HPLN Frequently Asked Questions

What is HPLN?

HPLN is the shorthand name for the Housing Planning Grant Program in DOLA’s online grant portal system. HPLN stands for Housing Planning.

What type of entities are eligible to receive a Housing Planning Grant award?

Eligible entities include municipalities, counties, city and city-counties, councils of governments (COGs), regional planning commissions, and public entities formed by the voluntary agreements of local governments in a region.

How would a jurisdiction know if they are subject to the requirements of SB24-174?

Information about the subject jurisdiction requirements is on the DOLA site. 

• Housing needs assessments are required of the following local governments (except if they have experienced a 1% negative population change in the most recent decennial census):
  • Municipalities with more than 1,000 residents, 
  • Counties with more than 1,000 residents
• Housing action plans are required of local governments (except if they have experienced a 1% negative population change in the most recent decennial census):
  • With populations of 5,000 or more
  • With populations of 1,000 or more that participated in regional assessment; or
  • Deemed “rural resort communities” (as of January 1, 2024)
• Water supply and strategic growth elements are required in all municipal, county, and regional master/comprehensive plans except:
  • Municipalities, counties, and regions are not required to include a strategic growth element if they have not received funding to do so and are:
    • Municipalities with a population of 20,000 or less and have experienced 1% negative population change or with a population of 2,000 or less
    • Counties with a population of 20,000 or less and have experienced a 1% negative population change or have a population of 5,000 or less in the county’s unincorporated territory

Additionally, jurisdictions are encouraged to contact the Technical Assistance team to confirm which (if any) requirements a jurisdiction is subject to.

Could two or more jurisdictions partner on a grant application or project?

Yes! Municipalities or counties are encouraged to partner on multijurisdictional HNAs and may collaborate with housing authorities, COGs, or other applicable regional entities.

What qualifies as an eligible regional entity?

Councils of governments (COGs), regional planning commissions, and public entities formed by the voluntary agreements of local governments in a region are eligible to apply. "Regional” could also mean a county and its municipalities, or 2-3 municipalities, etc.

Can I use HPLN funding to revise an existing Housing Needs Assessment (HNA), Housing Action Plan (HAP), or Strategic Growth element of a comprehensive plan?

Yes, existing HNAs, HAPs, and Strategic Growth elements are eligible projects to align with the requirements of SB24-174 (§§ 24-32-3701 — 24-32-3711).

Can the Planning Grant Program fund a Housing Needs Assessment (HNA) and Housing Action Plan (HAP) together?

Yes, coordinating the development of a Housing Needs Assessment (HNA) and Housing Action Plan (HAP) as part of the same project is encouraged.  It is also an opportunity to ensure strategies are developed to align with data and ensure equitable outcomes through inclusive public outreach and engagement. 

Can Planning Grant funds be used to create a master development plan for an affordable housing project?

No. The funds must be used to develop or revise a Housing Needs Assessment (HNA), Housing Action Plan (HAP), and/or Strategic Growth element of a comprehensive plan. Local governments should contact their DLG Regional Manager or DOH Regional Development Specialist to discuss funding opportunities for pre-development planning work for a specific affordable housing development project.

Can Planning Grant funds be used to revise or create a full comprehensive plan?

No. Full comprehensive plans cannot be funded using HPLN funds. Only Water Supply & Strategic Growth elements may be funded using HPLN as part of the comprehensive plan. Guidance will be published in early 2026 for Strategic Growth and Water Supply. If applying for HPLN funding for strategic growth elements or water supply elements before guidance is available, applicants are strongly encouraged to contact DOLA Grant Staff to confirm project eligibility before applying.

Will our SB24-174-compliant HNA provide the information we need to complete a Rural Resort Reclassification Petition?

It’s important to remember that the AMI limits for the Rural Resort Reclassification Petition process are higher than the statutory requirements outlined in SB24-174. If you plan to apply for a Rural Resort Reclassification in the future, you will want to consider expanding your data collection process to include the higher AMI limits during your SB24-174 HNA update. HPLN funds cannot be used solely to update the AMI limits for the Rural Resort Reclassification Petition process. However, HPLN funds can support the development or remediation of an HNA to comply with SB24-174, which may include additional data elements. Please review the Rural Resort Petition Reclassification Petition Process page or contact Ashley Weesner for more information. 

We do not meet the population requirements for Housing Action Plans. However, we participated in and accepted a Regional Housing Needs Assessment. Is a Housing Action Plan now required?

If a jurisdiction has a population between 1,000 and 4,999 AND has participated in a Regional Housing Needs Assessment, then it is required to complete a Housing Action Plan. However, if a jurisdiction experienced at least 1% population loss in the most recent decennial census, then it is exempt from the requirement to complete a Housing Action Plan. The part of the statue referring to population loss overrides the requirement to complete a Housing Action Plan based on participation in a Regional HNA.

That being said, local governments may choose to participate in regional HNAs or Housing Action Plans, or do their own local HNA or Housing Action Plan. Housing Planning Grant Funds (HPLN) funds may support a Housing Needs Assessment and Housing Action Plan, whether or not it is required by SB24-174. DOLA recommends consulting with your staff attorney if you have further questions.

What are the public engagement requirements for HNAs and Housing Action Plans?

HNAs require a public meeting, and Housing Action Plans require a public hearing. These are separate requirements, and local governments should check with their legal team to verify what qualifies as a public meeting and a public hearing for their jurisdiction. 

If we are revising our HNA, will the public meeting we had for the original HNA suffice for the SB24-174 public meeting requirement?

If the local government had a public meeting to discuss the HNA when it was originally adopted, that would fulfill the public meeting requirement.  The local government or regional entity will need to include information about the format of the public meeting, whether it was before the local governing body (required by SB24-174), and forward any comments from that meeting. If the local government did not have a meeting that qualifies under SB24-174 (in front of the local governing body), then a new meeting is required.

How does a Regional Housing Action Plan work?

Plans are required to address both local elements, like zoning changes, and regional elements, such as what share of regional affordable housing should be within the local government's boundaries. There are a dozen or so requirements for what must be in the Housing Action Plan. These requirements are covered in the new Housing Action Plan Guide linked here, which also provides context on how to provide each of the required sets of information.

The Regional Housing Action Plan may be led by the local jurisdiction or a regional entity like a Council of Governments. The Housing Action Plan Guide contains information on the pros and cons of regional and local Housing Action Plans. Generally, regional Housing Action Plans are more expensive, take longer, and require more coordination. However, participants can pool their resources and create better regional solutions.

Whether you do a local Housing Action Plan or are part of a regional one, the Housing Action Plan must be approved at a public hearing before the local government's governing body. For a regional Plan, that means each government in the Plan must have its own hearing.. DOLA recommends following your own adopted procedures for a public hearing, and as long as you meet that threshold, you will comply with the hearing requirement. 

A Regional Housing Action Plan can be one document as long as it contains the information for each jurisdiction as required by SB24-174. The Regional Housing Action Plan may be similar to a book with different chapters, each chapter covering the same required material, but with an additional overarching approach that includes regional needs and plans. 

There are other public engagement and posting requirements for a Housing Action Plan, and these are also covered by the Housing Action Plan Guide. 
 

What is the match requirement?

A minimum of 25% local match of the total project cost is required. The specific match amount is listed in your grant agreement. Local match may include a financial commitment from partners (e.g., COGs, housing authorities). In-kind match (e.g., staff time) does not count towards the match requirement. Please note that any costs that are ineligible for reimbursement cannot be used to meet match requirements.

Can you show an example of a project budget and how to calculate local match?

To clarify, the 25% match is based on 25% of the total project cost, not 25% of the grant request amount. The table below shows two different example scenarios where the grant request reflects 75% of the total project cost, while the local match represents 25% of the total project cost.

• Grant awards will be made in whole numbers. Figures in your budget should generally be rounded up to reflect the project cost in whole numbers.
• Most projects will have only one budget line item (consultant services).
• The application includes space for a budget narrative description. The budget narrative should describe and explain how funds will be spent.

How soon would we have access to these grant funds, if awarded?

Awards are usually announced approximately 4 weeks after the grant application
deadline, and grant agreement processing typically takes 3-8 weeks, depending on how many awards are being processed and how quickly the grantee provides required paperwork. Therefore, it will be at least 8 to 12 weeks after the application process before new grantees will be able to begin project implementation.

Note: Any expenses incurred before the execution of the grant agreement cannot be reimbursed.

Are we allowed to take indirect using the de minimis or our NICRA?

No. Indirect costs are not eligible costs for the Housing Planning Grant program.

Can we hire new employees with grant funds?

No. New staff salaries and fringe benefits are not eligible costs associated with this grant. However, funding through the Local Capacity Planning Grant (LPC) may be available to fund new staff if it is a previously unbudgeted position with primary job duties that are directly related to the scope of the local government’s LPC grant award.

Can Housing Planning Grant funds cover the time existing employees work on the HNA, HAP, or strategic growth element?

No. Existing staff salaries and fringe benefits are not eligible costs associated with this grant.

We currently have a contract in place with a consulting firm for land use/development/zoning code updates. Can we retain the same consultant to perform the work for our Housing Planning Grant without rebidding or issuing a new RFP?

It may be acceptable for a local government grantee to use a previously engaged consultant from a different project (e.g., general land use code update) on the HPLN Planning Grant work.

There needs to be a nexus between the previously procured/ongoing work (e.g., general land use code update) and the work that will be funded by the HPLN grant. Similarly, the consultant needs to be appropriate and qualified for the HPLN work.

The applicant needs to provide DOLA with documentation of their original procurement process for getting the consultant as part of the awarding and contracting documentation. The documentation must clearly explain that because a qualified consultant was recently retained to do similar work, the local government doesn't need to rebid the work.

It will be important for the consultant to give the work completed under the HPLN contract a different project number (for invoice purposes) that delineates the HPLN contract work from the original work. DOLA will look for this (as well as work dates) when reviewing reimbursement requests. Invoices need to be clear on which line items apply to the HPLN contract work. It's the responsibility of the local government grantee to ensure that reimbursement request documentation clearly shows what applies to the grant contract and what doesn't. For example, if there's a consultant invoice with multiple project numbers, the local government should redact or otherwise strike the work irrelevant to the HPLN grant.

Will there be a provided list of consultants to do the HPLN work?

DOLA is currently working with the Colorado Chapter of the American Planning Association (APA) to generate a list of consultants to assist HPLN applicants. 

When will guidance be available for Housing Action Plans and Strategic Growth elements?

DOLA is currently working on preliminary guidance. However, final guidance will not be provided until Summer 2025 for HAPs and Fall 2025 for Strategic Growth elements. The Technical Assistance staff will be unable to provide a thorough courtesy review of materials provided before final guidance is published.

After the Housing Needs Assessment (HNA) statutory deadline of December 31, 2026, how often are the HNAs required to be updated?

Every six years per statutory requirements (C.R.S. 24-32-3701 (4)).

How do we submit an application?

Potential applicants may indicate their interest in applying by completing this one-minute survey. Interested parties may also email ashley.basham@state.co.us to get feedback on the proposed project and technical assistance before applying.

The grant application must be submitted through the DLG Grants Portal. You will need to create an account to access the Notice of Funding Available (NOFA) for this grant program. An instructional video tutorial is available on DOLA's YouTube.

The list of application questions is posted on the DLG Grants Portal, both as a template to help applicants draft their application and as a PDF that shows the online application format. These items are provided as a helpful tool, but applications must be submitted through the grants portal.

What are the scoring criteria for this grant program? 

Projects that address the Housing Needs Assessment (HNA) and Housing Action Plan (HAP) requirements of SB24-174 (§§ 24-32-3703 - 24-32-3705) will be prioritized in early funding rounds, though other project types are eligible for consideration.

The scoring criteria will also weigh the applicant’s readiness, support from local leadership, organizational capacity and experience, SB24-174 applicability, plans for inclusive community engagement, the multijurisdictional nature (if applicable), and geographic diversity. The Evaluation Criteria are published in the HPLN Program Guidelines with additional descriptions.

What kind of specific language do local governments need to have within their Resolution for the “Official Action” section of the grant application form?

The intent of the "Official Action" section of the application is to confirm that the elected body is both aware of and approves of the intent to apply for grant funds and commits to the cash match (and the proposed project therein). Official action could be a motion by the Board that is made and approved in the meeting minutes. Another option is where authorization has been delegated. Some jurisdictions will give a Town/City/County Manager the authority to submit applications up to a certain dollar amount without going to the Board; in that case, applicants would submit a letter documenting this approval and noting the authorization.

If the applicant is a regional entity such as a COG or Housing Authority, the applicant must submit a letter documenting approved matching funds and noting the authorization from the governing board.

Does the date of official action need to be before the application is submitted? What if our Board/Council meeting is a few days after we want to apply?

Evidence of official action must be provided before the grant award. It is acceptable to explain in the grant application that official action is scheduled after the application deadline but will occur before the grant award. In this scenario, documentation of official action must be provided to DOLA staff as soon as it becomes available.

I checked the box to add a participating jurisdiction on the DLG Portal Application, but it would not populate the field. I expected the jurisdiction name to populate the field that says “—Select Other Eligible Organizations—“, but it didn’t appear. Is something wrong?

Nothing is wrong. The jurisdiction will be present when you submit, as long as their box is checked in the dropdown. It will appear on the application once you submit it.

Can we fund a Market Study with HPLN funds?

Aspects of Market Studies, Market Analyses, and/or Housing Studies may be an appropriate use of HPLN funds if the data collected directly informs HPLN deliverables. The study must include sufficient inputs and outputs required by SB24-174. Applicants must demonstrate a clear correlation between the requirements in SB24-174 and the study.

How long will this funding be available?

Funding for the Housing Planning Grant Program will remain available until the initial allocation of $12,000,000 is obligated and spent. Additional funding is not guaranteed. 

Return to Housing Planning Grant Program page