(concurring):
I had occasion, earlier this Term, to compare some of the laws we are called upon to interpret to King Minos’s labyrinth in ancient Crete, Lok v. I.N.S., 548 F.2d 37, 38 (2d Cir. 1977). Surely this is another case in point. Judge Oakes in his opinion for the panel found the “expected to reside” estimate the lynchpin of the statutory scheme, and the principal means by which the legislative objective of spatial deconcentration of low-income housing may be achieved. Hartford v. Glastonbury, 561 F.2d 1032, 1035-1036 (2d Cir. 1976). The majority, in contrast, characterizes it as merely “a relatively very small part of a very large application”, supra at 1049. The facts before us do not require a choice between these two radically different views of the statutory pattern. Nor do I understand the majority’s decision to be based on its evaluation of the importance of the “expected to reside” figure. I would, therefore, reverse without intimating any view concerning the general legislative pattern. At best an eagerness to characterize the statute will be treated as obiter dictum in future cases; at worst, we risk prejudging situations yet unforeseen.
The test we must apply to measure standing is a deceptively simple one: is there a substantial likelihood that the City of Hartford or the individual appellees will benefit personally from the injunction they seek? Simon v. Eastern Kentucky Welfare Rights Organization, 426 U.S. 26, 96 S.Ct. 1917, 48 L.Ed.2d 450 (1976). The decree entered by the district court afforded the suburban towns two options: to submit a revised application for a community development grant, including a realistic “expected to reside estimate,” or to forego HUD funds for FY 1975. I believe that where, as here, the relief sought permits the defendant two entirely practical options, Simon requires the plaintiff to demonstrate a substantial probability of benefit regardless of which course of action the defendant elects.
The appellees’ principal objective in commencing this lawsuit was; of course, to compel the suburban towns to comply with the law. Hartford maintains that it will receive the very benefit Congress intended if the suburban towns successfully reapply for community development grants: relief from the burden flowing from concentration of low income people, all too often members of minorities, in the central city.
Considered abstractly, this argument has appeal. In our system of coordinate powers, the courts must ordinarily respect legislative judgments concerning the efficacy of statutes. See Katzenbach v. Morgan, 384 U.S. 641, 652-56, 86 S.Ct. 1717, 16 L.Ed.2d *1053828 (1966); Cox, The Role of Congress in Constitutional Determinations, 40 U. Cincinnati L.Rev. 199 (1971). Any other policy would require the judiciary to indulge in an independent assessment of the wisdom of Congressional action. To declare a duty prescribed by Congress too “speculative” to be enforced by an aggrieved litigant is tantamount to saying it shall not be enforced at all. Therefore, although there should not be blind deference to legislatures, see Linda R. S. v. Richard D., 410 U.S. 614, 619, 93 S.Ct. 1146, 1149, 35 L.Ed.2d 536 (1973) (involving “special status of criminal prosecutions in our system”), I would be exceedingly loathe to label “speculative” a chain of causation that, on the appellees’ interpretation of the applicable law, Congress must have considered plausible.
Under the unusual circumstances presented here, however, it is not necessary to question congressional factfinding to conclude that neither Hartford nor the individual appellees would benefit from compelling the suburbs to comply with the Act in 1975. I must emphasize that the action of HUD challenged in this suit is extremely limited. HUD did not permanently waive the “expected to reside” requirement, but rather approved first year applications without the needed figures.1 Accordingly, general statements that the “expected to reside” figure is critical to achieving the overall statutory purpose of promoting de-concentration of low-income housing are beside the point: the essential issue is whether Hartford will benefit from the desired revision of the suburbs’ FY 1975 application for community development funds. It is impossible to show that any housing units are likely to be built as a result of the Towns’ eventual compliance with the “expected to reside requirement” in their FY 1975 application. Indeed, since the suburbs received the maximum available subsidies for low and moderate income housing that year, it is inconceivable that submitting an adequate “expected to reside” estimate could have any effect on deconcentration of housing for the poor in the Hartford metropolitan area.
A great deal has been made of the possibility that the City of Hartford will be near the front of the queue for funds available for reallocation as a result of East Hartford’s failure to reapply. But, as Judge Meskill points out, standing cannot be established by hindsight. It must be assessed at the outset of a lawsuit. See, The Supreme Court, 1975 Term, 90 Harv.L.Rev. 56, 210 (1976). It would be absurd — and wasteful — to permit litigation to be maintained in the mere hope that “a constitutional ‘controversy’ [will emerge] before the appellate process is complete.” Supra at 1051-1052, n. 3. Accordingly, I believe that a plaintiff must demonstrate a likelihood of benefit wholly apart from a defendant’s response to the district court’s decree. Where, as here, compliance with the conditions sought in the lower court’s order would be of no tangible value to the plaintiffs, the possibility that the defendants will fail to comply does not justify proceeding with the lawsuit. Thus, I do not believe that the mere chance Hartford will receive a portion of the $440,000 available for reallocation as a result of East Hartford’s refusal to reapply for a community development grant for FY 1975 — a chance that seems minimal in any event — would suffice *1054to confer standing on Hartford or its low-income residents.
OAKES, Circuit Judge (dissenting), with whom Judges SMITH, FEINBERG and GURFEIN concur:
The anomalies in this case might cause a lay observer to question the rationality of the judicial process. Plaintiffs’ principal purpose in bringing suit was to stop a federal agency (HUD) from violating the law (the Housing and Community Development Act of 1974 or HCDA) in a manner adverse to plaintiffs’ interests. Following a district court ruling that HUD had indeed violated the law, the agency did not appeal; instead, it revised its regulations (for fiscal years after 1975) to meet the plaintiffs’ objections. Having achieved this goal by virtue of bringing suit, plaintiffs now are told by the en banc majority that they lacked a sufficient interest in the outcome at the time they filed the suit and hence that they lacked standing to sue. This holding becomes particularly anomalous when one considers that, as Judge Meskill’s plurality opinion recognizes, at 1051 n. 3, it is more likely today than when the suit was initiated that Hartford, had it been successful on the standing issue, would have received reallocated fiscal year 1975 funds as the result of the suit it brought. In view of what has actually occurred as a result of the suit, the majority’s conclusion that no cognizable interest existed at the suit’s outset requires at the very least careful scrutiny-
I believe that both the plurality opinion and Chief Judge Kaufman’s concurring opinion misconceive the nature of this suit. They also fail to appreciate the underlying purpose of the statute under which the suit was brought. But more important, perhaps, they read into the law of standing a test far more restrictive than any devised by the Supreme Court, a test that could threaten the viability of all litigation aimed at illegal agency action. In an area of the lav/ that many commentators have decried as confused, see, e. g., K. Davis, Administrative Law Text § 22.01 (3d ed. 1972); Albert, Standing to Challenge Administrative Action: An Inadequate Surrogate for Claim for Relief, 83 Yale L.J. 425, 425 n. 1 (1974); Lewis, Constitutional Rights and the Misuse of “Standing,” 14 Stan.L.Rev. 433, 434 (1962); Scott, Standing in the Supreme Court — A Functional Analysis, 86 Harv.L. Rev. 645, 645 n. 1 (1973), and that Professor Paul Freund has called “among the most amorphous in the entire domain of public law,” Hearings on S. 2097 Before the Subcommittee on Constitutional Rights of the Senate Committee on the Judiciary, 89th Cong., 2d Sess., pt. 2, at 498 (1966), the two opinions of the en banc majority have succeeded only in further muddying the waters. Accordingly, I dissent.
I.
The Nature of the Suit
The way in which a suit is characterized has much to do with whether plaintiffs are deemed to have standing. If the purpose of the suit is misperceived, the interest of the plaintiffs is likely to be misconceived, since the latter turns on the former and the former shapes the latter. Here the majority fails to examine the suit’s principal purpose and, as a result, misunderstands the nature of the plaintiffs’ interest.
The majority views this suit as if its principal purpose were to prevent the defendant towns from receiving fiscal 1975 grants under the HCDA. They rely on the fact that the towns had an option under the injunction ultimately issued by the court below, an option of revising their Housing Assistant Plans (HAPs) with regard to the expected-to-reside (ETR) figures, thereby qualifying to seek dissolution of the injunction and release of the grant funds originally sought. On this basis the majority concludes that the plaintiffs could not have had a substantial probability of benefiting from the suit. But the suit was not brought to prevent the defendant towns from receiving grant monies, nor was it brought to obtain revision of one particular year’s ETR figures for these towns. Rather, it was brought with the goal of halting the violation by HUD, a federal administrative *1055agency, of the HCDA, an Act of Congress that the agency was charged with enforcing for the benefit of cities like Hartford.
II.
The Statute and the City of Hartford
HUD officials were initially the only defendants named in the complaint, which alleged that they had failed to meet their obligations under the HCDA. Because, at the time the suit was filed, HUD had already issued letters of credit to the towns whose grants were being challenged, HUD and the towns moved to join the towns as defendants, and the district court granted the motions, see City of Hartford v. Hills, 408 F.Supp. 879, 882 (D.Conn.1975) (opinion granting preliminary injunction). But the entry of the towns, while necessary to ensure an adequate remedy, did not change the nature of the suit as one aimed at violation of law by a federal agency. While the towns may have had the option on which the plurality and concurring opinions put such emphasis — that of revising their HAPs rather than forfeiting grant funds— HUD had no options; it had to enforce the statute as written. That it was not doing so at the time the suit was filed is clear from its failure to appeal and its adoption of explicit ETR regulations for post-1975 grants, 24 C.F.R. § 570.303(c)(2)(i) and (ii) (1976); see 41 Fed.Reg. 11128 (1976), as well as from Judge Blumenfeld’s ruling below, upheld by the panel majority.1 Had the plaintiffs not filed suit, all indications are that 1975 grants would have been disbursed illegally to the towns; moreover, HUD might well have continued its 1975 policy for a period stretching into the indefinite future. It was these abuses that plaintiffs, particularly the City of Hartford, sought to prevent by filing suit, and it is with this purpose in mind that any analysis of plaintiffs’ interest in the suit must proceed.
Once it is accepted that the plaintiffs’ principal objective in filing suit was to secure compliance by HUD with the law, analysis begins with the question why the plaintiffs cared about this objective. The panel majority opinion answers this question in some detail as to both the City and the low-income plaintiffs. I will not repeat that analysis here, but further examination of the interest of the City in particular is necessary in light of the en banc plurality and concurring opinions. To understand how Hartford would benefit from HUD insistence on adequate HAPs from Hartford’s suburbs, one must first understand both the nature of the City of Hartford and the structure of the HCDA.2
Based on uncontested affidavits and testimony, the district court found that “Hartford is one of the American central cities, suffering from a concentration of lower-income persons . . . .” City of Hartford v. Hills, 408 F.Supp. 889, 893 n. 14 (D.Conn. 1976) (opinion granting permanent injunction). The court noted inter alia the large number (over 50%) of Hartford residents receiving government assistance, the high unemployment rate in the city (13.6%), and the high minority population (35.5% overall; 80% of the school population). Id. The court characterized “[t]he housing situation in Hartford [as] bleak”, basing this assessment on the large number of “substandard, deteriorating or dilapidated units” and on the “critical housing shortage in the City, resulting in severe overcrowding.” Id. at 893-94 n. 14. Comparing the condition of Hartford in these respects to that of its *1056suburban towns, the court found a “marked contrast.” Id. at 894 n. 14. Since these findings are not in any way challenged here, no more need be said about the characteristics and problems of the City of Hartford; one doubts if the staid prose of an appellate opinion could accurately portray them in any event.
The HCDA and its legislative history leave little doubt that the Act was designed to assist cities in the precise position in which Hartford finds itself. The Act begins with a congressional finding that urban problems arise from, inter alia, “the concentration of persons of lower income in central cities”. 42 U.S.C. § 5301(a)(1) (Supp. V 1975). The “primary objective” of the Act — not some collateral purpose — is declared to be “the development of viable urban communities,” with “specific objectives” including “the elimination of slums and blight” and of “conditions which are detrimental to health, safety, and public welfare” and “the reduction of the isolation of income groups within communities and geographical areas . . . through the spatial deconcentration of housing opportunities for persons of lower income.” Id. § 5301(c) (emphasis added). These declarations leave very little doubt about congressional intent, and the legislative history reinforces the conclusion that the design of the Act was to assist cities like Hartford. The Senate Report notes Congress’s desire “to insure that Federal funds ... be used with a priority to eliminate slums and blight and to upgrade and make the Nation’s cities more livable, attractive and viable places in which to live.” S.Rep. No. 93-693, 93d Cong., 2d Sess., reprinted in [1974] U.S. Code Cong. & Admin. News pp. 4273, 4274. The Report also emphasizes the importance of “urban-suburban cooperation on housing and renewal”. Id. at 4320.3
There is thus little question that the HCDA in general was designed to assist cities like Hartford. Within the HCDA framework, moreover, the ETR estimate required in the HAP plays a crucial role. Community development grants cannot be made by HUD unless an application has been submitted, 42 U.S.C. § 5304(a) (Supp. V 1975), and the application must include a HAP that, inter alia, “assesses the housing assistance needs of lower-income persons . residing in or expected to reside in the community.” Id. § 5304(a)(4)(A). While certain other application requirements may be waived by HUD, the HAP requirement may not be waived. See id. § 5304(b)(3), (4); 408 F.Supp. at 898, 901. Both Congress and HUD have emphasized the importance of the HAP. See H.R.Rep. No. 93-1114, 93d Cong., 2d Sess. 3 (1974), quoted in panel op., ante, at 1036 n. 8; HUD Notice of Proposed Rulemaking, 41 Fed.Reg. 2348 (1976), quoted in panel op., ante, at 1036 n. 9.
The significance of the ETR figure is apparent when the HCDA’s “carrot and .stick” approach is considered. All communities, wealthy as well as poor, are interested in obtaining community development funds, which may be used for such local needs as street lights, playgrounds, and senior citizen centers. See 42 U.S.C. § 5305(a) (Supp. V 1975); 24 C.F.R. § 570.200(a) (1976). In order to obtain these funds under the Act, however — and this is what is of critical importance — “a locality must address its need for lower-income housing,” United States Commission on Civil Rights, Twenty Years After Brown: Equal Opportunity in Housing 32 (1975). This need *1057simply cannot be addressed without an accurate estimate of the number of lower-income persons expected to reside in the locality. The ETR figure is tied directly to housing assistance by 42 U.S.C. § 1439(a) (Supp. V 1975), which allows either a locality or HUD to reject an application for federal housing aid on the ground that it is inconsistent with the locality’s HAP.
Once the operation of the statute and the characteristics of Hartford are understood, the nature of Hartford’s injury from the suburban towns’ submission of zero or inadequate ETR figures becomes clear. As a central city, Hartford has been given by the HCDA “a statutory right or entitlement,” Warth v. Seldin, 422 U.S. 490, 514, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975), to cooperation from its suburbs (at least those applying for community development grants) with regard to the deconcentration of lower-income persons and the elimination of slums and blight, 42 U.S.C. § 5301 (Supp. V 1975). An alleged deprivation of such a right creates standing. Warth v. Seldin, supra, 422 U.S. at 514, 95 S.Ct. 2197. By submitting zero ETR figures, the defendant towns significantly reduced the likelihood that any deconcentration beneficial to Hartford would occur.4 For example, were a developer to apply for federal aid in building lower-income housing in one of the towns, the town could legitimately oppose the request — and thus effectively block construction of lower-income housing — simply by objecting under 42 U.S.C. § 1439(a)(2) (Supp. V 1975) that such housing is inconsistent with its'approved HAP, which indicates that no additional lower-income persons are expected to reside in the town. The Act was designed to prevent abuses of this sort, and it seems probable that no entity other than a city like Hartford would be interested in halting such violations of the letter and spirit of the law, at least when HUD is countenancing these violations. In short, I believe that Hartford stood to benefit from this suit both by forcing a change in overall HUD policy — a benefit that has been realized — and by forcing its suburbs to assist with the HCDA’s spatial deconcentration objective in return for their receipt of community development funds — a benefit that, to the extent ETRs have been revised upward in the resubmitted applications, also has been realized.
HL
The Law of Standing
The plurality and concurring opinions both adopt a standing test based on the fact that, under the district court’s injunction, the defendant towns could either revise their ETR figures or forego community development grant funds. From this the plurality concludes, citing Warth v. Seldin, supra, 422 U.S. at 504, 95 S.Ct. 2197: “Inasmuch as the first alternative would produce no benefit for plaintiffs, it is immaterial *1058whether they might benefit from the second . . . • Ante, at 1051. The concurring opinion’s similar conclusion is said to be compelled by Simon v. Eastern Kentucky Welfare Rights Organization, 426 U.S. 26, 96 S.Ct. 1917, 48 L.Ed.2d 450 (1976). Parts I and II of this dissent demonstrate how the factual premise of both opinions is erroneous. Here I point out that no legal analysis is offered in either opinion to explain how Warth and Simon, in which plaintiffs sought invalidation of legislative or executive rules, are relevant to a case involving a district court injunction that gives the defendants a choice of actions. Both cited cases do, of course, contain general language about the necessity for a plaintiff to show “a substantial probability” of benefit from judicial intervention, Warth, 422 U.S. at 504, 95 S.Ct. 2197, or “an injury to himself that is likely to be redressed by a favorable decision”, Simon, 426 U.S. at 38, 96 S.Ct. at 1924. But these unexceptionable propositions hardly help to resolve this case; they are simply the starting point of analysis.
Even assuming arguendo that the option given the localities is relevant to Hartford’s standing to challenge HUD policy — as discussed in Part I supra, the suit’s principal purpose was to force a change in a HUD policy that was adversely affecting the City of Hartford — I cannot accept the factual premise that upward revision of the defendant towns’ ETR figures would produce no benefit for Hartford. I have discussed the way in which Hartford would benefit in Part II. It is true that the injury is indirect, but the Supreme Court recently reaffirmed that such injury is sufficient for standing purposes if it is “fairly traceable to the defendant’s acts or omissions”, Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252, 260, 97 S.Ct. 555, 561, 50 L.Ed.2d 450 (1977). Here the injury to Hartford is traceable to the towns’ submissions and HUD’s approvals of inadequate HAPs, as discussed in Part II. It may also be true that the injury to Hartford is not directly measurable in dollars and cents; “[i]t has long been clear,” however, that other kinds of injury than the purely monetary will support standing, id. Finally, the injury alleged plainly has “that ‘essential dimension of specificity’ that informs judicial decisionmaking.” Id., quoting Schlesinger v. Reservists Committee to Stop the War, 418 U.S. 208, 221, 94 S.Ct, 2925, 41 L.Ed.2d 706 (1974). Hartford did not seek an abstract change in HUD policy, but rather a specific remedy with regard to particular grant applications made by its suburbs whose applications did not conform to the statutory requirements.
I therefore restate that the factual premise of the majority’s approach is unsupportable. But even if it is assumed ar-guendo that Hartford would not benefit from revision of the ETR figures, there nevertheless was a sufficient probability of Hartford’s obtaining reallocated funds to support the City’s standing here. The injunction blocked over four million dollars in grant funds to seven towns. A prediction made when the suit was filed would have to have acknowledged a “substantial probability” that at least some of those funds would be reallocated to Hartford as the result of a town choosing not to, or being unable to, submit an acceptable ETR figure, and indeed time has shown that monies would but for the instant decision en banc have become available for reallocation.5 Hartford’s eligibility therefor is discussed in the panel majority opinion. Ante, at 1037; see 408 F.Supp. at 885-86. It matters not at all how small the predicted sum might be, as long as “a distinct and palpable” benefit were involved. Warth v. Seldin, supra, 422 U.S. at 501, 95 S.Ct. 2197; see K. Davis, Administrative Law of the Seventies § 22.-02-10, at 507 (1976) (“The line is not between a substantial injury and an insubstantial injury. The line is between injury and no injury.”).
As in Arlington Heights, supra, 429 U.S. at 261, 97 S.Ct. at 561, “[a]n injunction would not, of course, guarantee” that grant funds would be reallocated; “uncertainties” would remain. But the Supreme Court in *1059Arlington Heights made clear that such uncertainties do not defeat a standing claim. Id. See also United States v. SCRAP, 412 U.S. 669, 93 S.Ct. 2405, 37 L.Ed.2d 254 (1973). The plurality and concurring opinions appear to demand more, something approaching a certainty that funds would be reallocated to Hartford. There is scarcely any lawsuit that involves a certainty of recovery, from administrative law to zoning. Such a standard has no support in Warth or Simon, much less in the more recent Arlington Heights; its adoption here significantly raises the barriers a litigant must cross in attempting to challenge illegal governmental action.
Hartford has shown injury to itself and a probability of benefit from judicial inter-' vention. It should therefore be held to have standing. To deny Hartford standing means, in Chief Judge Kaufman’s words, that “it is unlikely that there could ever be a plaintiff who will be allowed access to the courts to challenge HUD’s abdication of its congressionally-imposed duty.” Evans v. Lynn, 537 F.2d 571, 611 (2d Cir. 1976) (opinion dissenting from en banc decision), cert. denied, 429 U.S. 1066, 97 S.Ct. 797, 50 L.Ed.2d 784 (1977). Today’s holding, in short, “give[s] the Executive a silent veto not provided in the Constitution.” Id. (Gurfein, J., dissenting from en banc decision). I dissent.-
. The dissent asserts surprisingly, “Had the plaintiffs not filed suit, . HUD might well have continued its 1975 policy for a period stretching into the indefinite future.” Infra at 1055. But HUD’s policy in years subsequent to 1975 is not at issue in this lawsuit. No one until now has ever questioned HUD’s determination to require the expected-to-reside estimate as soon as an appropriate method of calculation was devised, and there is no evidence before us that HUD even considered its suspension of the requirement past fiscal 1975.
In view of the insistence in the dissenting opinion on a precise formulation of the interest at stake in this lawsuit, I find Judge Oakes’s broad formulation particularly troubling. It is impossible to avoid making standing doctrine more confusing than it already is if every case is seen as posing, in the most general terms, a mortal challenge to judicial review of administrative action. It is possible for standing cases to be of less than earthshaking importance. I believe the issues unnecessarily raised by both the plurality opinion and the dissent should be left for another day.
. The en banc majority does not, of course, reach the merits, as it finds a lack of standing. This opinion will not comment further on the merits, which are analyzed in the panel majority opinion, ante.
. I am puzzled by the concurring opinion’s attempt to “reverse without intimating any view concerning the general legislative pattern.” Ante, at 1052. The essence of Hartford’s claim here is that it was deprived of legal rights that were created by the HCDA, as discussed infra. The allegation of such a deprivation confers standing on the injured party. Warth v. Seldin, 422 U.S. 490, 514, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975); Linda R. S. v. Richard D., 410 U.S. 614, 617 n. 3, 93 S.Ct. 1146, 35 L.Ed.2d 536 (1973). One cannot determine what rights Hartford had under the HCDA without careful examination of “the general legislative pattern.”
. In light of this statement and the Act’s reference to “the isolation of income groups within communities and geographical areas”, 42 U.S.C. § 5301(c)(6) (Supp. V 1975), it is little short of incredible that the plurality opinion expresses doubt whether the HCDA was intended to promote intercity spatial deconcen-tration, ante at 1050 n. 2. See also 42 U.S.C. § 5301(a)(1) (Supp. V 1975) (congressional concern about “the concentration of persons of lower income in central cities”); id. § 5304(a)(1) (development planning to be on “areawide” basis); id. § 5304(a)(4)(C) (lower-income housing to be located with objective of “avoiding undue concentrations of assisted persons in areas containing a high proportion of low-income persons”). If nothing else were clear, it is at least clear that the Housing and Community Development Act of 1974 was not just another simple form of revenue-sharing with suburbs walling out the cities’ poor.
. The plurality and concurring opinions both mention that there were no more fiscal 1975 Title II funds available for the defendant towns, even if their ETR figures for that year were revised upward. The location and types of lower-income housing, however, might very well be affected by appropriate revision of the ETR figures; certainly Congress thought that there would be some impact when it required the ETR estimates. Moreover, the chronological relationship between the Title I Hap and the Title II housing grants is unclear on the record before us. It appears from the regulations that Title II funds for at least two fiscal years after 1975 may be based on the 1975 HAPs. The community development plan summary submitted with the application is a “three-year plan which specifies both short and long-term community development objectives which have been developed in accordance with areawide development planning and national urban growth policies.” 24 C.F.R. § 570.303(a) (1976). The ETR assessment required to be included in the HAP is a projection covering “the next three years.” Id. § 570.303(c)(2)(i). The HAP must specify “a realistic annual goal and also a three year goal for the number of dwelling units or persons to be assisted.” Id. § 570.303(c)(3). And it is to be noted that;
Where substantial housing needs are identified pursuant to paragraph (c)(2) of this section, and housing assistance resources are available, the Secretary may determine that Housing Assistance Plans with only minimal housing goals are plainly inappropriate to meeting the needs pursuant to the standards of review in § 570.306(b).
Id. § 570.303(c)(3)(v).
. The supplemental brief of HUD as amicus curiae tells us that two municipalities did not submit applications pursuant to the revised procedures. HUD tells us that absent affirmance it will remove the “holds” on these funds.