Potential Challenges to Targeting Low- and Moderate-Income Communities in a Time of Urgent Need: The Case of CDBG-DR in New York State after Superstorm Sandy

New York State received $4.5 billion in Community Development Block Grant-Disaster Recovery (CDBG-DR) funds after Superstorm Sandy. A major CDBG-DR requirement is to prioritize assistance to low- and moderate-income (LMI) populations. The state is spending two fifths of funds on community-wide (e.g., infrastructure) recovery activities. For these activities to be documented as LMI, a specified percentage of residents benefiting from them must be LMI. We explore the potential tension between addressing community recovery needs and prioritizing LMI assistance. Specifically, we develop a series of scenarios to estimate the likelihood that any community-wide activities will be documented as LMI in New York State. We find that documenting these activities as LMI is largely dependent on the underlying demographics of disaster-impacted areas. Additionally, as recovery activities increase in size, thereby impacting larger populations, they are less likely to be documented as LMI, potentially disincentivizing larger, more impactful investments. We recommend empirically based LMI targets for CDBG-DR grantees.