

Table 59: Winter Storm Events: 2010 to Present

Date Location Description
Nov. 29–30, 2010 Hood River and 4–5 inches of snow reported in Cascade Locks
Wasco Counties and Hood River; 0.5 inch of ice in Corbett.
Jan. 12–18, 2012 Hood River and 4.5 inches of new snow reported in Hood River; I–84
Wasco Counties closed due to ice and snow east of Troutdale.
Feb. 6–10, 2014 Hood River A strong winter storm system affected the Pacific
County Northwest, bringing a mixture of arctic air, strong
easterly winds, significant snowfall, and freezing rain to
several counties in northwestern Oregon.
Feb. 11–14, 2014 Hood River 2–7 inches of heavy rain fell across many counties in
County western Oregon, which, combined with warm
temperatures, led to snowmelt and rainfall runoff that
produced rapid rises on several rivers, including
flooding on three rivers in northwestern Oregon.
Mar. 2, 2014 Hood River Easterly winds brought cold air from east of the
County, Upper Cascades through the Columbia River Gorge as a
Hood River moist front pushed in from the Pacific. The
Valley, and combination of a cold air mass and frontal
Central precipitation resulted in approximately 6–8 inches of
Columbia River snow, as well as a quarter of an inch of ice on top of
Gorge the snow in Hood River and White Salmo, and as
much as 0.4–0.5 inch of ice in Parkdale.
Nov. 13, 2014 Hood River Sleet and freezing rain created hazardous commutes
County (Western for tens of thousands of persons in the western and
Columbia River eastern suburbs of Portland. Snow accumulations were
Gorge) primarily restricted to the Cascade valleys and the
central Columbia River Gorge. Spotters reported
around 6–8 inches of snow in the Cascade Foothills,
followed by 0.25 inch of ice. A combination of heavy
snow and ice resulted in slick driving conditions for the
western Columbia River Gorge. Areas in the gorge
measured a quarter of an inch of ice, whereas other
areas had 5–8 inches of snow.
Dec. 6–23, 2015 Statewide Storm DR-4258: Clatsop, Columbia, Multnomah, Clackamas,
Events Washington, Tillamook, Yamhill, Polk, Lincoln, Linn,
Lane, Douglas, Coos, and Curry counties were
presidentially declared disasters. Several Pacific storm
systems moved across the region over the December
12–13 weekend. Each storm system brought several
inches of snow to the mountain areas.

91
 Date Location Description
Dec. 8, 2016 Hood River A strong frontal system brought strong easterly winds
County (Western to the North Willamette Valley and a mix of snow,
Columbia River sleet, and freezing rain down to the valley floor. Ice
Gorge) accumulations were higher in the West Hills and near
the Columbia River Gorge. 70
February 2021 Statewide Storm Significant ice/snow event caused the largest power
Events outage in Oregon history. Over 300,000 were without
power, some were without power for up to a week.
There was significant property and power line
damage from downed trees.

There is no current research available regarding changes in the incidence of winter

storms in Oregon due to changing climate conditions. However, the warming climate is
likely to result in less frequent extreme cold events and high-snowfall years.

Within the Oregon, northeast communities are known for cold winter conditions.
This region is the commodity flow route to eastern Oregon. With long road closures,
these communities suffer from loss of traffic and revenue. Drifting, blowing snow and
windy and icy conditions have forced highway closures along Oregon’s principal
east-west transportation route, I–84, for hours. In such situations, travelers must seek
accommodations, sometimes in communities where lodging is very limited. Access to
farms and ranches can be extremely difficult and present a serious challenge for local
emergency managers.

Winter storms, particularly east of the Cascades where snowstorms are typically more
intense, bring larger amounts of snow and last longer. They can strand livestock in
pastures, leaving them without food and water and exposed to extreme cold for long
periods of time. Consequently, substantial losses of livestock from starvation,
dehydration, and freezing significantly impact producers and State and local
economies. In addition, water quality and health hazards develop when dead livestock
are not retrieved until roads are cleared and vehicles can be used to remove the
carcasses. Livestock buried under snow may not be found until the snow melts, carrying
the carcasses to streams and floodways. 71

2.5.3.4 Landslides
A landslide is one of the most common and devastating geologic hazards in Oregon.
A landslide is a downward movement of earth or rock driven by gravity. Landslides can
be triggered by natural or human-caused circumstances, such as heavy rains,
earthquakes, volcanoes, rapid snow melt, erosion, construction, and other human

70 Oregon OEM, Natural Hazards Mitigation Plan, p. 564.

71 Oregon OEM, Natural Hazards Mitigation Plan, p. 693.

92
activity. Average annual repair costs for landslides in Oregon exceed $10 million, with
individual severe winter storm losses often exceeding $100 million. As population growth
continues to push new development into landslide-susceptible terrain, greater losses
are likely to occur.

Three main factors influence an area’s susceptibility to landslides—the geometry of the

slope, geologic material, and water—and some geologic formations are more
susceptible to landslides than others. In general, locations with steep slopes are most
susceptible to landslides, and landslides occurring there tend to move more rapidly and
pose greater life safety risks. 72

The following table describes major landslides in Oregon since 1964.

Table 60: Major Landslides in Oregon Since 1964

Date Location Description

December 1964 Crook, Deschutes, Jefferson, DR-184
Klamath, Lake, and Wheeler
Counties
September 1993 Klamath County Rockslide resulting from
earthquake; one death
December 1996 – Lake and Wheeler Counties DR-1160
January 1997
May – June 1998 Crook County DR-1221
December 2003 – Crook, Deschutes, Jefferson, DR-1510
January 2004 Lake, and Wheeler Counties

December 2005 Jefferson County Damages: $11,666.67 (includes

Sherman and Wasco Counties)
December 2005 – Crook, Jefferson, and Wheeler DR-1632
January 2006 Counties

December 2006 Wheeler County DR-1683

January 2011 Crook County DR-1956

January 2017 Deschutes County DR-4328

February 2019 Jefferson County DR-4432 73

72 Oregon OEM, Natural Hazards Mitigation Plan, p. 747.

73 Hazards and Vulnerability Research Institute. The Spatial Hazard Events and Losses Database for the
United States, Version 5.1 [Online Database]. Columbia, SC: University of South Carolina, 2007. Available
from http://www.sheldus.org; FEMA, https://www.fema.gov/disasters.

93
Although it is difficult to predict exactly where and when a landslide will occur, these
events are triggered by heavy rainfall events when the soil becomes saturated or
following a seismic event. Given that they occur in every county in Oregon, there is a
100% probability of landslides occurring in the impacted region in the future.

It is very likely (> 90%) that Oregon will experience an increase in the frequency of
extreme precipitation events (high confidence). Because landslide risk depends on a
variety of site-specific factors, it is more likely than not (> 50%) that climate change,
through the increasing frequency of extreme precipitation events, will result in an
increased frequency of landslides.74

2.5.3.5 Drought
A drought is a prolonged period of less-than-normal precipitation such that the lack of
water causes a serious hydrologic imbalance. Common effects of drought include crop
failure, water supply shortages, and fish and wildlife mortality. High temperatures, high
winds, and low humidity can worsen drought conditions and make areas more
susceptible to wildfires. Human demands and actions can hasten or mitigate the
drought-related impacts on local communities. 75

The following table provides an historical view of drought events in Oregon, beginning
with Oregon’s impacts from the infamous Dust Bowl through more frequent and
recurring drought events.

Table 61: Drought Events in Oregon

Date Location Description
1929–1931 Regions 1–3 and 5–7 (1929–1930); In the 1920s and 1930s, these regions were
Regions 6 and 7 (1930–1931) more commonly known as the “Dust Bowl”
(Extreme Drought) as they were experiencing a period of
1939 Statewide prolonged, mostly drier than normal
conditions across much of the State and
country. Moderate to severe drought
affected much of the State.
1977 Northern & Southern Central and Significantly drier than normal year with
Eastern Oregon temperatures near normal.
1994 Regions 4–8 The Governor’s drought declaration
covered 11 counties.
2001 Southern and Eastern Oregon 18 counties, including Jefferson, Wheeler,
Crook, Deschutes, Klamath, and Lake,

74 Oregon OEM, Natural Hazards Mitigation Plan, p. 754.

75 Oregon OEM, Natural Hazards Mitigation Plan, p. 755.

94
Date Location Description
were placed under a Governor-declared
drought.
2002 Southern and Eastern Oregon The 18-county declaration remained in
effect with the Governor adding five
counties, bringing the total to 23 counties.
2003 Southern and Eastern Oregon Jefferson, Deschutes, and Lake counties’
drought declarations expired on June 23,
2003. The Governor issued new drought
declarations for Wheeler and Crook
counties and extended the Klamath
County drought order through December
2003.
2004 Eastern Oregon Klamath County was placed under a
Governor-declared drought; three other
counties were declared in neighboring
regions.
2005 Regions 5–7 The Governor declared a drought in
Wheeler, Crook, Deschutes, Klamath, and
Lake counties. All Region 5 counties were
declared, as well as two counties in
Region 7.
2007 Regions 6–8 The Governor declared a drought in Lake
County, along with five other counties in
Regions 6 and 7.
2010 Region 6 The Governor declared a drought in
Klamath and “contiguous counties.”
2012 Region 6 The Governor declared a drought in Lost
River Basin only, located within Klamath
and Lake counties.
2013 Regions 5–8 The Governor declared a drought in
Klamath County, along with four other
counties.
2014 Regions 4 and 6–8 The Governor declared a drought in
10 counties, including Crook, Wheeler,
Klamath, and Lake counties.
2015 Statewide All 36 Oregon counties received federal
drought declarations, including 25
counties under the Governor’s drought
declarations.
2018 Regions 1 and 4–8 Klamath, Lake, and Wheeler counties
received the Governor’s drought

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 Date Location Description
declarations, including eight other
counties in five other regions. 76

Climate change has brought longer and more severe droughts to the Pacific
Northwest. Prior to the 2020 Wildfires, all MID counties experienced moderate to
extreme drought. The buildup of dry brush over the previous several years contributed
to the extreme intensity of wildfires throughout all eight disaster-declared counties.
Continued drought in residential communities across Oregon threatens to exacerbate
the housing vulnerability throughout Oregon, particularly in the disaster-declared
counties

2.5.3.6 Volcanoes
Volcanoes are a potentially destructive natural hazard resulting from magma
ascending to and then erupting from the earth’s surface. Volcanic eruptions are usually
isolated around a single vent area; however, their explosivity and effects can vary
widely. While volcanic risk varies across the State, largely based on the proximity to
Cascade Range volcanoes, all MID area counties, except for Lincoln County, were
deemed by DOGAMI to have at least a moderate risk.

Potentially hazardous volcanoes in Oregon are present along the crest of the Cascade
Range and to a lesser extent in the High Lava Plains, presenting significant hazards to
communities within the region. The Cascade Range extends southward from British
Columbia into northern California and its volcanoes are a result of the interaction of
tectonic plates along the Cascadia Subduction Zone. The eruption of Washington
State’s Mount St. Helens in 1980 and subsequent activity demonstrate both the power
and catastrophic consequences that Cascade-type volcanoes can have on the
region.

76 Oregon OEM, Natural Hazards Mitigation Plan, p. 1141.

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Figure 12: Eruptions in the Cascade Range During the Past 4,000 Years

Source: Eruptions in the Cascade Range During the Past 4,000 years 77

In Oregon, volcanic hazards can have far-reaching consequences, which are

categorized as “proximal” or “distal,” based on the range of their impact relative to the
eruptive center or active vent. Proximal hazards are those occurring within 30 miles of
the active vent and include lava flow; pyroclastic flows, which include very hot ash,
lava, and gases; lahars, or volcanic mud and debris flows; debris avalanches and
landslides; release of volcanic gases; and showers of ejected rock fragments called
“tephra.”

While slow-moving and generally not life-threatening, lava flows can burn, crush, or bury
objects in their path and disrupt local streams. Conversely, pyroclastic flows and tephra
can move at speeds up to 150 mph, burning or crushing wood and other combustible
materials and crushing structures such as homes and indispensable services in their
path. In addition to the threat of being burned or crushed, these eruptive hazards can
also result in life-threatening gases and should prompt the evacuation of affected
areas.

Distal hazards include lahars, eruption columns, and clouds that can extend hundreds
of miles, and ashfall that can affect air quality, impede road and air travel, and
accumulate in sufficient quantities to collapse roofs. In addition to proximal and distal

77 Meyers and Driedger, Eruptions in the Cascade Range during the past 4,000 years.

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hazards, other non-eruptive hazards, such as earthquakes, flooding, and landslides, can
result from volcanic activity.

Unlike other geologic hazards, such as earthquakes and tsunamis, certain precursors
often foreshadow volcanic activity, such as heat output, volcanic gases, ground
movements, and earthquakes. Scientists use these clues to recognize a restless volcano
and to prepare for the events that may follow. Lessons learned at Mount St. Helens led
the U.S. Geological Survey (USGS) to establish the Cascades Volcano Observatory
(CVO) in Vancouver, Washington. Scientists at CVO continually monitor volcanic
activity within the Cascade Range and study the geology of volcanic terrains in
Oregon in cooperation with DOGAMI. USGS currently characterizes six Oregon
volcanoes—Mount Hood, Crater Lake, Newberry, South Sister, Middle Sister, and North
Sister—as “high to very high” threats.

While it is difficult for geologists to supply a timeline particular to volcanic activity and
USGS stresses the uncertainty and limitations in forecasting eruptions, DOGAMI made
use of open-file reports to understand the odds of certain events taking place at
particular volcanoes and assigned a volcanic hazard probability score of 3 out of 5 to
all MID areas, except for Lincoln County.

Table 62: Notable Geologic Events Near Mount Hood

Date or Age Event Deposits

1859, 1865, 1907(?) Minor explosive eruptions of Scattered pumice
Mount Hood
Late 19th century Late neoglacial advance Prominent, sharp-crested
moraines
Late 18th century Old Maid eruptive period Lava dome, pyroclastic flow
and lahar deposits, tephra
About 500 years ago Debris flows in Zigzag River Debris flow deposits
1,000 years ago Debris flows in upper Sandy Debris flow deposits
River
1,500 years ago Timberline eruptive period Lava dome, pyroclastic flow
and lahar deposits, tephra
7,700 years ago Eruptions from vent near Basaltic andesite of Parkdale
Parkdale; Mount Mazama lava flow; about 5 cm of
ashfall Mazama ash
11,000 to 20,000 years ago Waning phases of Evans Moraines
Creek glaciation
13,000 to 20,000 years ago Polallie eruptive period Lava domes, pyroclastic
flow and lahar deposits,
tephra
20,000 to 25,000 years ago Maximum of Evans Creek Belts of moraines in most
glaciation valleys

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 Date or Age Event Deposits
20,000 to 30,000 years ago Mount Hood dome eruptions Lava domes, pyroclastic
flow and lahar deposits
30,000(?) to 50,000(?) years ago Mount Hood lava flow Andesite lava flows of
eruptions Cathedral Ridge and
Tamanawas Falls

2.5.3.7 Windstorms
In the northwestern region of the United States, windstorms typically involve sustained
winds of more than 50 mph, with less frequent events exceeding 80 mph. Windstorms
can affect any region of the State but have a higher prevalence along the coastline
and coastal headlands. Windstorms are especially dangerous in areas with tree
coverage, exposed property, major infrastructure, and aboveground utility lines, where
they result in downed trees, power outages, and damage to roofs and outbuildings. 78

Rotational windstorms, commonly referred to as tornados, dust devils, or waterspouts,

occur with lower frequency in Oregon. These are typically short duration, localized
events that can present public safety hazards and damage.

The following table outlines recorded windstorm events with notable impacts.

Table 63: Historical Windstorm Events

Date Location of Impact Summary Damage
March 1971 Most of Oregon Notable damage in Falling trees damaged
Newport power lines, building
damage
January 1986 Northern and central 75-mph winds Damaged trees,
Oregon coast buildings, and power
lines
January 1987 Oregon coast Wind gusts to 96 mph at Significant erosion to
Cape Blanco highways and beaches,
several injuries
December Oregon coast / Winds on the coast, 60 Trees uprooted
1987 northwestern Oregon mph
March 1988 Northern and central Wind gusts, 55–75 mph One death near Ecola
coast State Park, uprooted
trees

78 Oregon OEM, Natural Hazards Mitigation Plan, p. 383.

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Date Location of Impact Summary Damage
January 1990 Statewide 100-mph winds in One death, damaged
Netarts and Oceanside buildings, falling trees
(FEMA DR-853-OR)
February Oregon coast Wind gusts of 53 mph at Damage to docks, piers,
1990 Netarts and boats
January 1991 Most of Oregon Winds of 63 mph at 75-foot trawler sank
Netarts, 57 mph at northwest of Astoria
Seaside
November Oregon coast Slow-moving storm, Buildings and boats
1991 25-foot waves offshore damaged, transmission
lines down
January 1992 Southwestern Oregon Wind gusts of 110 mph Widespread damage
at Brookings
January 1993 Oregon coast / northern Tillamook wind gusts of Widespread damage,
Oregon 98 mph especially Nehalem
Valley
December Statewide Wind gusts of more than Four deaths, many
1995 100 mph; Sea Lion injuries; widespread
Caves, 119 mph damage (FEMA
DR-1107-OR)
November Western Oregon Winds of 89 mph at Severe beach erosion,
1997 Florence, 80 mph at trees toppled
Netarts and Newport
February Southwestern Oregon 75–100 mph on the Widespread loss of
2002 southwestern coast electricity and damage
(Douglas, Coos, and to public utility
Curry counties) infrastructure (FEMA
DR-1405-OR)
January 2006 Clatsop, Tillamook, Two storm events with Property damage
Lincoln, and Lane high winds of 86 mph among all four coastal
counties and 103 mph, counties; also impacted
respectively five other counties
outside of Region 1;
total damages of
$300,000 and $200,000,
respectively
February Clatsop, Tillamook, Windstorm event with Property damage
2006 Lincoln, and Lane winds measured at 77 among all four coastal
counties mph counties; the storm also
impacted nine other
counties outside of
Region 1; total

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 Date Location of Impact Summary Damage
damages of $300,000
and $275,000

Oregon’s history of wind damage underscores the need for a comprehensive wind
hazard mitigation program. The necessity of such an action is supported by the
after-action report that followed western Oregon’s high wind event of February 7, 2002
(Hazard Mitigation Survey Team Report, FEMA DR-1405-OR).

Structures that are most vulnerable to high winds in Oregon include insufficiently
anchored manufactured homes and older buildings in need of roof repair. Section 307
of the Oregon Building Code identifies high-wind areas along the Oregon coast and
sets anchoring standards for manufactured homes located in those areas. It is essential
that coastal counties ensure that these standards are enforced. The Oregon
Department of Administrative Service’s inventory of State-owned and operated
buildings includes an assessment of roof conditions, as well as the overall condition of
the structure.

Fallen trees are especially challenging as they can block roads and rails for long
periods, which can affect emergency operations. In addition, uprooted or shattered
trees can down power and/or utility lines, disrupting local economic and other essential
activities. Much of the problem may be attributed to a shallow or weakened root
system in saturated ground. Many roofs have been destroyed by uprooted trees
growing next to a house. In some situations, strategic pruning may be the answer and
some counties will work with utility companies to identify problem areas and establish a
tree maintenance and removal program.

2.5.3.8 Extreme Heat

Oregon experienced an unprecedented extreme heat event across the State from
June 25 through June 30, 2021. A heat dome lodged over the Pacific Northwest
brought three consecutive days of temperatures between 106 and 117 degrees
Fahrenheit, resulting in the deaths of 83 people due to hyperthermia (elevated body
temperature). Ranging in age from 37 to 97, most of the deceased lived alone in
homes with no working air conditioning or fans. This lack of air conditioning left many
Oregon residents vulnerable to an extreme heat event. Just 78% of Portland area
households have a primary air conditioning unit, 13% less than the national average.79

79 https://oregoneconomicanalysis.com/2018/07/20/fun-friday-air-conditioning/

101
Figure 13: June 2021 Excessive Heat Map

80

Climate scientists predict that excessive heat will become a more common
occurrence, making for more frequent, more severe, and longer lasting heat events.81
While efforts must continue to slow and stop the factors contributing to climate change,
Oregon must also develop immediate and long-term strategies to adapt to today’s
changing climate. These efforts also must be incorporated into emergency and disaster
preparedness and mitigation plans. These events will continue to negatively impact
Oregon’s environment, economy, health, and livelihood.

2.5.3.9 Indispensable Services

Indispensable services are those that enable continuous operation of critical business
and government functions and/or are critical to human health and safety and
economic security. As part of the NHMP, DOGAMI and DLCD defined and quantified
such critical facilities to include buildings that function as airports, communications,
emergency operations, fire stations, hospitals or health clinics, military facilities, police
stations, schools, detention centers, or miscellaneous facilities (e.g., Oregon
Department of Transportation maintenance facility) that would be needed during or

80 https://www.oregon.gov/oem/Documents/2021_June_Excessive_Heat_Event_AAR.pdf
81 Substantial Changes in the Probability of Future Annual Temperature Extremes, University of Edinburgh.

102
immediately after a natural disaster. DOGAMI identified 3,990 such facilities valued at
more than $12 billion.

Tables 64 through 67 indicate the number and value of indispensable service facilities
exposed to each of five different hazard types.

Table 64: Wildfire Risk to Indispensable Services

High Low Moderate
County Services Value Services Value Services Value
Clackamas 5 $3,673,515 809 $3,136,262,722 11 $10,642,500
Douglas 52 $37,600,023 372 $871,024,081 61 $78,241,860
Jackson 112 $161,277,367 353 $1,564,121,625 10 $21,491,206
Lane 7 $5,655,494 634 $2,592,676,437 38 $54,174,853
Lincoln 193 $213,819,629
Linn 2 $419,288 328 $819,977,080 10 $5,251,334
Marion 2 $823,800 988 $3,308,607,213 2 $4,207,950
TOTAL 180 $209,449,487 3,677 $12,506,488,787 132 $174,009,703

Table 65: Landslide Risk to Indispensable Services

High Low Moderate
County Services Value Services Value Services Value
Clackamas 23 $113,269,172 644 $2,495,848,266 158 $541,461,299
Douglas 47 $55,717,431 319 $683,924,573 119 $247,223,960
Jackson 28 $66,167,333 332 $1,253,008,456 115 $427,714,409
Lane 22 $56,885,941 536 $2,360,693,588 121 $234,927,255
Lincoln 53 $36,616,276 104 $135,911,599 36 $41,291,754
Linn 5 $3,422,550 312 $782,580,902 23 $39,644,250
Marion 9 $5,903,193 897 $3,048,718,326 86 $259,017,444
TOTAL 187 $337,981,896 3,144 $10,760,685,710 658 $1,791,280,371

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Table 66: Earthquake Risk to Indispensable Services
Earthquake – High Earthquake – Low Earthquake – Moderate
County Services Value Services Value Services Value
Clackamas 384 $1,648,297,803 2 $1,500,000 439 $1,500,780,934
Douglas 184 $359,133,307 105 $303,058,431 196 $324,674,226
Jackson 277 $1,230,618,331 14 $42,668,087 184 $473,603,780
Lane 142 $293,816,852 300 $1,379,236,487 237 $979,453,445
Lincoln 127 $156,765,624 15 $9,274,189 51 $47,779,816
Linn 267 $721,958,342 14 $9,262,710 59 $94,426,650
Marion 817 $2,891,502,523 30 $99,152,014 145 $322,984,426
TOTAL 2,198 $7,302,092,782 480 $1,844,151,918 1,311 $3,743,703,277

Table 67: Flood Risk to Indispensable Services

Hazard Zone Other
County Services Value Services Value
Clackamas 12 $16,061,850 813 $3,134,516,887
Douglas 47 $127,700,345 438 $859,165,619
Jackson 35 $84,659,780 440 $1,662,230,418
Lane 95 $274,560,919 584 $2,377,945,865
Lincoln 10 $3,234,560 183 $210,585,069
Linn 26 $41,334,300 314 $784,313,402
Marion 157 $471,643,195 835 $2,841,995,768
TOTAL 382 $1,019,194,949 3,607 $11,870,753,028

2.5.4 Mitigation Needs Assessment Conclusion

The Mitigation Needs Assessment makes it clear that there are at least nine natural
hazards posing a risk to the seven MID counties. By characterizing these hazards in
terms of their frequency and the State’s vulnerability, the State and its sub-recipients
can draw on this needs assessment and the NHMP to identify current and future
hazards in their communities and target CDBG-DR funds toward cost-effective solutions
to mitigate them over the long term. In addition, this assessment will inform all CDBG-DR
programs and activities undertaken as part of this allocation so that, at a minimum,
they do not exacerbate hazards but rather serve to lessen their impacts.

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3. General Requirements
3.1 Citizen Participation
3.1.1 Outreach and Engagement
In the development of this Action Plan, OHCS consulted with disaster-affected residents,
stakeholders, local governments, public housing authorities, and other affected parties
in the surrounding geographic area to ensure that the consistency of the disaster
impacts identified in the plan and the plan and planning process were comprehensive
and inclusive.

State Agencies
To begin the development of the Public Action Plan, OHCS consulted with the following
State agencies to gain a better understanding of disaster impacts and the current
possible shortcomings of State and local funding for wildfire recovery.

• November 18, 2021 – Oregon Office • December 17, 2021 – Business Oregon
of Emergency Management
• January 5, 2022 – Oregon Department
• December 1, 2021 – Oregon of Consumer and Business Services
Department of Land Conservation
• January 10, 2022 – Oregon
and Development
Employment Department
• December 9, 2021 – Housing Authority
• January 18, 2022 – Oregon
of Jackson County
Department of Environmental Quality
• December 9, 2021 – Insurance
• January 26, 2022 – Oregon
Commissions/Homebuilders
Department of Agriculture
Association
• January 27, 2022 – Oregon
• December 15, 2021 – Marion County
Department of Consumer and
Housing Authority
Business Services
• December 16, 2021 – Oregon
• February 7, 2022 – Oregon Office of
Department of Consumer and
Emergency Management
Business Services
• February 8, 2022 – Oregon Law Center
• December 16, 2021 – Oregon
Department of Energy

Through these consultation meetings, OHCS was able to gather data, experiences, and
agency expertise to develop an initial unmet needs assessment.

105
Local Governments and Stakeholders
After developing the initial unmet needs assessment from State agency and federal
data, OHCS began an early round of public engagement meetings with local counties,
city governments, and long-term recovery groups (LTRGs). OHCS staff were allotted
time to present and ask for feedback at each community meeting. The goals of this
initial round of engagement were to present OHCS’s initial unmet needs assessment
and understand the gaps for which local governments, partners, and stakeholders
could present more insight.

• March 2, 2022 – City of Talent Council • March 24, 2022 – McKenzie Rebuilds
Housing Subcommittee
• March 3, 2022 – Clackamas County
LTRG • March 25, 2022 – Tribal Economic
Development Cluster
• March 4, 2022 – Housing Stability
Council • March 28, 2022 – McKenzie Valley
LTRG
• March 4, 2022 – Jackson County LTRG
• March 29, 2022 – Lane County
• March 7, 2022 – City of Phoenix Council
Commission
• March 7, 2022 – Holiday Farm Fire
• March 29, 2022 – Lincoln County Staff
Recovery Coordination
and Commissioner Kaety Jacobson
• March 8, 2022 – Lincoln County LTRG
• March 30, 2022 – City of Talent
• March 10, 2022 – Marion County Board Council Working Session
of Commissioners and Various Cities
• March 31, 2022 – Disaster Housing
• March 11, 2022 – Catholic Charities Recovery Task Force
Disaster Case Managers
• March 31, 2022 – Latinx Jackson
• March 16, 2022 – McKenzie Disaster County Focus Group (with Unete)
Recovery Collective
• April 1, 2022 – Klamath/Lake LTRG
• March 17, 2022 – Housing Tribal Cluster
• April 4, 2022 – Latinx Jackson County
• March 17, 2022 – Southern Oregon Focus Group (with Unete Oregon)
Regional Solutions Advisory Committee
• April 4, 2022 – OHCS Manufactured
• March 22, 2022 – Jackson County Housing Advisory Committee
Commission
• April 5, 2022 – Santiam LTRG
• March 23, 2022 – Reimagine and
Rebuild Rogue Valley Collective Input
Meeting

106
From the initial round of engagement, OHCS was able to receive information from local
stakeholders and input on the types of programming for which communities wanted
federal funding.

This initial round of public engagement found significant interest in programming for
housing and infrastructure issues caused by the wildfire impacts. Many individuals were
displaced by the fire and were currently living in RVs/fifth wheels. Community members
expressed interest in creating affordable rental housing or possible homeownership
opportunities for these individuals. From an infrastructure perspective, many
communities strongly indicated that damaged – or previously lacking - infrastructure
has limited the ability for both homeowners and businesses to recover. They also noted
that very few businesses received federal assistance, leaving them few resources with
which to attempt to reopen following both the wildfire and the COVID-19 pandemic.
Communities also expressed interest in finding innovative ways to build fire hardening
measures and strategies into their community planning and building codes. This would
ultimately help communities mitigate against future wildfire risks and vulnerabilities.
Feedback from these sessions greatly helped inform OHCS’s allocation of funds and
program implementation.

Summary of Feedback
Based on these meetings, the State received additional information on unmet recovery
and mitigation needs that are not necessarily reflected in the federal datasets.

Housing
• The vast majority of respondents affirmed the priority to focus on providing housing
for low- and moderate-income households.
• Severe shortage of rental housing, particularly affordable rental housing. Universally
commented on. True in urban areas (cities of Phoenix and Talent), also a common
theme in the Santiam Canyon, McKenzie River Valley, and Archie Creek fire-
impacted areas. Urban areas are seeing some multifamily projects come in for
permits; however, it is unclear where new rental opportunities in more remote rural
areas will come from as there are few opportunities for multi-unit rental
development due to land use and infrastructure constraints. Santiam Canyon,
Jackson County, and Lincoln County all noted severe challenges with regard to
workforce housing (at multiple income levels).
• Homeownership opportunities sought. Very common theme, emphasized
particularly in the City of Phoenix. The City of Talent and the Unete focus group were
very interested in expanding opportunities for community equity models (e.g., coop,
community land trust) in park rebuilds.

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• Many survivors were living in RVs/fifth wheels. Particularly true in the McKenzie River
Valley, Santiam Canyon, Lincoln County, and Klamath (Bootleg Fire). Hundreds of
individuals and families lost RVs that were a primary residence. Many were living on
the property of extended family or friends; in the Bootleg Fire, many were on public
property. In some areas, these are as much as half of the population that remains
very difficult to house/serve.
• Large LMI populations but has other needs as well. The Catholic Charities’ disaster
case managers (DCMs) reported that the hardest to serve populations in Jackson
County were LMI populations formerly occupying manufactured homes. Glide
Revitalization (Archie Creek fire/Douglas County) reported that roughly three-
quarters of families struggling to rebuild were LMI. Unete and Jackson County LTRG
surveys documented large LMI populations. However, moderate income
populations (above the LMI level) also are struggling with building costs, materials
costs, and being underinsured. This is notable in the McKenzie River LTRG needs
assessment, Lincoln County LTRG, Joint Committee on Wildfire Recovery testimony,
and the Unete focus group.
• Housing must be built to accommodate/provide access for those with disabilities.
This issue was noted among discussants at the AARP study presentation and Unete
focus group. Those with disabilities are struggling with recovery and we all either
have a disability currently or are at risk of developing one in the future.
• Housing permitting infrastructure. Lane County, in particular, noted that providing
permit review and inspection services will be a challenge.

Mitigation
• There was strong, near universal, support for the importance of integrating resilience
in new housing construction. Several discussions noted that this will be very difficult
with regard to manufactured homes.
• Local governments, in particular, are seeking mitigation infrastructure investments.
Marion County is seeking $2 million in funding to replace major components of the
public safety radio system. There are similar needs in Douglas and Lane counties.
(Jackson County requested consideration regarding the use of CDBG to support
debt service toward recent emergency communications investments.)
• Human/Organizational preparedness. Participants in the Unete focus group
commented on the need for more education on/understanding of how to deal with
disaster among community-based organizations, churches, and local governments.
• Dual-purpose investments were proposed (e.g., there was a need in the
Santiam/Detroit area for a warming shelter that could also double as an evacuation
point or immediate disaster shelter).

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Infrastructure
• Governments and LTRGs in both canyons (Santiam Canyon and McKenzie River
Valley) noted that additional investments in infrastructure (particularly
sewer/community septic) are essential for businesses and homeowners to recover.
Landlords/Sellers are not willing to rebuild because the infrastructure is insufficient.
The Glide Water District has a capacity issue that is a constraint on recovery as well.
(Much of the lost housing was marginally served or in gray areas in terms of
permitting. Feasible routes for returning housing in some numbers, particularly for
renters, are dependent upon new infrastructure investments.) There is a need for
immediate planning, engineering work, and longer term capital investments.
• Transportation investments. Improvements to damaged roads and a need for a
new, more urban infrastructure are issues in Marion and Lincoln counties, in
particular. The City of Phoenix and Unete focus group both noted a need for new
pedestrian safety improvements as denser development is occurring in the semi-
urbanized areas of Jackson County.
• The City of Phoenix plans to urbanize the unincorporated area that burned and will
require additional infrastructure investment.

Economic Revitalization
• Many businesses are stuck in recovery with insufficient insurance to complete
rebuilds. This issue was raised by the City of Talent Council, the Southern Oregon
Regional Solutions Advisory Committee, and elsewhere. Several communities, both
in Jackson County and in Santiam Canyon (particularly Detroit and Gates), lost
large proportions of their commercial areas. Lack of reinvestment poses a long-term
challenge to the financial viability of local government and is a deterrent to
potentially returning residents.
• Many businesses received no assistance. Early-stage businesses did not have the
financial records/history to qualify for SBA loans.
• New businesses seeking to establish business and/or join in the recovery process lack
resources. Several early-stage businesses in Glide are actively seeking financing.
• Mixed-income or mixed-use (housing over commercial) investments could be a
means to help jump-start commercial zone redevelopment (e.g., City of Detroit,
Jackson County urban areas).
• The workforce housing barriers noted above are an economic revitalization
challenge.

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Administration/Support Services
• Mixed comments from local governments on centralization/decentralization.
Several governments (e.g., Lane County Board of Commissioners) expressed interest
in more decision making and control being devolved to local government. Several,
including Jackson County and the City of Phoenix, noted that the local capacity to
manage/deliver programs under HUD rules could be a challenge.
• Social support programs for survivors. An interest in additional/continued services for
survivors was noted in multiple contexts, particularly a need for help with
mental/behavioral health, legal aid support, and assistance in accessing CDBG-DR
programs. Multiple parties emphasized a need to maintain continuity of services for
the most-challenged survivors by finding ways to allow them to continue working
with existing DCMs and LTRGs that have established relationships and trust. Lane
County noted a need for more tribal member outreach.

Eligibility
• Bootleg fire. The number of survivors severely impacted by the Bootleg fire (in 2021) is
likely larger than the Clackamas, Douglas (Archie Creek), or South Obenchain fires
of 2020. It is unfair that they have had so many fewer resources.
• Marginalization/Documentation issues. Members of the Unete focus group noted
that many from the farmworker and immigrant community do not live in the “black
and white” boxes of the majority population. Both the rules and the attitude of those
administering the rules and interacting with survivors need to take account of this
reality.

Survey
OHCS recognizes that affected stakeholders are at the center of and are partners in
the development and implementation of this plan. Opportunities for resident input were
provided throughout the planning process through a public input survey that was
posted on the OHCS website. This survey also was distributed at OHCS presentations
and provided to DCMs/community leaders to distribute to impacted residents.

An email inbox for the program also was created for residents to directly voice
concerns and/or provide additional feedback to the OHCS team.

The Public Action Plan’s Public Comments

In addition to the activities above, OHCS has published this Action Plan at
https://www.oregon.gov/ohcs/housing-assistance/Pages/CDBG.aspx for a 30-day
public comment period. Residents were notified through the following methods:

• Direct email notice to individuals who had signed up for updates on CDBG-DR plan
development.

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• Email notices to local and tribal governments and nonprofit/community-based
organizations that have been active in supporting survivors in disaster recovery,
e.g., Long Term Recovery Groups, AARP, disability service advocates, and culturally-
specific organizations.
• Press release to all major news outlets state-wide.
• Announcements on agency-managed social media accounts.
• Formal notice on OHCS’s website.
OHCS will ensure that all residents have equal access to information, including persons
with disabilities (vision and hearing impaired) and limited English proficiency (LEP).

A summary of residents’ comments on this Action Plan, along with OHCS responses, is in
an Appendix of this document. For more information, residents can refer to the OHCS
Citizen Participation Plan, which can be found at
https://www.oregon.gov/ohcs/housing-assistance/Pages/CDBG.aspx.

3.1.2 Public Hearings

As part of its initial Public Action Plan development process, OHCS is required to hold at
least one public hearing in one of the HUD-identified MID areas in order to obtain
residents’ views and to respond to proposals and questions.

The current (tentative) schedule for Public Hearings is to host public hearings in the
following locations, the week of May 16:

• Lincoln County
• Marion/Linn County
• Lane County
• Jackson County

• Virtual Open House

The in-person public hearings will be supplemented by placing key information and
recorded presentations on the project website along with multiple methods for making
virtual public comments.

3.1.3 Complaints and Appeals

3.1.3.1 Complaints
OHCS or its subrecipients shall provide a written response to each formal complaint
within 15 working days of receipt of the complaint or will document why additional time
for a response is needed.

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• Formal complaints are written statements of grievance, including email, comments
posted on the OHCS website, and handwritten complaints. OHCS shall detail the
process and contact information (through the website and email address) for
submitting complaints within program guidelines, application documents, and on
the OHCS website. OHCS shall maintain a tracker for collecting and categorizing
complaints through resolution.
• Informal complaints are verbal complaints. OHCS and its subrecipients will attempt
to resolve informal complaints; however, they are not subject to the written response
process described above.
• Complaints alleging the violation of fair housing laws will be directed to HUD for
immediate review. Complaints regarding fraud, waste, or abuse of government
funds should be forwarded to the HUD Office of the Inspector General Fraud Hotline
(phone: 1-800-347-3735 or email: [email protected]). OHCS will make available to
HUD detailed Fraud, Waste, and Abuse Policies and Procedures on
https://www.oregon.gov/ohcs/housing-assistance/Pages/CDBG.aspx to
demonstrate that adequate procedures are in place to prevent fraud, waste, and
abuse.

3.1.3.2 Appeals
OHCS or its subrecipients shall include written appeals processes within each set of
program guidelines. The appeals processes will include, but are not limited to the
following:

• The process for submitting, tracking, and resolving a written appeal to the
organization administering the program (OHCS or its subrecipient), to include
whether an appeals committee will be established to review and/or rule on
appeals.
• The documentation required when submitting an appeal.
• The timelines for reviewing and providing a response to the appeal.
• Clarification of what may or may not be appealed. Generally, policies that have
been approved and adopted within program guidelines may not be appealed.
OHCS and its subrecipients do not have the authority to grant an appeal to a
regulatory or statutory or HUD-specified CDBG-DR requirement.

3.2 Public Website

OHCS will maintain a public website that provides information accounting for how all
grant funds are used, managed, and administered, including links to all disaster
recovery action plans, action plan amendments, program policies and procedures,
performance reports, citizen participation requirements, activity and program

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information described in this plan, and the details of all contracts and ongoing
procurement processes.

These items are made available at https://www.oregon.gov/ohcs/housing-

assistance/Pages/CDBG.aspx.

Specifically, OHCS will make the following items available: the action plan created
using the Disaster Recovery Grant Reporting System (DRGR), including all amendments;
each Quarterly Progress Report (as created using the DRGR); citizen participation plan;
procurement policies and procedures; all executed contracts that will be paid with
CDBG-DR funds as defined in 2 CFR 200.22 (including subrecipients’ contracts); and a
summary, including the description and status of services or goods currently being
procured by the grantee or the subrecipient (e.g., phase of the procurement,
requirements for proposals). Contracts and procurement actions that do not exceed
the micro-purchase threshold, as defined in 2 CFR 200.67, are not required to be posted
on a grantee’s website.

In addition, OHCS will maintain a comprehensive website regarding all disaster recovery
activities assisted with these funds.

OHCS shall make these documents available in a form accessible to persons with
disabilities and those with limited English proficiency, or LEP. OHCS shall take reasonable
steps to ensure meaningful access to their programs and activities by LEP persons,
including individuals from underserved communities, and in a form accessible to
persons with disabilities.

The website will be updated in a timely manner to reflect the most up-to-date
information about the use of funds and any changes in policies and procedures,
as necessary. At a minimum, updates will be made monthly.

3.3 Amendments
Over time, recovery needs will change. Thus, OHCS will amend the Disaster Housing
Recovery Action Plan as often as necessary to best address the long-term recovery
needs and goals. This plan describes proposed programs and activities. As programs
and activities develop over time, an amendment may not be triggered if the program
or activity is consistent with the descriptions provided in this plan.

When unmet needs and program descriptions or other sections rise to the level of
requiring an action plan amendment, the State will do the following:

• Ensure that the current version of the Action Plan is accessible for viewing as a single
document, with all amendments, so that the public and HUD do not have to view
and cross-reference changes among multiple amendments.

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• Identify amendments by highlighting added or changed text and striking out
deleted text.
• Include a table that clearly illustrates where the funds are coming from and where
they are going.
• Include a revised budget allocation table that reflects the entirety of all funds,
if applicable to the amendment.

3.3.1 Substantial Amendment

A change to the initial Action Plan is substantial if it meets the following criteria:

• A change in program benefit or eligibility criteria

• The addition or deletion of an activity
• The allocation or reallocation of the greater of either a re-allocation of $5 million
or a reallocation that constitutes a change of 15% or greater of a program budget
When OHCS pursues the substantial amendment process, the amendment will be
posted on the State’s CDBG-DR website for a 30-day public comment period, located
at https://www.oregon.gov/ohcs/housing-assistance/Pages/CDBG.aspx.
The amendment will be posted in adherence with the Americans with Disabilities Act
and LEP requirements. OHCS will review and respond to all public comments received
and submit the comments and responses to HUD for approval.

A substantial action plan amendment shall require the following:

• The State will revisit the impact and needs assessment when moving funds from one
program to another through a substantial amendment.
• A 30-day public comment period will include the following:
– The State will prominently post the action plan amendment on the OHCS official
disaster recovery website at https://www.oregon.gov/ohcs/housing-
assistance/Pages/CDBG.aspx.
– The State will afford residents, affected local governments, and other interested
parties a reasonable opportunity to review the plan or substantial amendment.
– The State will identify and consider potential barriers that limit or prohibit
equitable participation and will undertake reasonable measures to increase
coordination, communication, affirmative marketing, targeted outreach, and
engagement with underserved communities and individuals, including persons
with disabilities and persons with limited English proficiency. This includes the
following:
o The action plan amendment will be translated according to the CDBG-DR
Language Access Plan.

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 o The action plan amendment will be posted in a way that meets all
accessibility requirements.
– The State will review and respond to all written and oral public comments
received. Any updates or changes made to the Action Plan in response to
public comments shall be clearly identified in the Action Plan and amendments.
The public comments also will be submitted to HUD with the final Action Plan
amendment.
• Receipt of approval from HUD.

3.3.2 Non-Substantial Amendment

A non-substantial amendment is an amendment to the plan that includes technical
corrections and clarifications and budget changes that do not meet the monetary
threshold for substantial amendments to the plan and does not require posting for
public comment. OHCS will notify HUD 5 business days before the change is effective.

All amendments will be numbered sequentially and posted to the website in one final,
consolidated plan.

3.4 Displacement of Persons and Other Entities

To minimize the displacement of persons and other entities that may be affected by the
activities outlined in this Action Plan, OHCS will coordinate across federal, State, and
local organizations to meet its commitment to minimize the displacement of
homeowners and tenants due to the delivery of CDBG-DR programs. Should any
proposed projects or activities cause the displacement of people, the following policy
has been adopted to ensure that the requirements of the Uniform Relocation
Assistance and Real Property Acquisition Act of 1970 (URA), as amended, are met.

OHCS will draw on existing Residential Antidisplacement and Relocation Assistance

Plans (RARAPs) and will adapt them to meet the URA, Section 104(d), and related
waivers and the alternative requirements specified in the Consolidated Notice. The
adapted RARAP also will be updated prior to implementing any activity with CDBG-DR
grant funds.

Since the 2020 Wildfires and prior to the availability of CDBG-DR funding, OHCS has
been working to minimize the displacement and loss of housing assistance for impacted
owner and renter residents by coordinating the provision of support and resources to
impacted survivors through multiple entities, including the following:

• FEMA
• FEMA disaster case managers
• Oregon Department of Human Services

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• Oregon Health Authority
• Oregon Office of Emergency Management
• Local governments
• Long-term recovery groups
• Community action agencies
• Public housing authorities
• State and local elected officials
• Other community-based organizations

OHCS will ensure that all CDBG-DR programs directly administered by OHCS and those
programs administered through partner State agencies and subrecipients comply with
the Uniform Relocation Assistance and Real Property Acquisition Act of 1970, as
amended (49 CFR Part 24), and Section 104(d) of the Housing and Community
Development Act of 1974, as amended, and the implementing regulations at 24 CFR
Part 570.496(a) to minimize displacement. These regulations and requirements apply to
both property owners and tenants in the event that proposed projects cause the
displacement of persons or other entities. OHCS will include detailed policies and
procedures for when proposed programs or projects could potentially cause the
displacement of people or other entities.

CDBG-DR funds may not be used to support any federal, State, or local projects that
seek to use the power of eminent domain, unless eminent domain is employed only for
a public use. Public use shall not be construed to include economic development that
primarily benefits private entities. None of the currently planned projects under this
Action Plan contemplate the use of eminent domain.

3.5 Protection of People and Property

The State of Oregon will leverage the CDBG-DR funds to build economic and disaster
resilience into all recovery programs and activities. Some of the ways that the State will
do this are included in the sections below.

3.5.1 Elevation Standards

3.5.1.1 Residential
All structures, defined at 44 CFR 59.1, designed principally for residential use and
located in the 1% annual chance (or 100-year) floodplain, which receive assistance for
new construction, reconstruction, rehabilitation of substantial damage, or rehabilitation
that results in substantial improvement, as defined at 24 CFR 55.2(b)(10), must be
elevated with the lowest floor, including the basement, at least 2 feet above the 1%
annual chance floodplain elevation (base flood elevation). Mixed-use structures with

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no dwelling units and no residents below 2 feet above base flood elevation must be
elevated or floodproofed in accordance with FEMA floodproofing standards at 44 CFR
60.3(c)(3)(ii) or a successor standard up to at least 2 feet above base flood elevation.

If a structure is located in a 500-year floodplain, the structure must be elevated 3 feet

above the 100-year floodplain.

Based on FEMA IA data, it is estimated that fewer than 10 properties that were
destroyed by the wildfires were located in the Special Flood Hazard Area (SFHA),
or 100-year floodplain. However, it is known that portions of some manufactured home
parks are located in the SFHA, and it is likely that there are more than 10 impacted
properties in the SFHA. OHCS will discourage the placement or reconstruction of
housing in the SFHA, wherever practicable; however, there will be homes that will be
rebuilt or replaced in the SFHA. OHCS will ensure that all rehabilitation of substantial
damage will meet the HUD-required elevation standards through the construction
requirements of all CDBG-DR residential programs.

The cost of elevation will be included as part of the overall cost of rehabilitation or
replacement of a property. It is estimated that the costs will depend on the location,
the size of the unit, and the level to which the property must be elevated. For single-
family residences and manufactured homes, if a home is within a 100-year floodplain,
OHCS will ensure the cost reasonableness of elevation costs by analyzing multiple bids
from contractors, cost estimating software, and/or examples of comparable costs to
elevate in similar markets.

OHCS and the Oregon Department of Land Conservation and Development (DLCD)
have already provided the 2-foot elevation requirements to local building and permit
officials, and they are working with residents in the floodplain to inform them that this is
a requirement in order to qualify for CDBG-DR assistance.

3.5.1.2 FEMA PA or HMGP Match

All critical actions, as defined at 24 CFR 55.2(b)(3), within the 500-year (or 0.2% annual
chance) floodplain must be elevated or floodproofed (in accordance with FEMA
floodproofing standards at 44 CFR 60.3(c)(2)–(3) or a successor standard) to the higher
of the 500-year floodplain elevation or 3 feet above the 100-year floodplain elevation.
If the 500-year floodplain is unavailable and the critical action is in the 100-year
floodplain, then the structure must be elevated or floodproofed (in accordance with
FEMA floodproofing standards at 44 CFR 60.3(c)(2)–(3) or a successor standard) at least
3 feet above the 100-year floodplain elevation.

“Critical actions” are defined as “any activity for which even a slight chance of
flooding would be too great because such flooding might result in loss of life, injury to

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persons or damage to property.” For example, Critical Actions include hospitals, nursing
homes, emergency shelters, police stations, fire stations, and principal utility lines.

Exceptions to this requirement may be allowable when the following conditions apply:

• CDBG–DR funds are used as the non-federal match for FEMA assistance.
• The FEMA-assisted activity, for which CDBG–DR funds will be used as match,
commenced before HUD’s obligation of CDBG–DR funds to the grantee.
• OHCS has determined and demonstrated with records in the activity file that the
implementation costs of the required CDBG–DR elevation or floodproofing
requirements are not “reasonable costs” as that term is defined in the applicable
cost principles at 2 CFR 200.404.

3.5.2 Flood Insurance Requirements

The 2020 Wildfires in Oregon were not a flooding event; however, the State is
committed to ensuring that homeowners are protected from future flooding disasters.
The State—including through the DLCD and Oregon Office of Emergency
Management—is working closely with local floodplain managers to encourage
residents, businesses, and local governments to maintain flood insurance, including for
properties located outside the SFHA. The State also is working closely with FEMA and
local floodplain managers to understand the implications of Risk Rating 2.0 and the
additional costs of flood insurance policies to help inform more resilient building codes
and practices.

Property owners who are receiving assistance must comply with all flood insurance
requirements.

Because the 2020 Wildfires were not a flooding event, the following conditions DO NOT
apply:

HUD-assisted homeowners for a property located in an SFHA must obtain and maintain
flood insurance in the amount and duration prescribed by FEMA’s National Flood
Insurance Program. The grantee may not provide disaster assistance for the repair,
replacement, or restoration of a property to a person who has received federal flood
disaster assistance that was conditioned upon obtaining flood insurance and then that
person failed to obtain or allowed their flood insurance to lapse for the property. The
grantee is prohibited by HUD from providing CDBG-DR assistance for the rehabilitation
or reconstruction of a house if:

• The combined household income is greater than 120% of the area median income
(AMI) or the national median,
• The property was located in a floodplain at the time of the disaster, and

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• The property owner did not maintain flood insurance on the damaged property.
To ensure that adequate recovery resources are available to LMI homeowners who
reside in a floodplain but who are unlikely to be able to afford flood insurance,
homeowners may receive CDBG-DR assistance if:

• The homeowner had flood insurance at the time of the qualifying disaster and still
has unmet recovery needs, or
• The household earns less than 120% of the AMI or the national median and has
unmet recovery needs.

3.5.3 Construction Standards

OHCS will require quality inspections and code compliance inspections on all projects
and places, with an emphasis on high-quality, durable, sustainable, and energy-
efficient construction methods and materials. Site inspections will be required on all
projects to ensure quality and compliance with building codes.

Oregon’s impacted communities indicated early in the aftermath of the disaster that
they were struggling to meet the demands of inspections, permitting, and supporting
residents through their recovery. To help increase the capacity of local governments,
the State legislature appropriated more than $4 million in financial assistance for local
building and planning department staff to help expedite the inspection and permitting
processes.

All rehabilitation, reconstruction, or new construction must meet an industry-recognized

standard that has achieved certification under at least one of the following programs:

• ENERGY STAR® (Certified Homes or Multifamily High Risk)

• Enterprise Green Communities
• LEED (New Construction, Homes, Midrise, Existing Building Operations and
Maintenance, or Neighborhood Development)
• ICC 700 National Green Building Standard®
• U.S. Environmental Protection Agency (EPA) Indoor airPLUS
• Equivalent or higher Oregon energy efficiency standards
• Any other equivalent comprehensive green building standard program acceptable
to HUD

OHCS will specify the standards that will be used within each set of program guidelines.

For the rehabilitation of non-substantially damaged residential buildings, OHCS will

follow the guidelines to the extent applicable as specified in the HUD Office of

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Community Planning and Development (CPD) Green Building Retrofit Checklist.
When older or obsolete products are replaced as part of rehabilitation work, the
rehabilitation is required to use ENERGY STAR-labeled, WaterSense-labeled, or Federal
Energy Management Program-designed products and appliances.

For infrastructure projects, OHCS will encourage, to the extent practicable, the use of
green infrastructure design and implementation, such as those issued by:

• U.S. EPA through their Green Infrastructure Design and Implementation guidance.
• HUD through their Green Infrastructure and Sustainable Communities Initiative.
• Standards that are incentivized through the Oregon Department of Environmental
Quality, including for clean water initiatives.

The term “substantial damage” applies to a structure in an SFHA—or floodplain—for

which the total cost of repairs is 50% or more of the structure's market value before the
disaster occurred, regardless of the cause of the damage.

Per Oregon Revised Statute 456.510, OHCS-funded rental housing programs must follow
visitability requirements. With certain exceptions, OHCS-subsidized rental housing for a
new single-family or duplex dwelling with habitable space on the first floor must be
designed and constructed as a “visitable” dwelling (see https://www.oregonlaws.org
/ors/456.510). The State will adopt this standard in the reconstruction or new
construction of all site-built housing funded with CDBG-DR assistance. This is in addition
to ensuring that all multifamily housing subsidized with CDBG-DR assistance meet
Americans with Disabilities Act and accessibility requirements. By adopting this standard
across its programs, the State will help increase the availability of accessible housing to
meet the current and future needs of older adults and people living with disabilities. This
will increase opportunities for households to age in place and build in increased
community resiliency for individuals with disabilities.

All projects will be subject to cost reasonableness standards as outlined in the policies
and procedures of the applicable program specific to the applicable activity.

3.5.4 Contractors’ Standards

Contractors selected under OHCS will make every effort to provide opportunities to low-
and very low-income persons by providing resources and information to notify Section 3
individuals and businesses about opportunities in the community.

OHCS will undertake the following efforts to help meet its Section 3 goals:

• Ensure that Section 3 requirements are outlined in all applicable contracts and
subrecipient agreements.

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• Build the capacity of stakeholders, including subrecipients and contractors, to meet
Section 3 standards through technical assistance, tools, and guidance.
• Designate a Section 3 coordinator who will manage, support, and facilitate an
effective Section 3 program, and who will be able to effectively communicate
program requirements to stakeholders.

OHCS will report on Section 3 accomplishments in the DRGR.

Recovery programs implemented by OHCS and its subrecipients will incorporate

uniform best practices of construction standards for all construction contractors
performing work in all relevant jurisdictions. Construction contractors will be required to
carry the required licenses and insurance coverage(s) for all work performed, and
State-contracted contractors will be required to provide a warranty period for all work
performed.

Contractor standards and warranty periods will be detailed in the respective policies
and procedures documents and will pertain to the scale and type of work being
performed, including the controls for ensuring that construction costs are reasonable
and consistent with market costs at the time and place of construction. Rehabilitation
contract work provided through a program administered by OHCS included in this
Action Plan may be appealed by homeowners and small businesses (if applicable)
whose property was repaired by contractors under the State’s control.

As included in the State’s certifications, OHCS is committed to meeting full and open
competition requirements, which will help ensure that construction costs are reasonable
and consistent with market costs at the time and place of construction.

The processes for homeowners to submit appeals and complaints for rehabilitation work
completed through State-administered programs will be detailed within each
respective set of program guidelines.

3.5.5 Preparedness, Mitigation, and Resilience

“Resilience” is defined as a community’s ability to minimize damage and recover
quickly from extreme events and changing conditions, including natural hazard risks.

3.5.5.1 Protect People and Property from Hardship

Each OHCS CDBG-DR program and activity—whether through construction activities,
public services, and/or planning activities—includes measures that will increase
resilience to disasters and reduce or eliminate the long-term risk of life, injury, damage
to and loss of property, and suffering and hardship by lessening the impact of future
disasters. Hardships include, but are not limited to, financial hardship and hardship
caused by future disasters and climate change. The State will document how programs

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and activities protect people and property from hardship within program and/or
applicant files.

3.5.5.2 Emphasize High Quality, Durability, Energy Efficiency, Sustainability,

and Mold Resistance
To ensure energy efficiency in all new construction, reconstruction, and replacement
activities, OHCS will adopt one of the standards allowed by HUD and/or more strict
standards required by the State of Oregon. These standards will be detailed in program
guidelines. For example, OHCS may adapt the practices and requirements carried out
through the Oregon Department of Energy’s Energy Efficient Wildfire Rebuilding
Incentive Program. This program incentivizes energy efficiency in the reconstruction or
replacement of damaged housing at or above the applicable building codes.
Incorporating these energy efficiency improvements help make structures more
comfortable and support long-term affordability through lower energy bills.

To the extent practicable and at a reasonable cost, the State will build the home to an
above-code standard, such as the Oregon Residential Reach Code, which provides an
additional choice for builders, consumers, and contractors to increase energy
efficiency for the construction of structures regulated by the Oregon Residential
Specialty Code.

For repairs, the State will use the HUD CPD Green Building Retrofit Checklist and will
attempt to add additional energy efficiency components when practicable and/or of
reasonable cost. In all construction activities administered by the State, the State will
use mold-resistant products when replacing surfaces such as drywall.

3.5.5.3 Support the Adoption and Enforcement of Modern and Resilient

Building Codes and the Mitigation of Natural Hazard Risks
The Oregon Building Codes Division adopts, amends, and interprets the specialty codes
that make up the Oregon State Building Code. The division administers each code
through specialized code programs. Agency staff members work with local building
officials, industry professionals, advisory boards, and the public to adopt new codes
and standards, approve new methods and materials, and maintain a uniform building
code throughout the State.

Oregon building codes include extensive energy efficiency requirements. The division
also publishes guidance on requirements and how to design and build for seismic,
ground snow load, and special wind risks.

Local building codes and planning departments also incorporate specific disaster
mitigation features that reflect the risks in their communities. Some of these features are
outlined below:

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• Three out of the seven HUD-identified MIDs are participating in the National Flood
Insurance Program Community Rating System. Marion County requires the
construction of properties to be at least 2 feet above base flood elevation.
• Jackson County requires a fire safety inspection, which includes fire resiliency
requirements.
• Klamath and Linn counties include recommendations for fire mitigation within their
local planning and permitting departments.

Each city and every county have a comprehensive plan that includes a zoning layer.
Some of them limit the density and quantity of development. Generally, these
requirements are in line with the State’s planning and Urban Growth Boundaries.
Through these zoning layers, many local governments define what are considered to
be buildable lands. The key components that influence the development on buildable
lands are described below:

• Urban Growth Boundaries allow cities to plan for growth and prevent urban sprawl,
safeguarding farm and forest lands.
• Affordable housing initiatives allow more people to call Oregon their home.
• Economic development analyses help local land use planners set up their towns
and cities for long-term success.
• Transportation planning allows towns to grow into newly built roads and pathways
without feeling constricted.
• Public facility plans ensure that people will have the utilities they need for
modern life.
• Recreation planning allows residents and visitors to enjoy Oregon’s beauty.

The Building Codes Division also has launched a Fire Hardening Grant Program for
homes and businesses that were lost or damaged in the 2020 Wildfires. The program will
provide money directly to home and business owners who complete qualifying fire
hardening improvements on their home or business that was damaged or destroyed.
The Fire Hardening Options Guide provides a menu of incentivized fire hardening
options to encourage residents and business owners to rebuild more resiliently. To the
extent practicable, OHCS will incorporate these fire hardening measures in all
reconstruction or substantial rehabilitation programs.

OHCS will draw from best practices across Oregon and the country, as applicable, to
incorporate these standards into the State’s program designs. In addition, OHCS may
help local governments consider adopting and enforcing modern and resilient building
codes that account for known risks and projected risks arising from climate change.

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3.5.5.4 Establish and Support Recovery Efforts by Funding Feasible, Cost-Effective
Measures That Will Make Communities More Resilient Against a Future Disaster
OHCS will document in program guidelines and project files how approved programs or
projects will make communities more resilient against a future disaster. Within the file,
OHCS will include a cost reasonableness and/or cost-benefit analysis of the activity,
which will include the quantifiable benefits or description of the mitigation benefits of
the project or program. This may include, but is not limited to, an analysis of:

• The risks to public health, safety, and well-being without the project or program.
• The costs against the anticipated value of the risk reduction in both direct damages
and subsequent negative impacts to the area if future disasters were to occur.
• The contribution of the activity to a long-term solution to the problem it is intending
to address.
• How the activity will protect the functionality of the project for its useful life and/or
create manageable future maintenance and modification options.

3.5.5.5 Make Land Use Decisions That Reflect Responsible and Safe Standards
to Reduce Future Natural Hazard Risks
Allowable uses of lands in Oregon are heavily regulated and enforced through State
and local building codes, zoning, and adopted plans. Many of these efforts include
extensive measures to reduce future natural hazard risks, and OHCS will ensure that
CDBG-DR activities comply with existing and future applicable State and local
requirements.

Through the planning activities funded through this Action Plan, local and tribal
governments may use funds to carry out the planning needed to enhance local codes
and standards, carry out additional outreach to members of their communities, and/or
develop policy modifications that will help encourage responsible and safe standards
to reduce future natural hazard risks.

3.5.5.6 Increase Awareness of the Hazards in Communities, Including Underserved

Communities, Through Outreach in the MID Areas
To effectively increase the awareness of community hazards, the State knows that
information needs to be shared with residents and businesses through local, trusted
resources. As part of the delivery of CDBG-DR programs, the State will allocate or award
significant funding to local governments and community-based nonprofit organizations
through its housing, public services, planning, and infrastructure programs.

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The State will partner with these organizations to help carry out the recovery and
mitigation programs. Through those partnerships, the State also will seize the opportunity
to help local entities share information, perform community outreach and
engagement, and solicit feedback from those with lived experiences to help increase
awareness of macro- and micro-level risks to impacted communities.

3.5.5.7 Promote Sound, Sustainable Long-Term Recovery Planning Informed by a

Post-Disaster Evaluation of Natural Hazard Risks
The State has allocated some funding toward planning activities. One of the primary
purposes of the program is to promote sound, sustainable long-term recovery that
accounts for an understanding of current and projected natural hazard risks, including
climate-related hazards.

3.5.5.8 Use of the FEMA-Approved Hazard Mitigation Plan

The Oregon DLCD is the lead agency for developing the State’s FEMA-approved
Hazard Mitigation Plan. However, the planning process is informed by multiple federal,
State, local, and tribal government agencies, through the development of local hazard
mitigation plans, and the State Interagency Hazard Mitigation Team.

For its programs, OHCS will coordinate and consult with DLCD and other members of
the State Interagency Hazard Mitigation Team, as well as local planning and mitigation
staff, to incorporate strategies that lessen the loss of life, property, economic, and
natural resources that face the risks identified through State and local planning efforts.

Through its application and cost evaluation processes described in program guidelines,
OHCS will ensure that all mitigation efforts have a reasonable cost relative to other
alternatives. The documentation will include the cost of the mitigation strategy and a
description and documentation of cost reasonableness.

3.5.6 Broadband Infrastructure in Housing

Any substantial rehabilitation, as defined by 24 CFR 5.100, reconstruction, or new
construction of a building with more than four rental units funded with CDBG-DR
assistance must include the installation of broadband infrastructure, except when OHCS
determines and documents that:

• The location of the new construction or substantial rehabilitation makes the

installation of broadband infrastructure infeasible,
• The cost of installing broadband infrastructure would result in a fundamental
alteration in the nature of its program or activity, or in an undue financial burden, or
• The structure of the housing to be substantially rehabilitated makes the installation of
broadband infrastructure infeasible.

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3.5.7 Cost-Effectiveness
The State will establish policies and procedures to assess the cost-effectiveness of each
proposed program or activity to assist a household under any residential rehabilitation
or reconstruction program or activity funded with CDBG-DR funds. Policies and
procedures also will establish the criteria for determining when the cost of the
rehabilitation or reconstruction of the unit will not be cost-effective relative to other
means of assisting the property owner.

OHCS will define “demonstrable hardship” in its policies and procedures before carrying
out activities that may be subject to the one-for-one replacement housing
requirements.

OHCS defines a residential property as “not suitable for rehabilitation” if any of these
conditions apply:

• The property is declared a total loss.

• Repairs would exceed 50% of the cost of reconstruction.
• Repairs exceed $50,000.
• Homes cannot be rehabilitated or reconstructed in place under existing agency
policies and award caps due to legal, engineering, or environmental constraints,
such as permitting, extraordinary site conditions, or historic preservation.
The State may provide exceptions to award maximums on a case-by-case basis and
will include procedures within program guidelines on how the State or its subrecipients
will analyze the circumstances under which an exception is needed, and the amount
of assistance necessary and reasonable.

3.5.8 Duplication of Benefits

Section 312 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act,
as amended, generally prohibits any person, business concern, or other entity from
receiving financial assistance with respect to any part of a loss resulting from a major
disaster for which such person, business concern, or other entity has received financial
assistance under any other program or from insurance or any other source.

To comply with Section 312, OHCS shall ensure that each program and activity provides
assistance to a person or entity only to the extent that the person or entity has a disaster
recovery need that has not been fully met.

OHCS and its subrecipients are subject to the requirements in Federal Register notices
explaining the duplication of benefit requirement (84 FR 28836 and 84 FR 28848,
published June 20, 2019, or other applicable notices).

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4. Grantee Proposed Use of Funds
4.1 Overview
OHCS is the lead agency and responsible entity for administering $422,286,000 in CDBG-
DR funds allocated for disaster recovery. OHCS will implement these programs directly
and/or in partnership with subrecipients. These programs include the following:

Housing
• Homeowner Assistance and Reconstruction Program and Accessory Dwelling Unit
Pilot Program
• Homeownership Opportunities Program
• Intermediate Housing Assistance

Infrastructure
• Disaster Resilience Infrastructure Program

Public Services
• Housing and Recovery Services
• Legal Services

Planning and Administration

• Community Planning and Revitalization Program
• Administrative Costs

4.2 Program Budget

HUD-Identified Percentage Maximum National Estimated
Program Budget MID Budget of Allocation Award Objective Outcome
Homeowner $204,597,567 $202,551,591 48% Based on Low- and
Assistance and Program Moderate-
Reconstruction Standards Income
Program and
Urgent
Need
Homeownership
Housing

$119,348,581 $118,155,095 28% Based on Low- and

Opportunities Underwriting Moderate-
Program and Program Income
Standards and
Urgent
Need
Intermediate $17,049,797 $16,879,299 4% Various Low- and
Housing Assistance Moderate-
Income

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 HUD-Identified Percentage Maximum National Estimated
Program Budget MID Budget of Allocation Award Objective Outcome
Disaster Resilience $40,117,170 $39,715,998 10% Based on Low- and
Infrastructure

Infrastructure Program Moderate-

Program Standards Income
and
Urgent
Need
Housing and $6,017,576 $5,957,400 1.5% N/A Low- and
Recovery Services Moderate-
Income
and
Public Services

Urgent
Need
Legal Services $6,017,575 $5,957,399 1.5% N/A Low- and
Moderate-
Income
and
Urgent
Need
Community $8,023,434 $7,943,200 2% Based on N/A
Planning and Program
Planning

Revitalization Standards
Program

Administrative $21,114,300 $20,903,157 5% Based on N/A

Administration

Costs need

Total $422,286,000 $418,063,140 100%

4.3 Connection to Unmet Needs

As required by the Federal Register, Vol. 87, No. 23, February 3, 2022, OHCS (87 FR 6364),
OHCS will allocate at least 80% of the funds to address unmet needs within HUD-
identified “most impacted and distressed” (MID)areas. These include Clackamas,
Douglas, Jackson, Lane, Lincoln, Linn, and Marion counties.

The remaining 20% of the allocation may be used to address unmet needs which are in
areas that received a DR-4562 presidentially declared disaster declaration. At this time,
the State is limiting the grantee-identified MID areas to Klamath County and aniticipates
that the majority of the remaining 20% will address unmet needs in the HUD-identified
MID areas.

This Action Plan primarily considers and addresses housing and infrastructure unmet
recovery and mitigation needs, along with public services and planning that support
housing, infrastructure, and economic revitalization unmet needs.

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The Federal Register notice also requires that at least 70% of all program funds benefit
LMI persons or households. Most of the programs included in the Action Plan include a
prioritization for LMI households and individuals; the State anticipates meeting this
requirement. The State will closely monitor the impact of State programs and CDBG-DR
programs on impacted LMI persons, including vulnerable populations, protected
classes, and members of underserved communities. The State also will assess the eligible
unmet needs of LMI and non-LMI persons after all federal, State, and insurance
proceeds are considered and may determine whether to request a modification of the
requirement through a waiver.

4.4 Leveraging Funds

As a component of this Action Plan, OHCS has coordinated across federal, State, and
local organizations to gather information about other resources available for recovering
from the 2020 Wildfires. This included data collection on FEMA awards, SBA programs,
insurance claims, and the significant funding made available by the State of Oregon.
The activities identified in this plan were specifically selected as both eligible CDBG-DR
activities and filling a gap that other funding sources could not fill. Utilizing CDBG-DR
funding for the most significant eligible needs will leverage other funding sources to
invest in varied areas of recovery. It is necessary for OHCS to be knowledgeable about
other funding programs to maximize the impact of CDBG-DR funding and ensure
compliance with duplication of benefits requirements. Through this compliance, there
will be an ongoing effort to identify additional federal, State, and local funding sources
while also coordinating with partners such as nonprofits, corporations, foundations, and
other stakeholders to maximize leveraging opportunities.

OHCS is committed to using CDBG-DR funds to address critical unmet needs that
remain following the infusion of funding from other funding sources detailed below.
Existing State resources and other funds from the disaster appropriation will be further
examined to ensure that all available and viable funding is utilized where it is most
needed and will be leveraged appropriately. OHCS will draw on existing relationships
with other agencies, as well as create new partnerships and data-sharing agreements
to ensure that there is no duplication of benefits and that all viable resources of funding
are leveraged.

4.4.1 State Funding

After the 2020 Wildfires, the State legislature moved quickly to pass legislation and
provide State funds to assist wildfire-impacted Oregonians. In October 2020, the State
Emergency Board approved more than $390 million for wildfire recovery and

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emergency shelters, 82 and in July 2021, the Oregon legislature passed House Bill (HB)
5006, which allocated $486 million to support wildfire recovery. 83

HB 5006 provides funding for various initiatives focused on housing; racial justice;
wildfires; water; utilities; education; capital improvements; seismic mitigation and
recovery; broadband; policy; and support of local, tribal, and non-State projects. 84

4.4.4.1 State Housing Funding

Through this funding, the State of Oregon has been increasing its capacity to respond
to the needs of impacted residents and communities, with a particular emphasis on
vulnerable populations. Some of the key housing initiatives that are being carried out by
State agencies are listed in the table below. These agencies collaborate internally and
across agencies on a regular basis to ensure that funding is leveraged and
administered equitably.

Table 68: Funding Allocated by the Oregon State Legislature for Long-Term Residential
Wildfire Recovery in House Bill 5006
Agency Initiative Funding
Oregon Department of Financial Assistance for Septic System $15,000,000
Environmental Quality Repair/Replacement
Oregon Department of Feed and Shelter Wildfire Survivors $76,488,018
Human Services
Oregon Department of Grant Program to Incentivize Energy- $10,831,296
Energy Efficient Rebuilding from the 2020
Wildfires
Oregon Housing and Wildfire Recovery for Affordable Housing $150,163,567
Community Services Development, Manufactured Home
Replacement, and Flexible Assistance
Oregon Department of Fire Hardening Grants for Wildfire $10,678,004
Consumer and Business Rebuilds
Services

With the $150 million that OHCS manages from HB 5006, the agency has implemented
several disaster recovery programs and will leverage the successes from these State
programs into their management of the CDBG-DR activities identified in this Action Plan.
OHCS is currently managing the Wildfire Recovery and Resilience Account, making
$25 million available for survivor resources, including temporary and permanent housing
solutions. In addition, the State has invested in land acquisition in order to be well

82 Oregon State Legislature, Wildfire Recovery and Emergency Shelters.

83 House Interim Special Committee on Wildfire Recovery, Funding Distribution.
84 Oregon State Legislature, HB 5006, Emergency Board Work Session Recommendations.

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positioned for future housing development, motel conversion projects to increase
available housing, bulk purchase of new modular homes, and the coordination of
manufactured home replacement. These State programs have initiated the housing
recovery efforts, which the CDBG-DR funds will leverage and expand on.

In addition to leveraging the funding from these programs, the programs from the
Oregon Department of Energy and the Oregon Department of Consumer and Business
Services support state-of-the-art building practices related to energy efficiency and fire
hardening. OHCS is committed to resilient construction practices in all activities funded
through CDBG-DR. The goal of this resilient reconstruction is not only to protect
resources from future disaster damage but to also set the bar for future development in
the State of Oregon. By utilizing CDBG-DR funding for model housing development,
including by drawing on best practices from other Oregon programs, these funds will
leverage increased building quality for future housing developments long after this
recovery effort.

The State’s 2022 Notice of Funding Availability (NOFA) for housing tax credits and State
and federal programs made additional funds available for the development,
rehabilitation, and preservation of affordable housing in disaster-impacted
communities. Some of the programs and funding that are already underway are
summarized in the table below.

Table 69: OHCS Program Disaster Set-Asides

Program (Pool) Funding Sources and Amounts

Wildfire Set-Asides Within OHCS Programs $85.35 million, OAHTC**
• Local Innovation Fast Track (LIFT) Rental
($50 million)
• LIFT Homeownership ($15.35 million)
• General Housing Account Program
($20 million)
Oregon Affordable Housing Tax Credits $200 million
(OAHTC) – Wildfire
Disaster Low-Income Housing Tax Credits $6.3 million
Permanent Supportive Housing* $10 million for preservation, OAHTC**
Affordable Rental Housing Preservation $20 million for preservation, OAHTC**
Manufactured Dwelling Park Preservation $25 million, OAHTC**
* For housing acquisition cost only. Must be a property included in the statewide Inventory.
** Up to 95% of the permanent loan amount. 85

85OHCS, NOFA FAQs, March 4, 2022,

https://www.oregon.gov/ohcs/development/Documents/nofa/2022/FAQ5-2022-NOFAS-03-04.pdf.

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As of the time of publication of the initial Action Plan, the Oregon legislature has
appropriated $71.5 million to address the needs of those experiencing or at risk of
experiencing homelessness in communities impacted by the 2020 Wildfires. OHCS, in
addition to these funds, has made $3 million in homelessness services assistance funding
available to the Oregon Department of Human Services to assist individuals
experiencing homelessness who were adversely impacted by the 2020 Wildfires.
Additional details are in the table below.

Table 70: State Resources Allocated to Address Homelessness In Wildfire-Impacted

Areas
Wildfires – Source Amount
of Funding of Funding Purpose of Funding
$30 million Supports shelter services through the conversion of
hotel and motel properties into safe and warm
October 2020 shelter spaces. Provides funding for 500 units in
Legislative wildfire-affected areas.
Emergency Board
$10 million Shelter support with funding priorities for wildfire-
affected communities.
December 2020 $31.5 million Shelter, food, and wraparound services to
Legislative Oregonians impacted by wildfires.
Emergency Board
OHCS $3 million Assistance and services to individuals experiencing
homelessness who were adversely impacted by the
2020 Wildfires.
TOTAL $74.5 million

Due to the significant funding invested through the Oregon legislature and the
significant funding the State received from the federal government to help address
homelessness shelter and support needs, the State has not budgeted CDBG-DR funding
directly for expanding sheltering sites. However, CDBG-DR assistance has been
budgeted to provide housing counseling, wraparound services, and temporary rental
assistance for displaced households experiencing homelessness or at risk of
experiencing homelessness as a result of the wildfires.

4.4.4.2 State Infrastructure Funding

Through HB 5006 and Emergency Legislative Board approvals, the State appropriated
and allocated additional infrastructure funding to help address those unmet needs not
covered by FEMA PA or HMGP or other federal funding sources. A summary of those
funds is included below.

Table 71: State Resources Allocated to Address Additional Infrastructure Recovery

Needs

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 Wildfires – Source
of Funding Amount of Funding Purpose of Funding
$108,825,000 Water and Wastewater Infrastructure
HB 5006 – State $20,000,000 HMGP Match
Funding and
American Rescue $3,266,000 Municipal Wildfire Assistance Program (local
planning capacity)
Plan Act
$19,874,000 Fire and Public Safety
TOTAL $151,965,000

In addition to these allocations, the State has appropriated more than $35 million to
help local governments with increasing staffing capacity and revenue loss replacement
(e.g., loss of revenue due to waivers of permit review fees for wildfire reconstruction).

4.4.4.3 State Economic Revitalization Funding

Through HB 5006, the State legislature appropriated $10 million for a main street
revitalization program for the wildfire-impacted communities.

4.4.2 Federal Assistance and Private Insurance

Additional funding sources that are important to document for the purposes of
leveraging disaster recovery funds and ensuring duplication of benefits compliance
include FEMA, SBA, and private insurance. Data specific to these sources were
provided above in the unmet needs assessments. Summary information is provided here
to document OHCS’s research as it relates to leveraging available funding sources.

Table 72: FEMA Resources Available for DR-4562 Recovery and Mitigation
Approved Awards and/or
FEMA Program Assistance from FEMA Total Approved Applications
Individual Assistance (IA) $38,774,394 3,251
Public Assistance (PA) $457,321,493 Project assessments ongoing
Hazard Mitigation Grant $97,576,243 Project assessments ongoing
Program (HMGP)

Table 73: SBA Resources Available for DR-4562 Recovery

SBA Loan Type Loan Amount Issued
Residential Loans Approved $19,432,309
Residential Loans Executed and Awarded $1,993,800
Business Loans Executed $1,993,800

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Table 74: Private Insurance for Structural and Personal Property Damages
Total Loss Claims
(Destroyed home Case Incurred Losses
Private Insurance Type and qualified (Total anticipated
of Coverage for policy limit) Total Paid Losses replacement costs)
Residential 2,792 $1,000,274,510 $1,089,904,743
80% of Residential 2,792 $800,219,608 $871,923,794
(assumed for structural
payouts)*
Commercial 1,331 $114,163,353 $359,578,648
* Due to the nature of the insurance data call and the knowledge that many insurance
providers have included personal property claims (including a significant number of cars and
vehicles) and losses within their policies, the State is assuming for this Action Plan that 80% of the
value of the residential insurance losses and incurred losses are for structural damages. The State
will use the 80% figure for its unmet needs assessment. The State will update this figure as it
receives additional information on insurance claims and payouts through program intake.

4.4.3 Total Unmet Needs After Leveraging Other Funding

The table below reflects the State’s current projected unmet need after subtracting
these resources from the calculation of need in the Unmet Needs Assessment and Data
and Methodology.

Table 75: Oregon 2020 Wildfires Unmet Needs Calculation

Unmet Need
(Total Impact
Resources less Applied
Category Data Source Total Impact Available Resources) % of Total
Housing Estimated $1,318.697M $1,126.953M $241.758M 55%
Reconstruction or
Replacement of
Damaged Housing Units
Infrastructure FEMA Public Assistance $130.533M $102.156M $28.377M 6%
(Categories C–G + 15%
resilience)
FEMA Hazard Mitigation $129.188M $136.269M ($7.081M) (2%)
Grant Program
Additional Resilient $281.965M $131.965M $150M 34%
Infrastructure Needs
Economic SBA – Commercial Loss $32.089M $1.994M $29.974M 7%
Revitalization
Additional Commercial Assessment $124.378M
Losses – Line item not still
included in the underway
calculation
TOTAL $1,892.47M $1,499.34M $443.03M 100%

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4.5 Program Partners
OHCS may engage program partners through formal agreements such as subrecipient
agreements and interagency agreements and through informal partnerships. It is
critical for OHCS to engage a spectrum of program partners so that programs are more
accessible, understandable, and tailored to equitably meet the unmet needs of
disaster-impacted residents and communities.

When engaging in formal agreements for the administration or implementation of

programs, OHCS will ensure that subrecipients have the capacity and expertise to carry
out the program activities included in their scope of work. OHCS may help expand
subrecipient capacity and will provide technical assistance and training to
subrecipients on program requirements, applicable federal cross-cutting requirements
and State overlays, and reporting and performance requirements, and may allocate
administrative funding, as appropriate, to do so.

The program descriptions include the types of subrecipients or interagency partnerships

that may support OHCS in the administration or implementation of specific programs.

4.6 Distribution of Funds

OHCS relied on the information collected through the unmet recovery and mitigation
needs assessment, to include qualitative and quantitative data received through the
public and stakeholder engagement and consultation carried out prior to program
development, including the Governor’s Wildfire Economic Recovery Council and the
Oregon Disaster Housing Task Force.

Using this information, the State has prioritized programs that will assist in meeting the
short- and long-term recovery needs of its residents and communities. In addition, each
program will help the State meet its pillars, or guiding principles, of recovery:

• Advancing equity and racial justice and supporting underserved communities.

• Rebuilding homes and communities so that they are more resilient to current and
future hazards.

4.6.1 Additional Details in the Program Descriptions

Program descriptions in the Action Plan include a section on the method of distribution
for that program. Programs may be administered directly by OHCS through
subrecipients, or through a hybrid model where OHCS is the program administrator but
assigns specific scopes of work to subrecipients to support OHCS in the administration of
the program.

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Each program section includes the following information:

• Program description
• How the program promotes equity in recovery and housing for vulnerable
populations
• How the program will advance long-term resilience
• Program’s national objectives
• Program eligibility
• Program-eligible activities and maximum assistance
• Connection to disaster and unmet needs
• How the program addresses disaster-impacted systems, if applicable
• Program’s affordability period, if applicable
• Program’s maximum assistance
• Program’s definition of “second home,” if applicable
• Program’s responsible entity
• Program’s method of distribution
• Program’s competitive application process, if applicable
• Program’s estimated beginning and ending dates

The programs established in this Action Plan are not entitlement programs and are
subject to available funding.

4.7 Program Income

The State understands that certain activities funded with CDBG-DR funds could result in
the generation of program income. OHCS shall develop and adopt specific policies
and procedures for each program that generate program income and will specify in
those policies whether program income may be retained by local governments,
if applicable. Up to 5% of the program income generated by CDBG-DR funds may be
used for administrative costs by OHCS, units of local government, or other subrecipients.

Unless otherwise specified, all program income shall be remitted to the State. OHCS
shall treat program income as additional CDBG-DR funds subject to the requirements of
the Consolidated Notice and shall use it in accordance with the State’s CDBG-DR
Action Plan.

To the maximum extent feasible, program income shall be used or distributed before
additional withdrawals from the U.S. Department of the Treasury are made.

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4.8 Resale or Recapture
Resale or recapture requirements will vary by program and may not be applicable to
all CDBG-DR programs. If applicable, the resale or recapture requirements are
described within each of the program sections below and program guidelines will
provide additional details on the terms of resale or recapture and the specific
circumstances under which resale or recapture will be used.

OHCS will ensure that affordability restrictions are enforceable and imposed by
recorded deed restrictions, covenants, property liens, bylaws, or other similar
mechanisms.

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5. Program Details
5.1 Housing
5.1.1 Connection to Unmet Needs
As described under the Leveraging Funds section, the State has invested significant
resources into addressing unmet wildfire housing recovery needs. Other federal and
private insurance resources have been available to some of Oregon’s impacted
residents. However, these funds are insufficient to meet the State’s housing recovery
needs. Following an analysis of relative unmet need across single-family, multifamily,
owner, and rental housing, the State has determined that the greatest gaps in housing
recovery at the time of the initial Action Plan are in the following areas:

• The reconstruction or replacement of damaged housing with more energy-efficient,

disaster-resilient, and physically accessible single-family owner-occupied damaged
housing, particularly for those who are LMI, under- or uninsured, and have not been
able to complete their recovery.
• The need for affordable housing that is more energy-efficient, disaster-resilient,
and physically accessible, which can be built in a manner that overcomes the
current constraints on available land, urban growth boundaries, and the risks from
natural hazards and the impacts of climate change.
• The need for stable and affordable homeownership opportunities for disaster-
impacted LMI renters to help households move into more energy-efficient, disaster-
resilient, and physically accessible housing; offset rising rents and property sales
prices in the disaster-impacted communities; and increase wealth-building
opportunities.
• The need for rental and intermediate housing support while disaster-impacted
residents complete their permanent recovery plan.
• The need for targeted housing navigation support, including access to legal
services, affirmative and culturally specific outreach and engagement, financial
and homebuyer counseling, and accessible program design for advancing equity
and racial justice through recovery programs.
It is well documented that housing policies86 and disaster recovery87 across the United
States have often favored and disproportionately assisted white and wealthier
American citizens and homeowners. The State of Oregon aims to lead an equitable
recovery from the 2020 Wildfires, which will require an intentional examination of

https://www.npr.org/2017/05/03/526655831/a-forgotten-history-of-how-the-u-s-government-segregated-
86

america; https://www.vox.com/22252625/america-racist-housing-rules-how-to-fix.
87https://www.nytimes.com/2021/06/07/climate/FEMA-race-climate.html;
https://www.facingsouth.org/2018/09/recent-disasters-reveal-racial-discrimination-fema-aid-process.

138
systemic policies and practices that, even if they appear to be fair, may marginalize
some populations and perpetuate disparities.

Through this process, the State will target CDBG-DR support and assistance to ensure
that programs meet the needs of:

• Federally protected class groups, which include race, color, national origin, religion,
sex (including gender identity and sexual orientation), familial status, and disability.
• Underserved communities, which HUD defines as populations sharing a particular
characteristic, as well as geographic communities, which have been systematically
denied a full opportunity to participate in aspects of economic, social, and civic life.
• Vulnerable populations, which HUD defines as a group or community whose
circumstances present barriers to obtaining or understanding information or
accessing resources.
CDBG-DR funds are subject to the Fair Housing Act, which prohibits discrimination
because of race, color, national origin, religion, sex (including gender, gender identity,
sexual orientation, and sexual harassment), familial status, and disability. Other federal
civil rights laws, including Title VI of the Civil Rights Act, Section 504 of the Rehabilitation
Act, and the Americans with Disabilities Act, prohibit discrimination in housing and
community development programs and activities. These civil rights laws include
obligations such as taking reasonable steps to ensure meaningful access to programs
and activities for persons with LEP and taking appropriate steps to effectively
communicate with individuals with disabilities by providing auxiliary aids and services.

5.1.2 Homeowner Assistance and Reconstruction Program

Table 76: Homeowner Assistance and Reconstruction Program Budget
Proposed
HUD-Identified Proposed Grantee
Program Budget MID Budget MID Budget
Homeowner Assistance $204,597,567 99% 1%
and Reconstruction
Program (TOTAL)
Homeowner Assistance $200,597,567 99% 1%
and Reconstruction
Program
Accessory Dwelling Unit $4,000,000 99% 1%
Pilot Program

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5.1.2.1 Program Description
5.1.2.1.1 Homeowner Assistance and Reconstruction Program
The Homeowner Assistance and Reconstruction Program will provide assistance in the
form of grants to eligible homeowners who experienced damage to their homes from
the 2020 Wildfires and have remaining recovery needs after accounting for other
duplicative benefits received.

The program will fund eligible rehabilitation, reconstruction, acquisition, and

replacement costs, including additional costs to comply with federal, State, and local
construction standards, such as replacing on-site residential infrastructure, complying
with green building standards, and ensuring that homes are accessible for individuals
living with disabilities and senior residents. Eligible costs also include elevation, fire
hardening, and other program-required mitigation costs that will help protect homes
from natural hazards faced in the fire-impacted communities.

Participants whose properties are located in an SFHA or a 100-year floodplain, and who
receive assistance for new construction, reconstruction, rehabilitation of substantial
damage, or rehabilitation that results in substantial improvement, as defined at 24 CFR
55.2(b)(10), must be elevated with the lowest floor, including the basement, at least 2
feet above the 1% annual chance floodplain elevation (base flood elevation).

5.1.2.1.2 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
The program is designed to prioritize homeowners who continue to face recovery
barriers because they have not had access to the resources, support services, and/or
capacity to complete their recovery.

The State will achieve this through the following approaches:

• Implementing a phased approach to applicant processing. The program is designed

to prioritize those individuals and households who have struggled to access the
necessary resources to initiate or complete their recovery. By prioritizing LMI
households first, the State can ensure that those survivors with the fewest resources
are able to initiate their recovery. This approach represents a direct application of
OHCS’s Targeted Universalism policy. Data show that many of the LMI residents
struggling to complete their recovery are Latino/a/x, black, indigenous, and people
of color. OHCS will leverage data analysis and engagement through OHCS’s Equity
Lab, culturally-specific organizations, and local engagement to identify barriers that
are disproportionately impacting federally protected classes, underserved
communities, and vulnerable populations. Drawing from this analysis, OHCS will
target resources and recovery strategies to help overcome recovery barriers
experienced by different groups. In future phases, subject to funding availability, the

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 State may expand the program to help higher income households address their
remaining unmet recovery needs.

Table 77: Application Phases

Application Phases Phase I Phase II Phase III

At or below 80% of X
the AMI
At or below 120% of X
Household Income
the AMI
Greater than 120% X
of the AMI
Status of Repairs Incomplete X X X

• Partnering with local and tribal governments, long-term recovery groups, culturally
specific and community-based organizations, community action agencies, disaster
case management, and other organizations. Through these subrecipient
agreements and partnerships, the State will carry out targeted outreach and
engagement to individuals and communities with LEP, members of protected
classes, vulnerable populations, and individuals from underserved communities. The
State will work with these organizations to ensure that program materials are
accessible and understandable to all applicants and that program intake and
application processes are accommodating and provided in a manner that
accounts for culturally specific needs. The State may engage organizations to help
with applicant intake and provide support through the application process. This will
provide applicants with options for obtaining support from a trusted support
network, which is intended to address potential accessibility challenges for
impacted residents who have not yet participated in State or federal recovery
programs.
• Funding public service providers who will provide additional support to applicants
through housing and financial counseling and legal services. These programs are
described further below. The programs will fund community organizations that
provide comprehensive housing navigation, counseling, and legal services to help
disaster survivors overcome barriers to accessing recovery resources and sustain
affordable housing beyond the life of the CDBG-DR assistance.
• Directly managing the construction process on behalf of applicants and/or
providing construction advisory services to applicants. To help safeguard applicants
from contractor fraud, price gouging, construction delays, and the time-consuming
requirements of managing the housing recovery process, the State will either
manage the recovery on behalf of applicants or will provide construction advisory
services to applicants as they complete their recovery.

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5.1.2.1.3 How the Program Promotes Long-Term Resilience
The program will help the State replace damaged or destroyed housing with housing
stock that is more energy-efficient, resilient to the hazards in the impacted-communities
(including flood, wildfire, earthquake, extreme heat/winter, drought, and other
applicable high-risk hazards based on location of the housing), and the projected
impacts of climate change. In addition, the replacement housing will be built to
accessibility and visitability standards that will allow impacted residents to age in place
and increase the housing stock available to individuals living with disabilities.

By building to higher energy efficiency, resilience, and more accommodating

construction standards, the State aims to help mitigate future loss of life and property
and reduce short- and long-term interruptions caused by future disasters.

5.1.2.1.4 Accessory Dwelling Unit Pilot Program

Within the Homeowner Assistance and Reconstruction Program, the State will set aside
$4,000,000 for an Accessory Dwelling Unit Pilot Program for applicants eligible under
Phase 1 and future phases of the Homeowner Assistance and Reconstruction Program,
subject to funding availability.

Accessory dwelling units (ADUs) are independent residential dwelling units located on
the same lot as a stand-alone single-family home. ADUs can be additions to existing or
reconstructed homes (“internal” or “attached” ADUs) or new stand-alone accessory
structures or converted portions of existing stand-alone accessory structures
(“detached” ADUs).

Internal, attached, and detached ADUs are a cost-effective way for the State to help
impacted residents and communities replenish damaged rental housing stock and will
achieve the following:

• Help increase housing affordability for wildfire-impacted and LMI tenants.

• Prioritize income-generating opportunities for LMI homeowners. OHCS’s investment
in this program, coupled with targeted support provided through Housing and
Recovery Services will help individuals who have been unable to benefit from
wealth-building opportunities due to historic discrimation and systemic inequalities.
• Create infill housing.
• Reduce the displacement of wildfire survivors.
• Enhance neighborhood resilience.
The award will be structured as a partially forgivable loan:

• The forgivable portion of the loan is tied to the property owner meeting the terms of
compliance, which include maintaining the property as affordable to an income-

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 eligible tenant (household at or below 80% AMI, adjusted for household size) for a
minimum of 8 years. The forgivable portion of the loan is subject to recapture in
accordance with the receding percentages included in the program guidelines
and recorded loan.
• The repayable portion of the loan will be a low-interest loan amortized over a period
of 20 to 30 years. If the property is sold prior to full repayment, the balance of the
repayable portion will be due upon sale.
• The lien, resale, and recapture requirements will be recorded on the property as a
deed restriction or covenant.
The ADU pilot program will be offered on a first-come, first-served basis to approved
Homeowner Assistance and Reconstruction Program participants who meet the
following criteria:

• Ability of the applicant to take on additional debt and/or to complete the project.
This includes, but may not be limited to:
– Approval from first mortgage holders allowing for subordinate debt.
– Analysis of local zoning and requirements and whether they allow for the
development of ADUs for long-term rental and residence.
– Necessary approvals from all property owners to allow for the program to record
additional debt and deed restrictions on the property.
• Demonstrated financial feasibility and commitment to maintain the ADU as an
affordable rental property to LMI individuals or households for a minimum of 8 years.
The program will publish the definition of affordable rents within program guidelines.
– Property owners must also agree to provide priority access to wildfire survivors for
a period of time that will be defined in program guidelines. The term of wildfire
priority may be subject to the recovery status of the community at the time the
property is ready to be occupied.
– Property owners must agree to participate in program-provided counseling on
Fair Housing Act laws and affordable small rental property financial
management and compliance requirements prior to receiving final approval for
ADU assistance.
– Property owners may choose to use rental revenues to hire property managers to
help in the management of the property per the program terms.
• Feasibility and cost reasonableness analysis of developing the ADU based on the
property site layout. The program may allow for internal, detached, or attached
ADUs.

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5.1.2.2 Program’s National Objective(s)
Assistance provided under this program will meet the national objectives of benefiting
LMI persons or households or addressing an urgent need (Urgent Need).

The program may use the Urgent Need national objective to provide assistance to
eligible disaster-impacted applicants with incomes greater than 80% AMI.

5.1.2.3 Program Eligibility

Geographic Eligibility: FEMA IA-declared counties for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath

Eligible Applicants: To be eligible for the program, homeowners must meet the
following criteria:

• Must have been the owner-occupant of the damaged property at the time of the
disaster.
• The damaged property must have been the applicant’s primary residence at the
time of the disaster.
• The damaged property must have sustained damages as a result of the 2020
Wildfires.
• The damaged property must be an eligible structure as defined in the program
guidelines, including, but not limited to, single-family residences, manufactured
homes, pre-fabricated homes, and recreational vehicles.

5.1.2.4 Program-Eligible Activities and Maximum Assistance

Table 78: Homeowner Assistance and Reconstruction Program Eligible Activities

Rehabilitation, reconstruction, elevation, new construction, public

CDBG-DR facilities, and infrastructure in support of housing development,
Eligible acquisition, and clearance; HCDA Section 105(a)1, 2, 4, 5, 8, 11, and
Activities 14; applicable waivers identified in the Allocation Announcement
Notice and Consolidated Notice (87 FR 6364)

The program will provide the awards necessary to repair, reconstruct, or replace the
damaged property per program construction standards. Eligible costs also include
demolition and removal of the original structure.

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Additional funds may be provided to address site-specific accessibility needs (e.g.,
ramps and lifts), environmental issues, on-site residential infrastructure repairs or
replacement (e.g., septic tanks and wells), resilience and mitigation measures,
elevation requirements, installation and transportation costs, relocation costs, and
municipal ordinances, as needed. Cost reasonableness will be established using
national building standard estimating software, comparative and market analysis of
price per square foot, and/or the review of multiple construction bids.

Maximum assistance for single-family site-built residences: The specific award amount
is capped based on the size of the floorplan for which the applicant is eligible, less any
duplication of benefits (e.g., from private insurance, FEMA IA, the SBA, or other
duplicative sources).

If assistance is provided directly to homeowners who executed eligible contracts prior

to applying to the program, the maximum award will be determined by reviewing the
cost reasonableness methods described above.

Maximum assistance for owners of manufactured homes and recreational vehicles: The
specific award amount is capped based on the type of unit for which the applicant is
eligible, less any duplication of benefits (e.g., from private insurance, FEMA IA, the SBA,
or other duplicative sources).

If additional assistance is needed for site improvements or transportation, the maximum

award will be determined through the cost reasonableness methods described above.

5.1.2.5 Connection to Disaster and Unmet Needs

Assistance provided under this program is limited to applicants who experienced
verifiable damages from the 2020 Wildfires in the FEMA IA-declared counties. This
includes seven HUD-identified MIDs (Clackamas, Douglas, Jackson, Lane, Lincoln, Linn,
and Marion) and one grantee-identified MID (Klamath).

5.1.2.6 Program’s Affordability Period

For HARP:

The program’s affordability periods are not required for participants whose homes are
rebuilt or replaced on privately owned or leased land. No land restrictions, convents,
or liens will be placed on participating properties unless associated with the ADU pilot
program noted above.

Applicants who move into manufactured housing parks that are publicly subsidized or
owned by a resident cooperative, nonprofit, public housing authority, or similar
ownership structure may be subject to affordability periods and requirements included
in the covenants, tenant agreements, and/or bylaws of those parks. The State will work

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with these park owners and the applicants to ensure that the program applicants
understand the affordability requirements prior to moving into the park.

For the ADU Pilot Program:

• Affordability Period: Program participants must agree to maintain the property as

affordable to an income-eligible tenant (household at or below 80% AMI, adjusted
for household size) for a minimum of 8 years. The forgivable portion of the loan is
subject to recapture in accordance with the receding percentages included in the
program guidelines and recorded loan. The repayable portion of the loan will be a
low-interest loan amortized over a period of 20 to 30 years. If the property is sold
prior to full repayment, the balance of the repayable portion will be due upon sale.
The lien, resale, and recapture requirements will be recorded on the property as a
deed restriction or covenant.
• Affordable Rents: The State will allow property owners to charge either low or high
HOME/CDBG rent limits, adjusted for the number of rooms in the ADU. Whether the
property owner may charge low or high rent limits will be determined based on an
analysis of the cash flow on the property and the relative income levels in the
county in which the property is located. The rent charged should not exceed 30% of
an LMI household income.
5.1.2.7 Program’s Definition of “Second Home” and Eligibility
Per the requirements in the Consolidated Notice, properties that served as second
homes at the time of the disaster, or following the disaster, are not eligible for assistance
for rehabilitation, reconstruction, new construction, or replacement. A second home is
defined as a home that is not the primary residence of the owner, a tenant, or any
occupant at the time of the disaster or at the time of application for CDBG-DR
assistance.

5.1.2.8 Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

Program’s Method of Distribution Description and Overview

The State is the administering entity for the program but may engage subrecipients to
support applicants through outreach and engagement, editing and translating
program materials for readability, program intake and processing, and/or to provide
other related services that facilitate or expedite the application review process.

Homeowners will sign a grant agreement with the State prior to receiving assistance
from the program. As described in more detail in program policies and procedures,
the State will provide assistance to eligible homeowners through the following methods
of distribution:

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• Participants who have not yet started their recovery. The State will manage and
complete the acquisition, construction, or replacement of damaged homes on
behalf of homeowners who have not yet executed repair, reconstruction, and/or
acquisition contracts. The State will contract with vendors, dealers, and builders to
carry out the housing replacement activities. The State will require contractors to
provide program participants with a 1-year warranty on the construction or
replacement home.
• Participants who have started their recovery. If participants have executed
contracts at the time of application but have not yet completed their repairs,
reconstruction, or replacement and are unable to complete their recovery,
the State may provide direct gap assistance. In this scenario, homeowners may be
able to continue to manage their own contractors on all or a portion of the
remaining recovery needs, provided the contractors and scope of work meet
program requirements and the project meets environmental, asbestos, lead-based
paint review, and other applicable abatement and mitigation requirements. The
State will provide construction advisory and housing navigation services for all
homeowners who receive assistance directly from the program.
5.1.2.9 Program’s Competitive Application Overview
The program is not a competitive program; however, there will be program phases.
Providing funding beyond Phase 1 is subject to funding availability.

5.12.10 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the first quarter of 2023, after HUD
has approved the Public Action Plan.

The program will end when all eligible participants have completed closeout, all
budgeted funds have been expended, or 6 years after execution of the grant
agreement with HUD.

5.1.3 Homeownership Opportunities Program

Table 79: Homeownership Opportunities Program Budget
Proposed HUD-
Identified MID Proposed Grantee
Program Budget Budget MID Budget
Homeownership $119,348,581 99% 1%
Opportunities Program

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5.1.3.1 Program Description
Due to rising housing rental and homeownership costs, a lack of available housing, and
the relative disaster impacts to renters and damages to single-family housing, the State
will help replace destroyed housing stock with affordable homeownership opportunities
for disaster-impacted first-time homebuyers. The program will develop single-family site-
built or pre-fabricated structures—defined as one to four units—for the purposes of
selling to eligible disaster-impacted first-time homebuyers. Pre-fabricated (including
manufactured) homes may only be placed in manufactured housing parks that are
owned by a nonprofit, community land trust, public housing authority, or resident
cooperative and have a regulatory agreement in place to maintain affordability.

• The award to the homebuyer will be structured as a fully or partially forgivable, zero-
interest loan. The award amount and structure will be calculated based on the
applicant’s household income, other reasonably priced resources available to the
applicant for home purchase, and projected costs for maintaining the home and
housing costs (e.g., property taxes, homeowner and flood insurance, utilities).
• Buyers are not required to qualify for a first mortgage to be eligible for the program.
• The repayable portion of the loan will be amortized over a period that makes the
payments affordable for the homebuyer. If the property is sold prior to full
repayment, the balance of the repayable portion will be due upon sale.
• The forgivable portion of the loan is subject to recapture in accordance with the
receding percentages included in the program guidelines and recorded loan.
• The property will be maintained as affordable housing for the duration of a property
affordability period, which may be longer than the term of the loan to the
homebuyer. The resale requirements associated with the affordability period will be
recorded on the property either as a deed restriction, covenant, through bylaws
(if placed in an affordability-regulated manufactured housing park), and/or other
means. The program also may take a security interest on a manufactured home.

This program includes two levels of subsidy to build housing that is more affordable,
energy-efficient, and resilient in the face of future disasters:

• New Housing Production: The program will work with developers, manufactured
home dealers, and/or builders to incentivize development and supplement the cost
of developing housing per program construction standards.
• Homeownership Assistance: OHCS will support eligible participants directly by
providing additional homeownership assistance, as needed, to make the home
affordable.

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5.1.3.1.1 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
This program will replenish damaged housing stock with more energy-efficient, resilient,
accessible, and affordable homeownership opportunities for LMI first-time homebuyers.
Affordable homeownership is a critical component of any forward-thinking strategy
that seeks to address both housing and prosperity. In disaster-impacted communities
with a shortage of housing, a depletion of residents’ resources, and rising home prices,
fixed home payments insulate residents from displacement pressures. Homeownership
provides an avenue to build wealth and home equity that can support a household’s
other financial needs.

Across the income spectrum, communities of color have lower homeownership rates
than whites due to historical and ongoing discriminatory lending and disparate access
to home financing. Common barriers to homeownership include limited access to
capital because of low credit scores and/or credit “invisibility. 88” These barriers
disproportionately impact communities of color in Oregon. This approach represents a
direct application of OHCS’s Targeted Universalism policy, as OHCS aims to remove
barriers that facilitate homeownership opportunities for LMI and Latino/a/x, black,
indigenous, and people of color. OHCS will invest in partnerships with culturally specific
organizations to implement aspects of this program in order to meet this goal.

By providing low- to zero-interest flexible loans that are affordable and accessible to
low-income households, the State will expand opportunities for safe, accessible,
affordable, energy-efficient housing for disaster-impacted residents, including those
individuals and households who have been historically excluded from other housing
lending programs.

The program is designed to prioritize homebuyers who continue to face recovery

barriers. The State will achieve this through the following approaches:

• Implementing a phased approach to applicant processing. The program is designed

to prioritize those individuals and households who have struggled to access the
necessary resources to initiate or complete their recovery. By prioritizing LMI
households first, the State can ensure that those survivors with the fewest resources
are able to recover. In future phases, subject to funding availability, the State may
expand the program to help households with incomes up to 120% of the AMI.

88 https://www.consumerfinance.gov/about-us/blog/who-are-credit-invisible/

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Table 80: Homeownership Opportunities Program Phases

Application Phases Phase I Phase II

At or below 80% of the AMI X
Household Income
At or below 120% of the AMI X

• Partnering with local and tribal governments, long-term recovery groups, culturally
specific and community-based organizations, community action agencies, disaster
case management, and other organizations. Through these subrecipient
agreements and partnerships, the State will carry out targeted outreach and
engagement to individuals and communities with LEP, members of protected
classes, vulnerable populations, and individuals from underserved communities.
The State will work with these organizations to ensure that program materials are
accessible and understandable to all applicants and that program intake and
application processes are accommodating and provided in a manner that
accounts for culturally specific needs. The State may engage organizations to help
with applicant intake and provide support through the application process. This will
provide applicants with options for obtaining support from a trusted support
network, which is intended to address potential accessibility challenges for
impacted residents who have not yet participated in State or federal recovery
programs.
• Funding public service providers who will provide additional support to applicants
through housing and financial counseling and legal services. These programs are
described further below. The programs will fund community organizations that
provide comprehensive counseling and legal services to help disaster survivors
overcome barriers to accessing recovery resources and sustaining affordable
housing beyond the life of CDBG-DR assistance.
• Directly managing the construction process on behalf of applicants. To help
safeguard applicants from contractor fraud, price gouging, construction delays,
and the time-consuming requirements of managing the housing recovery process,
the State will either manage the construction process or will provide construction
advisory services to applicants as they complete their recovery.

5.1.3.1.2 How the Program Promotes Long-Term Resilience

The program will expand the availability of affordable housing stock that is more
energy-efficient and resilient to the hazards in the impacted-communities (including
flood, wildfire, earthquake, extreme heat/winter, drought, and other applicable
high-risk hazards) and the projected impacts of climate change. In addition, the
replacement housing will be built to accessibility and visitability standards that will allow
impacted residents to age in place and increase the housing stock available to
individuals living with disabilities.

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By building to higher energy efficiency, resilience, and more accommodating
construction standards, the State aims to help mitigate future loss of life and property
and reduce short- and long-term interruptions caused by future disasters.

5.1.3.2 Program’s National Objective(s)

Assistance provided under this program will meet the national objectives of benefiting
LMI persons or households or addressing an urgent need.

The program may use the Urgent Need national objective to provide assistance to
eligible disaster-impacted applicants with incomes greater than 80% AMI and up to
120% AMI.

5.1.3.3 Program Eligibility

Geographic Eligibility: FEMA IA-declared counties for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath

Eligible Applicants: To be eligible for the program, applicants must meet the following
criteria:

• Must have a household income at or below 120% of the AMI. This income limitation is
included in the Consolidated Notice from HUD.
• Must have experienced a verified residential loss as a result of the 2020 Wildfires.
• Must be a first-time homebuyer. A first-time homebuyer is an individual who meets
any one of the following criteria:
– An individual who has had no ownership in a principal residence during the 3-
year period ending on the date of purchase of the property. This may also
include a spouse.
– A single parent who has only owned with a former spouse while married.
– An individual who is displaced and has only owned with a spouse. A displaced
individual is someone whose marital status affects their ability to be properly
housed.
• Must agree to the affordability terms, which includes maintaining the property as
owner-occupants for a defined period (homebuyer affordability period) and
recording a deed restriction on the property to ensure that the property remains
affordable to income-eligible homeowners for a defined period in the event of
resale (property affordability period).

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• Must meet program underwriting requirements. The underwriting process will review
the applicant for such items as the applicant’s ability to afford the cost of
maintaining a home. It is not a requirement for applicants to qualify for a first
mortgage or other credit to access the program.

5.1.3.4 Program-Eligible Activities and Maximum Assistance

Table 81: Homeownership Opportunities Program Eligible Activities

Rehabilitation, reconstruction, elevation, new construction, acquisition,

CDBG-DR
clearance, and homeownership assistance; HCDA Section 105(a)1, 4, 5,
Eligible
8, 11, 14, 15, and 24; applicable waivers identified in the Allocation
Activities
Announcement Notice and Consolidated Notice (87 FR 6364)

Program guidelines will provide significant details on the eligible activities and award
calculation process. The State will perform a cost analysis for each property and
applicant, following the methods described below.

New Housing Production

The State will develop detailed construction standards and eligible costs around
complying with State and local building codes, accessibility standards, energy
efficiency, the grade of construction materials and finishes, structural and on-site
resilience improvements, and on-site preparations. Using these construction standards,
the State will competitively select developers, builders, and/or dealers to construct
or provide manufactured homes.

The subsidy to the entity building or providing the housing will be issued in the form of a
forgivable loan, which may be forgiven upon completion of the sale of the property to
an eligible homebuyer. The amount of subsidy provided will be based on an analysis of
the market, including the current costs of construction and labor, local demand for
construction resources, comparable sales in the area, and affordability calculations for
the intended homebuyers.

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Homeownership Assistance
• The award to the homebuyer will be structured as a fully or partially forgivable, zero-
interest loan.
• The award amount and structure will be calculated based on the applicant’s
household income, other reasonably priced resources available to the applicant for
home purchase, projected costs for maintaining the home, and housing costs (e.g.,
property taxes, homeowners insurance).
• Buyers are not required to qualify for a first mortgage to be eligible for the program.
• The forgivable portion of the loan is subject to recapture in accordance with the
receding percentages included in the program guidelines and recorded loan.
• The repayable portion of the loan will be amortized over a period that makes the
payments affordable to the homebuyer. The process for determining the amount an
applicant must repay will be designed to accommodate different applicant
circumstances. This will include procedures for analyzing the following:
– Sliding scales of percentages of what a household can pay toward housing costs
(based on income and/or household composition).
– Processes for overcoming credit barriers by allowing for alternative sources to
establish payment history.
– The projected long-term housing costs (e.g., pad/lot rent, homeowner insurance,
property taxes).
– The ability for the applicant household to access other reasonably affordable
capital, such as a market rate first mortgage loan, which can be applied toward
the acquisition of the property. It is not a requirement for applicants to qualify for
a first mortgage or chattel loan.
– The size and composition of the household, which will inform the size, layout, and
accessibility components of the home.
– Other relevant factors that may impact a household’s ability to access and/or
maintain the home for the period of affordability.
Through this analysis, the State will determine the portion of the loan that will be
forgivable over the duration of the affordability period. The State may forgive up to
100% of the loan. Program guidelines will include clear processes for analyzing the
amount of the loan that may be forgiven in order to best meet individual household
needs, while ensuring consistency and equity in the implementation of the program.

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5.1.3.5 Connection to Disaster and Unmet Needs
The program is limited to 2020 Wildfires-impacted individuals and households who were
renters or who meet the other definition of a first-time homebuyer described above.
Through this program, OHCS will help address impacted communities’ unmet
affordable housing recovery needs and help build long-term financial and disaster
resilience for impacted renters and first-time homebuyers.

5.1.3.6 Program’s Affordability Period

The Consolidated Notice requires a minimum affordability period for new construction
of single-family units for homeownership. The State anticipates investing significant
resources in the development of new housing through this program and, in return for this
investment, will build long-term affordability requirements into the property. However,
the State does not want to place an unreasonable affordability period on homebuyers.
Therefore, this program will have two sets of affordability periods, which may be
different depending on the amount of program assistance provided to the homebuyer:

• Property Resale Affordability Period

• Homebuyer Affordability Period

1.4.1.1.2 Property Resale Affordability Period

The property affordability period is tied to the amount of assistance provided for the
home, including any new housing production subsidy and homeownership assistance
provided to the applicant.

Table 82: Property Resale Affordability Period

Homeownership Assistance Amount

(including New Housing Production Subsidy) Property Period of Affordability (in years)
Less than $15,000 5
$15,000 to $40,000 10
$40,001 to $99,999 15
More than $100,000 50

Resale Requirements: The resale requirements will be recorded as a deed restriction or

covenant on the property (for prefabricated homes placed in affordability-regulated
manufactured housing parks, the resale restrictions will be outlined in the bylaws and/or
lease agreements). The restrictions will ensure that if the housing does not continue to
be the principal residence of the household for the duration of the property period of
affordability, the housing will be made available for subsequent purchase only to a
buyer whose household qualifies as an LMI household and will use the property as the
household’s primary residence.

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Within the program guidelines, loan agreement, and deed restriction or covenant,
the State will include language which ensures that the price at resale provides the
homebuyer with a fair return on investment and will ensure that the housing will remain
affordable to a reasonable range of low-income homebuyers. It also will include the
details on how it will make the housing affordable to a low-income homebuyer in the
event that the resale price necessary to provide fair return is not affordable to the
subsequent buyer.

When a home is placed in an eligible manufactured housing park, the State will work
with the park owner(s) and the homebuyer to ensure that the home and/or site is
preserved as affordable for the prescribed period of affordability through bylaws, lease
agreements, covenants, and/or other means that accommodate different affordable
park ownership structures (community land trusts, resident cooperatives, nonprofits, and
public housing authorities).

The State may work with local jurisdictions, nonprofits, community land trusts, housing
authorities, or resident cooperatives to manage the resale process and/or ensure that
the properties remain affordable for the duration of the affordability period.

5.1.3.6.2 Homebuyer Affordability Period

The affordability period on the property may be longer than the term of the loan
agreement(s) with the program’s participating homebuyer.

For forgivable loans, the homebuyer affordability period is tied to the amount of
assistance provided for the home, including the supplement to developers for housing
construction and any homeownership assistance provided to the applicant.

Table 83: Homebuyer Affordability Period

Homeownership Assistance Amount

(including New Housing Production Subsidy) Homebuyer Period of Affordability (in years)
Less than $15,000 5
$15,000 to $40,000 10
More than $40,000 15

Recapture Requirements: The award to the homebuyer will be structured as a receding

forgivable loan and is subject to recapture in accordance with the receding
percentages documented in the recorded loan. The loan amount due will be reduced
on a pro rata basis for the time the homebuyer has owned and occupied the housing
measured against the required homebuyer affordability period. For example, if the
homebuyer affordability period is 15 years, then 1/15th of the loan will be forgiven after

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every year of ownership and occupancy of the home as the primary residence by the
homebuyer.

5.1.3.7 Program’s Definition of “Second Home”

Per the requirements in the Consolidated Notice, properties that served as second
homes at the time of the disaster, or following the disaster, are not eligible for assistance
for rehabilitation, reconstruction, new construction, or replacement. A “second home”
is defined as a home that is not the primary residence of the owner, a tenant, or any
occupant at the time of the disaster or at the time of application for CDBG-DR
assistance.

The program will not fund second homes.

5.1.3.8 Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

5.1.3.9 Program’s Method of Distribution

OHCS may administer the program directly and/or may provide assistance to eligible
subrecipients to administer the program in a fiduciary capacity on behalf of OHCS
provided that they also meet any additional qualifications and monitoring and
administration requirements set forth in the program guidelines. Eligible subrecipients
include homeownership centers, community development financial institutions, public
housing authorities, and/or other qualified public or private nonprofit organizations.

Homebuyers will execute loan documents with the State or its subrecipient prior to
receiving assistance from the program.

5.1.3.10 Program’s Competitive Application Review

The program is not a competitive program; however, it is phased per the description
above.

5.1.3.11 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the first quarter of 2023, after HUD
has approved the Public Action Plan.

The program will end when all eligible participants have completed closeout, all
budgeted funds are expended, or 6 years after execution of the grant agreement with
HUD.

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5.1.4 Intermediate Housing Assistance
Table 84: Intermediate Housing Assistance Budget

Proposed
HUD-Identified Proposed Grantee
Program Budget MID Budget MID Budget
Intermediate Housing $17,049,797 99% 1%
Assistance

5.1.4.1 Program Description

This program provides assistance to 2020 Wildfire-impacted owners and renters who
lack the necessary resources or support networks to obtain affordable housing and
need alternative housing until permanent housing solutions are secured.

The State will provide grants to eligible subrecipients to provide:

• Up to 36 months of rental, temporary relocation, and/or other intermediate housing

assistance, pending a waiver approval from HUD.
• Housing navigation, case management, and support services to disaster-impacted
residents.

5.1.4.1.1 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
The program provides assistance to those individuals and households who are
experiencing homelessness, housing instability, or are at risk of experiencing
homelessness due to the lack of affordable intermediate housing options. The program
will be designed to ensure that Latino/a/x, black, indigenous, and people of color, and
other qualifying disaster survivors, who are unstably housed as a result of the disaster
can be housed temporarily until they may benefit from a permanent subsidized housing
recovery program. OHCS will invest in partnerships with culturally specific organizations
to ensure that Latino/a/x, black, indigenous, and people of color are able to contact
and work with a trusted source for this assistance.

5.1.4.1.2 How the Program Promotes Long-Term Resilience

The program helps at-risk disaster survivors have access to stable and affordable
housing while they work toward their long-term recovery. This intermediate assistance is
critical for helping residents preserve personal savings, retirement, and any other assets
needed to meet their permanent recovery plan and long-term financial resilience.
These resources also will help protect impacted residents from having to take on

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additional debt, including high-interest and predatory debt that increases the
vulnerability of survivors to current and future disasters and household disruptions.

5.1.4.2 Program’s National Objective(s)

Assistance provided under this program will meet the national objectives of benefiting
LMI persons or households or addressing an urgent need.

The program may use the Urgent Need national objective to provide assistance to
eligible disaster-impacted applicants with incomes greater than 80% AMI.

5.1.4.3 Program Eligibility

Geographic Eligibility: FEMA IA-declared counties for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath
Eligible Applicants: To be eligible for the program, applicants must meet the following
criteria:

• Households at or below 80% of the AMI must face housing instability and/or are
displaced in one of the HUD- or grantee-identified MIDs.
• Households between 80.1% to 120% of the AMI must have a verified residential loss
as a result of the 2020 Wildfires.
• Assistance may be provided, including for hotel payments, for households actively
participating in the Homeowner Assistance and Relocation Program or
Homeownership Opportunities Program who are unable to occupy their home
during construction activities.

5.1.4.4 Program-Eligible Activities and Maximum Assistance

Table 85: Intermediate Housing Assistance Eligible Activities

Interim housing assistance, rental assistance to displaced homeowners,

CDBG-DR
and relocation assistance, HCDA Section 105(a)1, 4, 8, and 15;
Eligible
applicable waivers identified in the Allocation Announcement Notice
Activities
and Consolidated Notice (87 FR 6364)

The State will provide grants to eligible subrecipients to provide:

• Up to 36 months of rental, temporary relocation, and/or other intermediate housing

assistance, pending a waiver approval from HUD.

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• Housing navigation, case management, and support services to disaster-impacted
residents.
The maximum amount of assistance an applicant may receive is described below.
All awards are subject to a duplication of benefits review.

• Rental Assistance: On a monthly basis, for up to 36 months (subject to waiver

approval) of rental payments. The amount calculated on a monthly basis will be the
lesser of:
– The actual cost of rent, or
– The maximum applicable HOME/CDBG fair market rents based on the household
size, and location.
• Temporary Relocation Assistance:
– The program will pay reasonable costs, including hotel payments, based on rate
schedules developed by OHCS. Wherever possible, OHCS will attempt to
negotiate lower or bulk rates for disaster survivors.
• Other intermediate housing assistance (e.g., utilities, security deposits):
– Limited to actual costs and a cost reasonableness review from the subrecipient.
– Refundable security deposits are limited to up to 3 months, subject to State laws
listed at https://oregon.public.law/statutes/ors_90.300.
– Moving costs per the General Services Administration schedule, to be paid up to
two times per participant (moving in, moving out).

5.1.4.5 Connection to Disaster and Unmet Needs

The program provides financial and supportive assistance to households displaced by
the 2020 Wildfires.

5.1.4.6 Program’s Affordability Period

Not applicable.

5.1.4.7 Program’s Definition of “Second Home”

Not applicable.

5.1.4.8 Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

5.1.4.9 Program’s Method of Distribution

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The State will administer this program directly or will make grants to subrecipients able to
deliver the program to disaster-impacted residents. The State will allocate funds based
on estimated unmet needs in the impacted communities, estimates from the
subrecipients on the number of participants they can serve, and/or subrecipient
capacity. Eligible subrecipients include, but are not necessarily limited to, the following:

• Community action agencies

• Culturally specific and community-based organizations (nonprofits)
• Long-term recovery groups (nonprofits)
• Local governments
• Local public housing authorities
• Other nonprofit, quasi-public, or public organizations

5.1.4.10 Program’s Competitive Application Review

Not applicable.

5.1.4.11 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the first quarter of 2023, after HUD
has approved the Public Action Plan.

The program will end when all funds have been expended and all eligible participants
have completed closeout.

5.2 Infrastructure
5.2.1 Disaster Resilience Infrastructure Program
Table 86: Disaster Resilience Infrastructure Program Budget
Proposed
HUD-Identified Proposed Grantee
Program Budget MID Budget MID Budget
Disaster Resilience $40,117,170 99% 1%
Infrastructure Program

5.2.1.1 Program Description

The Disaster Resilience Infrastructure Program is a competitive program that will provide
grant assistance for public infrastructure and public facility projects with unmet needs
that are related to:

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• New housing and/or replacement of damaged housing, and/or
• Mitigating the loss of life or property in the face of current and future natural
hazards.
The program may be implemented in multiple rounds.

5.2.1.1.1 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
The State will prioritize projects that provide the essential public infrastructure necessary
for housing and/or will protect life and property, including for members of protected
classes, HUD-identified vulnerable populations, and historically underserved
communities.

5.2.1.1.2 How the Program Promotes Long-Term Resilience

The State will prioritize projects that mitigate, eliminate, or reduce the loss of life or
property in the face of current and future natural hazards. Applicants will be required to
demonstrate how the projects will be operated and maintained beyond the life of the
CDBG-DR grant.

This program is designed to promote sound, sustainable long-term recovery and

projects that account for the unique hazards, opportunities, land use restrictions, urban
growth boundaries, underserved communities, and disaster impacts within Oregon’s
impacted communities. Applicants will be required to describe the data and/or
planning analysis they will use in their evaluation of hazard risk, including climate-related
natural hazards.

Subrecipients will be required to demonstrate how their projects clearly address the
following opportunities, as applicable:

• Increasing resilience to the impacts of climate change.

• Protecting public health.
• Conserving lands, waters, and biodiversity.
• Addressing environmental injustice.
• Spurring economic growth and creating jobs.

5.2.1.2 Program’s National Objective(s)

Assistance provided under this program will meet the national objectives of benefiting
LMI persons or households or addressing an urgent need.

The Urgent Need national objective will only be used when an LMI national objective
cannot be achieved through the project, but the project has demonstrable recovery or

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mitigation public infrastructure benefits within the HUD- or grantee- identified MID. Each
approved application will describe the urgency, type, scale, and location of the
disaster-related impact that will be addressed through the project.

5.2.1.3 Program Eligibility

Geographic Eligibility: Eligible entities located in one of the FEMA IA-declared counties
for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath

Eligible Applicants: Eligible applicants include, but are not limited to, the following:

• Tribal, State, county, and municipal governments, agencies, districts, and authorities
• Schools (K–12)
• Public housing authorities
• Other public or quasi-public entities
• Nonprofit entity with a specific public role described in an Oregon revised statute
(e.g., soil and water conservation districts)

5.2.1.4 Program-Eligible Activities and Maximum Assistance

Table 87: Disaster Resilience Infrastructure Program Eligible Activities

HCDA Section 105(a)1, 2, 4, 5, 7, 8, 9, 11, 12, 13, 14, 15, and 16;
CDBG-DR
applicable waivers identified in the Allocation Announcement Notice
Eligible
and Consolidated Notice (87 FR 6364) and other applicable notices or
Activities
guides

This program is designed to allow for a flexible range of eligible activities to help local
entities meet the public facilities and infrastructure recovery or mitigation needs of their
disaster-impacted communities. All infrastructure projects must clearly demonstrate
how they support:

• New housing and/or replacement of damaged housing, and/or

• Mitigating the loss of life or property in the face of current and future natural
hazards.
The maximum award is subject to a review of duplication of benefits and cost
reasonableness or cost-benefit analysis.

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Award maximums will be established in the program guidelines and in any public
announcement of funding availability.

5.2.1.5 Connection to Disaster and Unmet Needs

This program addresses unmet recovery and mitigation public infrastructure needs in
HUD-identified and grantee-identified MIDs, after deducting any duplication of benefits
from other federal, State, or private sources.

5.2.1.6 How the Program Will Address Disaster-Related Systems

As described in the Unmet Needs Assessment, there are many infrastructure needs
resulting from the 2020 Wildfires that were not covered by FEMA PA or HMGP, either due
to a lack of funding or because of the limitations placed by FEMA on what can be
replaced with Public Assistance funds.

These program funds must be used to replace damaged systems or build new systems
that will help protect life and property and can withstand future disasters and the
impacts of climate change.

5.2.1.7 Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

5.2.1.8 Program’s Method of Distribution

The program will be implemented through a competitive application process whereby
eligible applicants apply to OHCS for grants for eligible projects. Applications will be
scored and awarded based on published ranking and scoring criteria, subject to
funding availability.

OHCS will coordinate and consult with State partners, such as OEM, Business Oregon,
DLCD, and the Department of Environmental Quality (DEQ), when applicable, to ensure
that recovery and mitigation projects are coordinated with other related infrastructure
programs.

5.2.1.9 Program’s Competitive Application Review

OHCS will establish weighted scoring or eligibility criteria that will assess such factors as
the following:

• Ensuring that all newly constructed infrastructure is designed and constructed to

withstand extreme weather events and the impacts of climate change, including
whether projects meet federal elevation, updated code compliance, floodproofing
requirements, wildfire mitigation strategies, mitigation strategies against other

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 applicable natural hazards within the local and State natural hazards mitigation
plans, and green infrastructure strategies.
• Demonstrating that the project has been adopted through a local consolidated or
comprehensive plan, capital improvement plan, local resolution, and/or a similar
process that has undergone review and approval by the governing body.
• Cost reasonableness of the project.
• The ability to leverage other funding.
• The effectiveness of the proposed project within a defined service area in
protecting the public, including members of protected classes, HUD-defined
vulnerable populations, and historically underserved communities, from the risks in
each of the respective impacted communities.
• How the project will address a disaster-related impact.
• The ability of the subrecipient to operate and maintain the project beyond the life
of the CDBG-DR grant.

5.2.2.10 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the third quarter of 2023, after
HUD has approved the Public Action Plan.

The program will end when all funds have been expended and all eligible participants
have completed closeout, or 6 years after execution of the grant agreement with HUD.

5.3 Public Services

5.3.1 Housing and Recovery Services
Table 88: Housing and Recovery Services Budget
Proposed HUD- Proposed Grantee
Program Budget Identified MID Budget MID Budget
Housing and $6,017,576 99% 1%
Recovery Services

5.3.1.1 Program Description

OHCS may administer the Housing and Recovery Services Program directly or by
awarding grants to homeownership centers, nonprofit organizations, or other qualified
subrecipients to deliver housing and financial counseling and housing navigation
services to impacted residents to help in their transition to more permanent housing.
Services also may be provided to small rental property owners who provide affordable
housing to income-qualified tenants. Services may include homeowner education,

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renter counseling, homebuyer education, financial literacy, credit rehabilitation, debt
management, budgeting, homelessness counseling, avoiding fraud and scams,
applying for public and private resources, foreclosure prevention strategies, and
relocation counseling, among other services tailored to fit the participants’ needs.

5.3.1.1.1 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
Disaster-impacted households are facing monumental challenges and are making life-
changing decisions related to housing and their household finances. Due to the
pressures from FEMA, insufficient insurance, confusing application processes, lack of
affordable housing, and other circumstances, many households are forced to make
quick decisions, even as they are reeling from the shock and confusion that always
accompanies a disaster. These quick and short-term decisions can have long-term
consequences, particularly for those impacted residents with access to the fewest
resources and Oregon’s most vulnerable populations.

Housing counseling and navigation providers will help impacted residents, vulnerable
populations, and members of underserved communities expedite their recovery by:

• Performing outreach and engagement to understand impacted participants’

unmet needs, including specific needs faced by Latino/a/x, black, indigenous and
people of color and individuals living with disabilities, and other individuals and
households who continue to struggle to recover.
• Assessing housing needs and financial resources and addressing other concerns
about short- and long-term housing.
• Discussing the unique assistance needs and resources available.
• Connecting with State and local recovery resources.
• Communicating with lenders, insurance companies, and government agencies.
• Supporting application intake and assisting with the necessary paperwork for
recovery programs.
• Reviewing income, expenses, credit, and debt and helping to develop ways to
improve a participant’s financial situation.
• Creating a personalized action plan.
• Providing other housing navigation services.
• Providing financial counseling services to owners of small rental properties who will
rent housing at affordable rates to income-qualified tenants.

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5.3.1.1.2 How the Program Promotes Long-Term Resilience
The program helps at-risk disaster survivors have access to stable and affordable
housing. This assistance is critical for helping residents plan for current and future
housing costs, access recovery programs, complete the required paperwork, and gain
the support needed to drive their recovery in a way that makes them more resilient to
future disasters and disruptions.

5.3.1.2 Program’s National Objective(s)

Assistance provided under this program will meet the national objectives of benefiting
LMI persons or households or addressing an urgent need.

The program may use the Urgent Need national objective to provide assistance to
eligible applicants with incomes greater than 80% AMI.

5.3.1.3 Program Eligibility

Geographic Eligibility: FEMA IA-declared counties for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath

Eligible Applicants: To be eligible for the program, applicants must meet the following
criteria:

• Must be displaced or facing housing insecurity in one of the HUD- or grantee-

identified MIDs.

5.3.1.4 Program-Eligible Activities and Maximum Assistance

Table 89: Housing and Recovery Services Eligible Activities

CDBG-DR HCDA Section 105(a)8, 15, and 19; applicable waivers identified in
Eligible the Allocation Announcement Notice and Consolidated Notice
Activities (87 FR 6364)

Assistance will be provided to eligible subrecipients in the form of grants to deliver the
following types of services:

• Performing outreach and engagement to understand impacted participants’

unmet needs.
• Assessing housing needs, financial resources, and addressing other concerns about
short- and long-term housing.

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• Discussing unique assistance needs and the resources available.
• Connecting with State and local recovery resources.
• Communicating with lenders, insurance companies, and government agencies.
• Supporting application intake and assisting with the necessary paperwork for
recovery programs.
• Reviewing income, expenses, credit and debt, and helping to develop ways to
improve a participant’s financial situation.
• Creating a personalized action plan.
• Providing other housing navigation services.
• Providing financial counseling services to owners of small rental properties who will
rent housing at affordable rates to income-qualified tenants.
The maximum amount that can be allocated to the subrecipient will be detailed in
program guidelines and will be determined based on such factors as the subrecipient’s
capacity, location, and/or the communities served by the organization.

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5.3.1.5 Connection to Disaster and Unmet Needs
The program provides services to individuals and households living in 2020 Wildfires-
impacted communities.

5.3.1.6 Program’s Affordability Period

Not applicable.

5.3.1.7 Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

5.3.1.8 Program’s Method of Distribution

The State may implement this program directly and/or through subrecipients.

The program policies and public funding announcements will provide information on
how qualified providers will receive grants to provide eligible services to eligible
applicants.

Eligible subrecipients may include homeownership centers, culturally specific or

community-based organizations, long-term recovery groups, and/or other nonprofit
organizations qualified to provide housing or financial counseling services to applicants.

The State may allocate funds to eligible organizations based on their capacity,
location, and/or the communities served by the organization.

5.3.1.9 Program’s Competitive Application Review

Not applicable.

5.3.1.10 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the first quarter of 2023, after HUD
has approved the Public Action Plan.

The program will end when all funds have been expended and all eligible participants
have completed closeout, or 6 years after execution of the grant agreement with HUD.

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5.3.2 Legal Services
Table 90: Legal Services Budget

Proposed HUD- Proposed Grantee

Program Budget Identified MID Budget MID Budget
Legal Services $6,017,575 99% 1%

5.3.2.1 Program Description

Through the Legal Services Program, OHCS will provide funding to qualified legal aid
and/or legal services providers to deliver the assistance necessary to help impacted
residents transition to more permanent housing.

5.3.2.1.1 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
In the aftermath of a disaster, legal services are a critical component of comprehensive
disaster relief. Legal resources are often unattainable and/or unaffordable to
Latino/a/x, black, indigenous, and people of color, HUD-defined vulnerable
populations, and LMI households as they work through the challenges of recovery that
require legal representation, support, and/or analysis. Failure to resolve these legal
issues often results in the denial of recovery resources and/or delays to recovery; these
delays and denials disproportionately impact communities of color and individuals with
LEP.

This program will help vulnerable populations overcome many of these challenges and
access recovery resources through the following types of legal services:

• Replacing identification papers.

• Working through insurance claims.
• Clearing property titles and working through heirship and probate.
• Fighting unlawful evictions and foreclosures.
• Combating contractor scams and fraud.
• Assistance with school transfers.
• Obtaining emergency child custody, visitation, support, and other court orders
requiring modification as a result of displacement, injury, or job loss.
• Other legal services related to recovery.

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5.3.2.1.2 How the Program Promotes Long-Term Resilience
The program helps at-risk disaster survivors secure stable and affordable recovery
housing that is more resilient to future disasters. This assistance is critical for helping
residents navigate the legal challenges that serve as barriers to recovery and maintain
legal access to their recovery housing.

5.3.2.2 Program’s National Objective(s)

Assistance provided under this program will meet the national objectives of benefiting
LMI persons or households or addressing an urgent need.

The program may use the Urgent Need national objective to provide assistance to
eligible disaster-impacted applicants with incomes greater than 80% AMI.

5.3.2.3 Program Eligibility

Geographic Eligibility: FEMA IA-declared counties for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath

Eligible Applicants: To be eligible for the program, applicants must meet the following
criteria:

• Must be actively participating in one of the other CDBG-DR housing programs.

5.3.2.4 Program-Eligible Activities and Maximum Assistance

Table 91: Legal Services Eligible Activities

CDBG-DR HCDA Section 105(a) 8; applicable waivers identified in the Allocation

Eligible Announcement Notice and Consolidated Notice (87 FR 6364)
Activities

Assistance will be provided to eligible subrecipients or OHCS-contracted legal services

providers to deliver the following types of assistance:

• Replacing identification papers.

• Working through insurance claims.
• Clearing property titles and working through heirship and probate.
• Fighting unlawful evictions and foreclosures.
• Combating contractor scams and fraud.

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• Assistance with school transfers.
• Obtaining emergency child custody, visitation, support, and other court orders
requiring modification as a result of displacement, injury, or job loss.
• Other legal services needed for applicants to complete their recovery through one
of the other CDBG-DR programs.

5.3.2.5 Connection to Disaster and Unmet Needs

The program provides services to individuals and households impacted by the 2020
Wildfires.

5.3.2.6 Program’s Affordability Period

Not applicable.

5.3.2.7 Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

5.3.2.8 Program’s Method of Distribution

The program policies or public funding announcements will provide information on how
qualified providers will receive awards to provide eligible services to eligible applicants.

The State may allocate funds to eligible organizations and/or competitively procure
service providers.

5.3.2.9 Program’s Competitive Application Review

Not applicable.

5.3.2.10 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the first quarter of 2023, after HUD
has approved the Public Action Plan.

The program will end when all funds have been expended and all eligible participants
have completed closeout, or 6 years after execution of the grant agreement with HUD.

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5.4 Planning and Administrative Costs
5.4.1 Community Planning and Revitalization Program
Table 92: Community Planning and Revitalization Program Budget
Proposed HUD-
Identified MID Proposed Grantee
Program Budget Budget MID Budget
Community Planning and $8,023,434 99% 1%
Revitalization Program

5.4.1.1 Program Description

The Community Planning and Revitalization Program will provide grant assistance for
recovery and mitigation planning and/or community technical assistance, including,
but not limited to, the following:

• Housing development strategies

• Economic revitalization
• Public land use and infrastructure policy and planning
• Public resilience and preparedness policy and planning
• Planning needed to enhance local codes and standards; carry out outreach to
members of their communities; and/or develop policy modifications that will result in
more resilient, safe, or affordable communities
The program may be implemented in multiple rounds, through a competitive process
and/or through direct allocation to eligible subrecipients.

5.4.1.1.1 How the Program Promotes Equity in Recovery and Housing for
Vulnerable Populations
To receive funding under this program, subrecipients will be required to describe how
their plan and/or technical assistance will address historic and systemic barriers,
environmental injustice, or other limitations faced by HUD-defined vulnerable
populations, underserved communities, individuals and households with LEP, protected
classes, and communities of color.

The planning and technical assistance process is intended to be inclusive and reflective
of those with lived disaster experience, housing insecurity, and/or economic insecurity.
The State will provide technical assistance to subrecipients to help them design and
implement an inclusive planning process that incorporates feedback and input in a
manner that is equitable and representative of the residents living in the impacted
areas.

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This level and type of inclusive community planning is designed to help recovering
communities incorporate the affordable and resilient housing needs of vulnerable
populations in their long-term recovery and resilience planning.

5.4.1.1.2 How the Program Promotes Long-Term Resilience

Each jurisdiction experienced the 2020 Wildfires differently, with some rural communities
facing a lack of public infrastructure and losing more than half of their residential or
commercial population, and others facing reconstruction needs in more urban areas. In
addition, many communities have existing plans that need to be supplemented or
enhanced with additional analysis, while others have a need for new planning to
rebuild their communities in a manner that can withstand future disasters.

This program is designed to promote sound, sustainable long-term recovery resilience

and planning that accounts for the unique hazards, opportunities, housing stock,
economic revitalization, land use restrictions, urban growth boundaries, underserved
communities, and disaster impacts within Oregon’s impacted communities. Applicants
will be required to describe the data and/or planning analysis they will use in their
evaluation of hazard risk, including climate-related natural hazards.

Subrecipients will ensure that their plans identify the following opportunities, as
applicable, within each of their plans:

• Increasing resilience to the impacts of climate change.

• Protecting public health.
• Conserving lands, waters, and biodiversity.
• Addressing environmental injustice.
• Spurring economic growth and creating jobs.

5.4.1.2 Program’s National Objective(s)

• Planning activities are presumed to meet a national objective under the
requirements at 24 CFR570.208(d)(4).

5.4.1.3 Program Eligibility

Geographic Eligibility: FEMA IA-declared counties for DR-4562:

• HUD-identified MID counties: Clackamas, Douglas, Jackson, Lane, Lincoln, Linn, and
Marion
• Grantee-identified MID counties: Klamath

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Eligible Applicants: Eligible applicants may include, but are not limited to:

• Tribal, State, county, and municipal governments, agencies, and authorities

• Schools (K–12)
• Public housing authorities
• Other public or quasi-public entities, including councils of government and other
regional organizations and economic development districts
• Long-term recovery groups and other community or housing development nonprofit
organizations

5.4.1.4 Program-Eligible Activities and Maximum Assistance

Table 93: Community Planning and Revitalization Program Eligible Activities

CDBG-DR HCDA Section 105(a)8, 9, 12, 16, and 21, administration costs,
Eligible applicable waivers identified in the Allocation Announcement Notice
Activities and Consolidated Notice (87 FR 6364)

Assistance may be used for recovery and mitigation planning and/or community
technical assistance, including, but not limited to, the following:

• Housing development strategies

• Economic revitalization
• Public land use and infrastructure policy and planning
• Public resilience and preparedness policy and planning
• Planning needed to enhance local codes and standards; carry out outreach to
members of their communities; and/or develop policy modifications that will result in
more resilient, safe, or affordable communities

Application procedures and maximum awards for planning and technical assistance
activities will be further detailed in program policies and procedures and public
notifications of funding availability.

5.4.1.5 Connection to Disaster and Unmet Needs

This pr ogram is limited to communities that were impacted by the 2020 Wildfires.

5.4.1.6Program’s Responsible Entity

Administering Entity: The State of Oregon, OHCS, and/or its subrecipients

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5.4.1.7 Program’s Method of Distribution
The program will be implemented through an allocation or application process
whereby eligible applicants apply to OHCS for planning grants. Awards will be made
based on an analysis of relative need and/or through published ranking and scoring
criteria, subject to funding availability.

OHCS will coordinate and consult with State partners, such as OEM, Business Oregon,
DLCD, and DEQ, and other regional or local entities, when applicable, to ensure that
planning efforts are coordinated.

When making awards, OHCS will assess such factors as:

• Eligibility as a recovery and mitigation plan and/or community technical assistance.

• How the plan or technical assistance will help the community protect the public,
including members of protected classes, HUD-defined vulnerable populations, and
historically underserved communities, from the risks in each of the respective
impacted communities.
• Cost reasonableness of the plan.
• The projected steps and path for adopting the plan.
• The outreach or engagement strategy for ensuring that the planning process is
inclusive and representative of the community, including individuals in federally
protected classes, vulnerable populations, and underserved communities.

5.4.1.8 Program’s Competitive Application Review

Not applicable.

5.4.1.9 Program’s Estimated Beginning and Ending Dates

The State anticipates that the program will begin in the third quarter of 2023, after
HUD has approved the Public Action Plan.

The program will end when all funds have been expended and all eligible participants
have completed closeout, or 6 years after execution of the grant agreement with HUD.

5.4.2 Administrative Costs

Table 94: Administrative Costs Budget

Proposed HUD- Proposed Grantee

Program Budget Identified MID Budget MID Budget
Administrative Costs $21,114,300 99% 1%

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5.4.2.1 Program Description
The costs necessary for the general administration of the CDBG-DR grant include, but
are not limited to, the State and subrecipient’s staff time administering programs;
compliance and monitoring of the State’s subrecipients, vendors, and other recipients
of funding; and other costs specified as eligible administrative expenses in 24 CFR
570.206.

Up to 5% of the overall grant and any program income may be used for administration
of the grant, inclusive of administrative costs incurred by OHCS and its subrecipients.

5.4.2.2 Program Eligibility

Table 95: Administrative Costs Eligible Activity

CDBG-DR Program administrative costs, defined at 24 CFR 570.205 and

Eligible 570.206, and any applicable waivers or alternative requirements
Activities

Eligible Recipients: State and eligible subrecipients carrying out CDBG-DR programs

6. Appendix
6.1 Certifications
• The grantee certifies that it has in effect and is following a residential
antidisplacement and relocation assistance plan in connection with any activity
assisted with funding under the CDBG program.
• The grantee certifies its compliance with restrictions on lobbying required by 24 CFR
Part 87, together with disclosure forms, if required by Part 87.
• The grantee certifies that the Action Plan for Disaster Recovery is authorized under
State and local law (as applicable) and that the grantee, and any entity or entities
designated by the grantee, possess(es) the legal authority to carry out the program
for which it is seeking funding in accordance with applicable HUD regulations and
this notice. The grantee certifies that activities to be administered with funds under
this notice are consistent with its Action Plan.
• The grantee certifies that it will comply with the acquisition and relocation
requirements of the Uniform Relocation Assistance and Real Property Acquisition
Act, as amended, and its implementing regulations at 49 CFR Part 24, except where
waivers or alternative requirements are provided for in this notice.
• The grantee certifies that it will comply with Section 3 of the Housing and Urban
Development Act of 1968 (12 U.S.C. 1701u) and implementing regulations at 24 CFR
Part 135.

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• The grantee certifies that it is following a detailed citizen participation plan that
satisfies the requirements of 24 CFR 91.105 or 91.115, as applicable (except as
provided for in notices providing waivers and alternative requirements for this grant).
Also, each local government receiving assistance from a State grantee must follow
a detailed citizen participation plan that satisfies the requirements of 24 CFR 570.486
(except as provided for in notices providing waivers and alternative requirements for
this grant).
• Each State receiving a direct award under this notice certifies that it has consulted
with affected local governments in counties designated in covered major disaster
declarations in the non-entitlement, entitlement, and tribal areas of the State in
determining the uses of funds, including the method of distribution of funding, or
activities carried out directly by the State.
• The grantee certifies that it is complying with each of the following criteria:
– Funds will be used solely for necessary expenses related to disaster relief,
long-term recovery, restoration of infrastructure and housing, and economic
revitalization in the MID areas for which there is a presidentially declared disaster
in 2020 pursuant to the Robert T. Stafford Disaster Relief and Emergency
Assistance Act of 1974 (42 U.S.C. 5121 et seq.).
– With respect to activities expected to be assisted with CDBG-DR funds, the
Action Plan has been developed in order to give the maximum feasible priority
to activities that will benefit LMI families.
– The aggregate use of CDBG-DR funds shall principally benefit LMI families in a
manner that ensures that at least 70% of the grant amount is expended for
activities that benefit such persons.
– The grantee will not attempt to recover any capital costs of public improvements
assisted with CDBG-DR grant funds by assessing any amount against properties
owned and occupied by LMI persons, including any fee charged or assessment
made as a condition of obtaining access to such public improvements, unless
(a) disaster recovery grant funds are used to pay the proportion of such fee or
assessment that relates to the capital costs of such public improvements that are
financed from revenue sources other than under this title, or (b) for the purposes
of assessing any amount against properties owned and occupied by persons of
moderate income, the grantee certifies to the Secretary that it lacks sufficient
CDBG funds (in any form) to comply with the requirements of clause (a).
• The grantee certifies that it will conduct and carry out the grant in conformity with
Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d) and the Fair Housing Act
(42 U.S.C. 3601–3619) and implementing regulations, and that it will affirmatively
further fair housing.

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• The grantee certifies that it has adopted and is enforcing the following policies. In
addition, States receiving a direct award must certify that they will require units of
general local government that receive grant funds to certify that they have
adopted and are enforcing:
– A policy prohibiting the use of excessive force by law enforcement agencies
within its jurisdiction against any individuals engaged in nonviolent civil rights
demonstrations, and
– A policy of enforcing applicable State and local laws against physically barring
entrance to or exit from a facility or location that is the subject of such nonviolent
civil rights demonstrations within its jurisdiction.
• Each State receiving a direct award under this notice certifies that it (and any
subrecipient or administering entity) currently has or will develop and maintain the
capacity to carry out disaster recovery activities in a timely manner and that the
grantee has reviewed the requirements of this notice. The grantee certifies to the
accuracy of its applicable Public Law Financial Management and Grant
Compliance certification checklist, or other recent certification submission,
if approved by HUD, and related supporting documentation referenced therein and
its Implementation Plan and Capacity Assessment and related submission to HUD
referenced therein.
• The grantee will not use grant funds for any activity in an area identified as
floodprone for land use or hazard mitigation planning purposes by the State, local,
or tribal government or delineated as an SFHA (or 100-year floodplain) in FEMA’s
most recent flood advisory maps, unless it also ensures that the action is designed or
modified to minimize harm to or within the floodplain, in accordance with Executive
Order 11988 and 24 CFR Part 55. The relevant data source for this provision is the
State, local, and tribal government land use regulations and hazard mitigation plan
and the latest issued FEMA data or guidance, which includes advisory data (such as
Advisory Base Flood Elevations) or preliminary and final Flood Insurance Rate Maps.
• The grantee certifies that its activities concerning lead-based paint will comply with
the requirements of 24 CFR Part 35, subparts A, B, J, K, and R.
• The grantee certifies that it will comply with the environmental requirements at
24 CFR Part 58.
• The grantee certifies that it will comply with applicable laws.

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6.2 Waivers
6.2.1 Extension of Tenant-Based Rental Assistance
OHCS is requesting a waiver of 42 U.S.C. 5305(a) to provide tenant-based rental
assistance to households impacted by the disaster to the extent necessary to make
eligible rental assistance and utility payments paid for up to 36 months on behalf of
displaced and at-risk households when such assistance or payments are part of a
homeless prevention, intermediate housing, or rapid rehousing program or activity, as
well as for intermediate housing for grant recipients during the repair or reconstruction
of their homes. While existing CDBG regulations may allow payments for these purposes,
grantees under the annual CDBG programs are subject to a much shorter time
limitation (3 months). This waiver will assist individual and families—both those already
receiving rental assistance and those who will receive rental assistance subsequently—
to maintain stable, permanent housing and help them return to their communities, as
desired, when additional permanent housing is available or when their homes have
been restored. It also will provide additional time to stabilize individuals and families in
permanent housing where rents are higher than is typical for the area and vacancy
rates are extraordinarily low while damaged homes continue to be repaired.

6.2.2 Applicability of the Davis-Bacon and Related Acts, Section 3,

and Section 504 to Ongoing or Pre-Award Non-Residential and Non-
Commercial Construction Work
If construction work is ongoing when an application for reimbursement or financing of
construction costs is submitted, then the Davis-Bacon prevailing wage rates are
applicable. Under the regulations of the U.S. Department of Labor (DOL) at 29 CFR
§1.6(g), where federal assistance is not approved prior to contract award (or the
beginning of construction if there is no contract award), Davis-Bacon wage rates apply
retroactively to the beginning of construction and must be incorporated retroactively in
the contract specifications.

However, if there is no evidence that the owner intended to apply for the CDBG-DR
assistance prior to the contract award or the start of construction, then OHCS is
requesting for HUD to request that DOL allow prospective, rather than retroactive,
application of the Davis-Bacon wage rates.

The State seeks a similar alternative requirement for the applicability of compliance with
Section 3 and Section 504 under these circumstances.

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6.2.3 Section 104(d) One-for-One Replacement of Lower Income
Dwelling Units
OHCS is adopting the waiver provided through Section IV.F.1 of the Consolidated
Notice. For the purpose of complying with this alternative requirement, OHCS is defining
a property as “not suitable for rehabilitation” if any of these conditions apply:

• The property is declared to be a total loss.

• Repairs would exceed 50% of the cost of reconstruction.
• Homes cannot be rehabilitated or reconstructed in place under existing agency
policies and award caps due to legal, engineering, or environmental constraints,
such as permitting, extraordinary site conditions, or historic preservation.

6.3 Summary and Response to Public Comments

Comments and responses shall be posted in the final Action Plan submitted to HUD.

6.4 Data Sources/Methodologies

6.4.1 Housing Unmet Needs Calculation
6.4.1.1. HUD Unmet Needs Calculation Methodology
For its unmet housing needs calculation, HUD considers major low, major high, and
severe damage categories for both owner and renter households, which are defined in
the Federal Register Notice for calculating unmet recovery needs. For owner-occupied
properties, this means anyone with real property damages above $8,000 or $3,500 in
personal property damages. For renter-occupied properties, the threshold includes
anyone with more than $2,000 in personal property damages. There are additional
details below on the damage categories by owner-occupied and renter- (tenant)
occupied households. Generally, FEMA categorizes manufactured homeowners who
owned their unit as owners, even when their unit is placed on leased land.

Owner-Occupied Households

Real or Personal Property Damage Categories

• Minor Low:
– Less than $3,000 in FEMA-inspected real property damage or less than $2,500 in
FEMA-inspected personal property verified loss
• Minor High:
– $3,000 to $7,999 in FEMA-inspected real property damage or $2,500 to $3,499 in
FEMA-inspected personal property verified loss

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• Major Low:
– $8,000 to $14,999 in FEMA-inspected real property damage or $3,500 to $4,999 in
FEMA-inspected personal property verified loss
• Major High:
– $15,000 to $28,800 in FEMA-inspected real property damage or $5,000 to $9,000
in FEMA-inspected personal property verified loss
• Severe:
– Greater than $28,800 in FEMA-inspected real property verified loss or determined
destroyed or greater than $9,000 in FEMA-inspected personal property verified
loss or determined destroyed

Renter-Occupied Households

Personal Property

• Minor Low:
– Less than $1,000 in FEMA-inspected personal property verified loss
• Minor High:
– $1,000 to $1,999 in FEMA-inspected personal property verified loss
• Major Low:
– $2,000 to $3,499 in FEMA-inspected personal property verified loss
• Major High:
– $3,500 to $7,500 in FEMA-inspected personal property verified loss
• Severe:
– Greater than $7,500 in FEMA-inspected personal property verified loss

While the FEMA IA data are incomplete in presenting the true level of impact to owners
and renters, it is the best available dataset available to the State that distinguishes
between impacted owners and renters. The table below demonstrates the relative
percentages of owners and renters who:

• Applied to FEMA IA (total registrants).

• Had a FEMA verified loss (FVL) greater than $0 (total FVL over $0).
• Experienced major to severe levels of FEMA verified loss (total major to severe).

The data analysis in this table also includes the average FEMA verified loss for owners
and renters (average FVL in $).

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Table 96: Average FEMA Verified Loss for Owners and Renters
FEMA Individual
Assistance Owner Owner % Renter Renter % Unidentified Total
Total Registrations 6,958 29% 17,055 71% 25 24,038

Total FVL Over $0 1,835 47% 2,089 53% 0 3,924

Total Major to 47% 53%
1,427 1,605 0 3,032
Severe

Average FVL $ $46,255 N/A $5,847 N/A N/A N/A

Data from FEMA FIDA 40449 4562, February 17, 2022.

1.4.1.1.3 FEMA/SBA Multiplier

OHCS has calculated the ratio and derived what is called an SBA multiplier, using a
subset of FEMA IA applicants with the following:

• Major and severe HUD-defined damages of FEMA verified loss

• SBA verified loss and FEMA real property verified loss

The use of an SBA multiplier is the methodology that HUD has used for projecting a more
accurate estimated need, as the SBA inspection conceivably covers the cost of
bringing the home back to pre-disaster condition, while FEMA inspections are based on
the amount needed for a homeowner to make the home safe, sanitary, or functional.
The following table shows the number of households that registered with both FEMA IA
and the SBA and calculates the SBA multiplier.

Table 97: Ratio of SBA to FEMA Verified Loss for SBA Multiplier
Ratio of SBA to FEMA
No. of Owner Total Real Verified Loss = SBA
Registrations Property Multiplier
Damage (both FEMA and Total SBA FEMA Verified (SBA FVL/FEMA Real
Category the SBA) Verified Loss Loss Property FVL)
Severe 168 $25,028,153 $14,817,592 1.69
Major High 2.43
and Low 22 $1,046,927 $430,701
TOTAL 190 $26,075,080 $15,248,293 1.71

When this multiplier is applied across FEMA IA owner-occupied registrants with major to
severe FEMA verified losses, there would be an estimated $143,105,403 in owner-
occupied losses, as laid out in the table below.

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Table 98: Average Owner Loss with SBA Multiplier

Ratio of SBA Total Owner

to FEMA Count with Estimated Average
FEMA IA Verified Loss FEMA Verified Total Owner Total Owner Owner Loss
Damage (SBA Loss FEMA Verified Loss with SBA with SBA
Category Multiplier) Loss Multiplier Multiplier
Severe 1.69 1,147 $81,740,816 $138,141,978 $120,437
Major High 2.43 280 $2,042,562 $4,963,425 $17,727
and Low
TOTAL 1.71 1,427 $83,783,378 $143,105,403 N/A

Because FEMA does not assess real property damages for rental properties, to project
the rental housing replacement need, OHCS uses the average owner loss with SBA
multiplier and projects that onto the renter FEMA IA population, as demonstrated in the
table below.

Table 99: Estimated Rental Loss with SBA Multiplier

Total Renter Average Owner Estimated Total

FEMA IA Damage Count with FEMA Loss with SBA Renter Loss with
Category Verified Loss Multiplier SBA Multiplier
Severe 745 $120,437 $89,726,045
Major High and Low 860 $17,727 $15,244,806
TOTAL 1,605 N/A $104,970,851

Using the SBA-FEMA methodology with FEMA IA data, the owner and renter housing loss
is detailed in the table below. However, the State knows that this assessment
undervalues the actual costs to recover from the residential damages caused during
the 2020 Wildfires and therefore additional analysis is performed in the next section.

Table 100: Sum of Owner and Renter Loss using SBA Multiplier
FEMA IA Damage Total Estimated Loss
Category Registrant Count with SBA Multiplier Percentage of Total
Owner – Major to 1,427 $143,105,403 58%
Severe
Renter – Major to 1,605 $104,970,851 42%
Severe
TOTAL 3,032 $248,076,254 100%

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6.4.1.2 Alternative Methodology: Estimated Costs to Replace Damaged and
Destroyed Housing
According to OEM and local damage assessments, the actual number of residential
units that were damaged or destroyed in the 2020 Wildfires is 4,326, or nearly 30% more
than the 3,032 valid FEMA registrants with major to severe damages; therefore, the
FEMA IA data registrant totals do not reflect the actual number of residential units that
were damaged or destroyed. In addition, based on OHCS research, the SBA-estimated
loss does not reflect the current costs to reconstruct or replace damaged or destroyed
housing—including affordable housing or building back more resiliently—in the HUD
MIDs and Klamath County.

Because of the limits of the FEMA and SBA data, OHCS performed additional analysis to
calculate a more accurate projection of the costs to rebuild or replace major
damaged or destroyed housing. The housing damage analysis performed by OEM and
local governments does not include a distinction between owner-occupied and renter-
occupied units but includes a breakdown based on structure type. The analysis below
includes an average estimate of cost based on average costs across different structure
and reconstruction types.

Table 101: Sources for Average Cost to Rebuild Resiliently

Source Average Unit Cost

SBA Average Verified Loss $210,222
Affordable Multifamily Cost per Unit $314,347
Manufactured Home Cost per Unit in Investor-Owned Parks
$139,117
with Site Improvements
Modular Cost per Unit in Affordable Parks (including land
$331,817
and infrastructure)
Manufactured Home Cost per Unit in Affordable Parks
$305,000
(including land and infrastructure)
November 2021 Zillow Estimate/New Construction $252,494
November 2021 Zillow Estimate/New Construction $302,494
Septic/Well Repairs
Average of Averages of Estimated Unit Cost to Rebuild $265,070
Add 15% Resilience $39,761
Average of Averages of Unit Cost to Rebuild Resiliently $304,831

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6.4.1.2.1 SBA Average Verified Loss
This value was calculated using the average current value of verified loss for
homeowners who were approved for an SBA loan as a result of the 2020 Wildfires.

After disasters, the SBA provides subsidized low-interest disaster loans to homeowners
and renters. These loans can be used to repair or replace real estate and personal
property impacted by the wildfires.

The SBA’s loss verification is used to estimate and validate the cost of restoring disaster-
damaged property to its pre-disaster condition. In the past, loss verifiers conducted
damage assessments solely through on-site inspections. However, in 2017, the SBA
implemented the desktop loss verification process. This process uses a two-step
approach, an initial desktop loss verification and a post-desktop review. The initial
desktop loss verification is used to estimate the cost of repairs. This is evaluated through
telephonic interviews and third-party information sources (tax assessor’s websites,
Google Earth, and Zillow). After an initial desktop loss is calculated, a post-desktop
review is conducted. For loans less than $25,000, loss verifiers rely on a FEMA on-site
inspection report. In the event that this was not conducted, the SBA conducts its own
on-site inspection. For loans exceeding $25,000, an SBA-conducted on-site inspection is
required.

6.4.1.2.2 Affordable Multifamily Cost per Unit

The calculation for affordable multifamily cost per unit was provided by the Housing
Authority of Jackson County (one of the eight impacted counties). These estimates
come from four construction projects that the housing authority had completed in the
past 4 years. Two of these projects occurred after the time of the disaster. Both
multifamily housing projects started after the 2020 Wildfires saw increased per unit costs
of 5% and 19%, respectively. Hard construction costs increased by 22% in 2021.
These project costs include land acquisition, construction, and soft costs per unit
post-wildfire. Increased costs from the projects were attributed primarily to increases in
land, labor, and construction material costs.

6.4.1.2.3 Manufactured Homes in Investor-Owned Manufactured Home Parks

with Site Improvements
The average cost of a manufactured home (MH) in an investor-owned manufactured
housing park, including site improvements, is calculated from OHCS’s Manufactured
Home Replacement Program. The estimates provided are the average of single-wide
and double-wide unit costs, plus site improvements. These costs do not include
elevation costs. MH park owners who are bringing in new manufactured homes and
homeowners involved in replacements note that increases in replacement MH costs,
lack of inventory, timeline delays, and challenges in rebuilding park infrastructure have
accounted for the lack of affordability and availability for impacted MH residents.

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6.4.1.2.4 Manufactured and Modular Home Costs per Unit in Affordable Parks
The manufactured and modular home costs per unit in affordable parks are based on
OHCS-funded projects that purchase and rebuild manufactured housing parks, provide
prefabricated units, and preserve the parks as affordable. Based on current cap rates
and market conditions, the development cost per space is estimated at between
$300,000 and $350,000 (depending on the unit type), and includes land, infrastructure,
capital improvements, and unit acquisition and installation.

6.4.1.2.5 November 2021 Zillow Estimate (New Construction)

The November 2021 Zillow estimates are a seasonally adjusted measure of typical home
values across a given region and housing type. The Zillow estimates provide median
home values at the county level. For this dataset, OHCS used the Zillow estimate and
assumed that two-thirds of the actual home value is for the residential structure itself.
With this data, OHCS then calculated a weighted average of home values in the
impacted counites. Thus, taking 66% of the median home value from Zillow’s $382,567
average across the eight counties gives us a weighted home value of $252,494.

This number also was validated through data that OHCS received from multiple
homebuilders, who estimated the cost to build new single-family housing (3-bedroom/2-
bath) in Oregon to range from $220,000 to $250,000. This did not include the cost of
land acquisition or residential infrastructure.

6.4.1.2.6 November 2021 Zillow Cost Estimate with Septic/Well Repairs (New
Construction)
This November 2021 Zillow cost estimate follows the same methodology as above but
includes additional septic and well repairs. The Oregon DEQ estimates these additional
costs to be around $50,000 per residential unit. OHCS estimates that more than 1,100
damaged properties will need this type of repair. One additional component that most
of the above datasets specifically excluded was site work—infrastructure in support of
housing, landscaping, and other costs outside of the construction of the housing unit
itself. Much of the impacted structures are located in rural areas without access to
public utilities. As such, it is important for OHCS to include these home infrastructure-
related costs for the installation of wells, septic, resilient landscaping, hardscaping for
driveways, sidewalks, and other site improvements.

6.4.1.2.7 Resilient Construction Estimates

OHCS anticipated that all new reconstructed properties will integrate resilient building
design and materials. Based on the HUD Federal Register Notice, the State anticipates
at least a 15% cost increase from standards-based construction to resilient and
mitigating construction.

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6.4.2 Data Sources Referenced in the Action Plan
• OHCS, Implementing a Regional Housing Needs Analysis Methodology in Oregon
(March 2021), https://www.oregon.gov/ohcs/about-us/Documents/RHNA/2020-
RHNA-Technical-Report-Final.pdf
• Oregon Disaster Housing Recovery Action Plan (June 2021),
https://www.oregon.gov/ohcs/get-involved/Documents/committees/ODHTF/07-22-
21-Oregon-Disaster-Housing-Recovery-Action-Plan-June-2021.pdf
• State of Oregon, 2021–2025 Consolidated Plan,
https://www.oregon.gov/ohcs/development/Pages/consolidated-plan.aspx
• U.S. Census Bureau, Rental and Homeowner Vacancy Rates by Area,
https://www.census.gov/housing/hvs/data/ann20ind.html DR-4562: Housing Impact
Assessment, https://www.oregon.gov/ohcs/get-
involved/Documents/committees/ODHTF/05-03-2021-DR-4562-
OR%20Assessment%20(FINAL%202021-04-30).pdf
• Oregon Office of Emergency Management, 2020 Oregon Wildfire Spotlight,
https://oregon-oem-geo.hub.arcgis.com/apps/2020-oregon-wildfire-
spotlight/explore
• Oregon Office of Emergency Management, Wildfire Dashboard,
https://experience.arcgis.com/experience/533e2f942b1a49bdb6746a16b68b7981
• Oregon Office of Emergency Management, Wildfire Response and Recovery,
https://wildfire.oregon.gov/recovery
• Oregon Health Authority, Social Determinants of Health – Rent Burden,
https://www.oregon.gov/oha/PH/ABOUT/Documents/indicators/rentburden.pdf
• DR-4562-OR: Housing Impact Assessment, https://www.oregon.gov/ohcs/get-
involved/Documents/committees/ODHTF/05-03-2021-DR-4562-
OR%20Assessment%20(FINAL%202021-04-30).pdf
• U.S. Census Bureau QuickFacts, Various Counties in Oregon,
https://www.census.gov/quickfacts/fact/table/US/PST045221
• Oregon State University, A Review of Manufactured Housing Policies (2018),
https://appliedecon.oregonstate.edu/sites/agscid7/files/applied-
economics/final_paper_bewley.pdf
• Prosperity Now, Oregon Manufactured Housing Opportunity Profile: Data Snapshot,
https://prosperitynow.org/sites/default/files/resources/Affordable%20Homeownershi
p/Snapshots/Oregon%20MH%20Data%20Snapshot.pdf
• Network for Oregon Affordable Housing, Manufactured Home Parks, https://noah-
housing.org/programs/manu/

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• CASA of Oregon, Manufactured Housing Cooperative Development,
https://casaoforegon.org/for-individual/manufactured-housing-cooperative-
development/
• OHCS, NOFA: Preservation of Manufactured Dwelling Park, NOFA #2020-8,
https://www.oregon.gov/ohcs/development/Pages/nofa-ghap-manufactured-
parks.aspx
• Associated General Contractors, Oregon-Columbia Chapter, Construction
Workforce Shortages Reach Pre-Pandemic Levels (September 2021),
https://www.agc-oregon.org/uncategorized/construction-workforce-shortages-
reach-pre-pandemic-levels-2/
• FEMA, DR-4562-OR: Disaster Sheltering and Housing Strategy,
https://www.oregon.gov/ohcs/get-involved/Documents/committees/ODHTF/FEMA-
Disaster-Sheltering-Housing-Strategy-DR4562.pdf FEMA, Individual Assistance
Program and Policy Guide, https://www.fema.gov/sites/default/files/2020-
07/fema_individual-assistance-program-policy-guide_2019.pdf
• OHCS, Housing Stability Council, Bylaws,
https://www.oregon.gov/ohcs/hsc/Pages/index.aspx
• OHCS, Statewide Housing Plan: 2019–2023,
https://www.oregon.gov/ohcs/pages/oregon-state-wide-housing-plan.aspx
• OHCS, Statewide Housing Plan: 2019–2023, Priority: Equity and Racial Justice,
https://www.oregon.gov/ohcs/Documents/swhp/facts-swhp-equity-priority.pdf
• Unete (Center for Farm Worker and Immigrant Advocacy), Almeda Housing Survey
2021,
https://www.canva.com/design/DAExaPiwXT8/fxIcQhZ0eyOysmz950zPIA/view?utm_
content=DAExaPiwXT8&utm_campaign=designshare&utm_medium=link&utm_sourc
e=shareyourdesignpanel#1
• OHCS Statewide Shelter Study (August 2019), https://www.oregon.gov/ohcs/about-
us/Documents/poverty/Oregon-Statewide-Shelter-Study.pdf
• Oregon Community Foundation, Homelessness in Oregon (March 2019),
https://oregoncf.org/community-impact/research/homelessness-in-oregon/
• Oregon Department of Land Conservation and Development, Urban Planning,
https://www.oregon.gov/lcd/UP/Pages/Urban-Planning.aspx
• IRS, Opportunity Zones, https://www.irs.gov/credits-
deductions/businesses/opportunity-zones
• Office of Management and Budget, Implementation Guidance for the Justice40
Initiative, https://www.whitehouse.gov/wp-content/uploads/2021/07/M-21-28.pdf

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• Oregon State Legislature, Regional Housing Needs Analysis Memo (April 2021),
https://olis.oregonlegislature.gov/liz/2021r1/Downloads/CommitteeMeetingDocume
nt/244208
• OHCS, Implementing a Regional Housing Needs Analysis Methodology in Oregon
(March 2021), https://www.oregon.gov/ohcs/about-us/Documents/RHNA/RHNA-
Technical-Report.pdf
• OHCS, Regional Housing Needs Analysis Companion Summary (February 2021),
https://www.oregon.gov/ohcs/about-us/Documents/RHNA/02-21-2021-ECONW-
OHCS.pdf
• Oregon Department of Land Conservation and Development, RHNA Working Group
Meeting (October 28, 2021),
https://www.oregon.gov/lcd/UP/Documents/20211028_RHNA_WorkGroup_Mtg1.pdf
• Oregon Office of Emergency Management, State Disaster Recovery Plan (March
2018),
https://www.oregon.gov/oem/Documents/OR_RECOVERY_PLAN_MARCH_2018.pdf
• Oregon State Legislature, Equity Framework in COVID-19 Response and Recovery,
https://digital.osl.state.or.us/islandora/object/osl%3A948967/datastream/OBJ/view
• OHCS, House Bill 2100, Task Force on Homelessness and Racial Disparities in Oregon,
https://www.oregon.gov/ohcs/get-involved/Documents/01-21-2022-Findings-and-
Recommendation.pdf
• Office of the Governor, Wildfire Economic Recovery Council,
https://www.oregon.gov/gov/policies/Wildfire Programs Council
Documents/Wildfire-Prog-Dir-Rpt_March-2022.pdf
• Congressional Research Service, FEMA PA Overview,
https://crsreports.congress.gov/product/pdf/IF/IF11529
• Oregon Office of Emergency Management, Hazard Mitigation Grant Program,
https://www.oregon.gov/oem/Documents/DR4258_Brochure.pdf
• Oregon Office of Emergency Management, State Interagency Hazard Mitigation
Team (State IHMT), https://www.oregon.gov/oem/Councils-and-
Committees/Pages/IHMT.aspx
• Oregon Office of Economic Analysis, Oregon Employment (September 2020),
https://oregoneconomicanalysis.com/2020/10/15/oregon-employment-september-
2020/
• Oregon State University, Oregon Agriculture, Food and Fiber: An Economic Analysis,
https://agsci.oregonstate.edu/sites/agscid7/files/main/about/oragecon_report_202
1.pdf

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• Oregon Department of Land Conservation and Development, Natural Hazards
Mitigation Plan,
https://www.oregon.gov/lcd/NH/Documents/Approved_2020ORNHMP_02_ExecSum
.pdf
• USDA, Forest Service, Wildfire Risk to Communities (2021),
https://wildfirerisk.org/download/
• Oregon Climate Change Research Institute, Fourth Oregon Climate Assessment
Report: State of climate science: 2019,
https://www.oregon.gov/lcd/NH/Documents/Apx_9.1.21_OR_ClimateAssmtRpt4_201
9_OPT.pdf
• Oregon Department of Geology and Mineral Industries, Earthquake regional impact
analysis (2020), https://www.oregongeology.org/pubs/ofr/p-O-20-01.htm
• Center for Emergency Management and Homeland Security, Spatial Hazard Events
and Losses Database for the United States, https://cemhs.asu.edu/sheldus
• Oregon Office of Emergency Management, Initial After-Action Review of the June
2021 Excessive Heat Event,
https://www.oregon.gov/oem/Documents/2021_June_Excessive_Heat_Event_AAR.p
df
• University of Edinburgh, Substantial changes in the probability of future annual
temperature extremes (2021),
https://www.research.ed.ac.uk/en/publications/substantial-changes-in-the-
probability-of-future-annual-temperatu
• Oregon State Legislature, Wildfire Recovery and Emergency Shelters,
https://www.oregonlegislature.gov/courtney/Documents/E Board 10.23.20 Press
Release.pdf
• House Interim Special Committee on Wildfire Recovery, Funding Distribution (2021),
https://olis.oregonlegislature.gov/liz/2021I1/Downloads/CommitteeMeetingDocume
nt/250450
• Oregon State Legislature, House Bill 5006, Emergency Board Work Session
Recommendations (2021),
https://olis.oregonlegislature.gov/liz/2021R1/Downloads/CommitteeMeetingDocum
ent/246321

Data Table Sources

• FEMA FIDA 40449 4562
• DR-4562-OR Housing Impact Assessment
• 2020 Decennial Census Redistricting Data
• ACS 5-Year Estimates (2015–2019) – Most demographic data

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• ACS 5-Year Estimates (2014–2018) – SVI data
• ACS 5-Year Estimates (2011–2015) – LMI data
• OEM FEMA PA Report (February 2022)
• OEM HMGP Report (February 2022)

6.5 Important Definitions and Terms

Federally Used Acronyms
AMI: Area Median Income

CBDO: Community-Based Development Organization

CDBG: Community Development Block Grant

CDBG-DR: Community Development Block Grant – Disaster Recovery

CFR: Code of Federal Regulations

DRGR: Disaster Recovery Grant Reporting System

DUA: Disaster Unemployment Assistance

FEMA: Federal Emergency Management Agency

HCDA: Housing and Community Development Act of 1974, as amended

HMGP: (FEMA) Hazard Mitigation Grant Program. This program provides funding to
State, local, tribal, and territorial governments so that they can rebuild in a manner that
reduces or mitigates future disaster losses in their communities.

IA: (FEMA) Individual Assistance

LEP: Limited English Proficiency

LIHTC: Low-Income Housing Tax Credit

LMI: Low-to-Moderate Income

NFIP: National Flood Insurance Program

PA: (FEMA) Public Assistance. This program provides supplemental grants to State, tribal,
territorial, and local governments, as well as certain types of private nonprofits so that
communities can quickly respond to and recover from major disasters or emergencies.

RE: Responsible Entity

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RFP: Request for Proposal

SBA: U.S. Small Business Administration

SFHA: Special Flood Hazard Area

Underserved Communities: HUD defines “underserved communities” as populations

sharing a particular characteristic, as well as geographic communities, which have
been systematically denied a full opportunity to participate in aspects of economic,
social, and civic life. Underserved communities that were economically distressed
before the disaster include, but are not limited to, those areas that were designated as
a Promise Zone, Opportunity Zone, Neighborhood Revitalization Strategy Area, tribal
area, or those areas that meet at least one of the distress criteria established for the
designation of an investment area of the Community Development Financial Institutions
Fund at 12 CFR 1805.201(b)(3)(ii)(D).

URA: Uniform Relocation Assistance and Real Property Acquisition Act of 1970, as
amended

USACE: U.S. Army Corps of Engineers

Vulnerable Populations: HUD defines “vulnerable populations” as a group or community

whose circumstances present barriers to obtaining or understanding information or
accessing resources.

Oregon-Specific Acronyms
DEQ: Oregon Department of Environmental Quality

DLCD: Oregon Department of Land Conservation and Development

DOGAMI: Oregon Department of Geology and Mineral Industries

DR-4562: Oregon Wildfires and Straight-line Winds (incident period September 7, 2020 –
November 3, 2020)

ETART: Erosion Threat Assessment and Reduction Team

HSC: Housing Stability Council

ODHS: Oregon Department of Human Services

OED: Oregon Employment Department

OEM: Oregon Office of Emergency Management

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OHCS: Oregon Housing and Community Services

NHMP: Natural Hazards Mitigation Plan

RHNA: Regional Housing Needs Assessment

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