Only 6.1% of Puerto Rico's $8.28 billion mitigation fund has been spent

On September 16, 2026, the PDF that needs to be placed next to the CDBG-DR Expenditure Report (cousin 756) is the CDBG-MIT Grant Financial Report as of April 1, 2026. It is issued by the same Office of Community Planning and Development from DRGR, but the program is not Disaster Recovery: it is Mitigation. HUD created this report in August 2022. The CDBG-DR Reports page describes it as “A list of all active CDBG-MIT (Mitigation) grants, sorted by grantee. Identifies grant award amount, grant balance and expenditure percentage.” Three columns, three labels. Grant Award ≠ Grant Balance ≠ Expenditure Percentage. Expenditure Percentage, in this report, is the metric that HUD prints; we do not rename it as “6.1% of the Island’s resilience has already been built” or as a disbursement to the beneficiary.

The Puerto Rico row is a single one: grantee name Puerto Rico, grant number B-18-DP-72-0002, Grant Award $8,285,284,000.00, Grant Balance $7,776,135,781.27, Expenditure Percentage 6.1%. The suffix of the grant number matters. In the CDBG-DR Expenditure Report of February 1, 2026, the large recovery grant is B-18-DP-72-0001 (Award $8,220,783,000, Drawn 45.3%). Here, at MIT, the grant is B-18-DP-72-0002. They are different instruments: one DR, the other MIT; one 0001, the other 0002; one with Drawn % from one report, the other with Expenditure Percentage from another. Adding them and titling “Puerto Rico has $16 billion from HUD” would be double counting programs. This note does not add up.

The 6.1% Expenditure Percentage, with a Grant Balance of $7,776,135,781.27 against an Award of $8,285,284,000.00, is the snapshot that HUD provides on April 1, 2026. We do not calculate on our own a "spent = award − balance" to contradict or "confirm" the 6.1%: the report already publishes the three columns. If an analyst subtracts, they should label the subtraction as their own arithmetic, not as a HUD figure. The 6.1% is also not directly comparable on a term-by-term basis with the 45.3% Drawn of grant DR 0001: these are different reports, different methodologies (the DR Financial Report uses On Pace / Slow Spender; the MIT report, on this single-page document, does not include that classification). Comparing 6.1% with 45.3% and concluding that "MIT is doing worse than DR" requires a methodology note that this edition does not pretend to provide.

The regulatory context of that grant is in the notices hub (cousin 759), not in the financial PDF. The initial AAN for CDBG-MIT is 84 FR 45838 (August 30, 2019). The Third CDBG-Mitigation Allocation Public Law 115-123 appears as 85 FR 4676 (January 27, 2020), Puerto Rico ONLY. The Housing mitigation Action Plan—and the partial approvals of 2021 that HUD filed in its press room—is the programmatic document; the April 2026 Financial Report is the thermometer of award/balance/expenditure percentage. Partial approval of an Action Plan ≠ full line of credit ≠ grant Expenditure Percentage. Whoever covers mitigation (watersheds, relocation, resilient infrastructure, energy hardening with MIT seal) has to ask Housing which DRGR activities feed the 6.1%, not invent a list of dams.

The MIT table of April 1, 2026 fits on one page and allows comparison of grantees without leaving the PDF. Texas-GLO B-18-DP-48-0002 shows Award $4,297,189,000.00, Balance $2,845,764,367.84, Expenditure Percentage 33.8%. Louisiana B-18-DP-22-0001: Award $1,213,917,000.00, Balance $969,633,877.10, 20.1%. Virgin Islands B-18-DP-78-0002: Award $774,188,000.00, Balance $588,475,396.66, 24.0%. Florida B-18-DP-12-0002: Award $633,485,000.00, Balance $463,399,145.97, 26.8%. Puerto Rico, with the highest Award on the sheet, has the lowest Expenditure Percentage among those large pairs, according to HUD columns. That comparison is lawful if the report label and the cut-off date are maintained. It is not lawful if translated to “the Virgin Islanders execute four times better” or to a moral ranking of governments.

The footnote of the PDF notes “*Funds were De-Committed” next to Wisconsin B-19-DT-55-0001 (Award $980,000.00, Balance $980,000.00, 0.0%). De-committed ≠ de-obligated from FEMA PA ≠ recaptured by Congress. It is the note that HUD puts on its own sheet. It serves as a reminder that an Award can be moved. The Puerto Rico grant, in this report, does not have an asterisk.

Rules for the September 16 edition. (1) Cite B-18-DP-72-0002, not 0001. (2) Cite April 1, 2026, not the February Expenditure Report. (3) Leave Grant Award, Grant Balance, and Expenditure Percentage in HUD's words. (4) Do not mix this 6.1% with the 92 percent of incomplete construction projects from OIG-25-39: one is HUD's CDBG-MIT, the other is FEMA grid PA. (5) When the September 1 or October 1, 2026, package is released on hud-partners/community-cdbg-dr-reports, replace the cutoff; do not recycle April as if it were the current month. Cousin: 756. Topic: economy. Primary source: CDBG-MIT Grant Financial Report, April 1, 2026, on hud.gov.