Congressionally Directed Spending (CDS). Earmarks. Are these the same thing? Different programs? And why is this suddenly part of the funding conversation?
The short answer: CDS and earmarks are the same tool, different names. Both refer to funding Congress allocates to specific projects at the request of individual legislators for needs in their own communities.
The longer story explains why this might feel unfamiliar. Congress banned earmarks in 2011 and did not revive them until 2021. A decade is long enough for terminology to fade, for expertise to retire, and for an entire generation of professionals to enter the industry without ever encountering the practice. When CDS returned, it came back quietly—with new transparency rules, spending caps, and disclosure requirements—but without the institutional knowledge that once surrounded it.
Today, CDS directs billions of dollars annually to specific projects, with significant allocations flowing through HUD, Transportation, and Defense. Since returning in 2021, the program has grown quickly—from roughly $9 billion and 5,000 projects in FY2022 to nearly $17 billion and 9,000 projects in FY2023. But this is not a predictable or guaranteed funding stream. Annual amounts fluctuate based on budget negotiations and spending caps. And a critical distinction: appearing on a CDS award list is not the same as receiving funds. Projects can be announced, even published, without money ever being delivered.
What Makes CDS Different from Most Federal Funding?
The opportunity is real. So is the complexity. Most programs require competitive applications— you write the proposal, wait months for review, and hope your project scores high enough. CDS works differently. This is funding your congressional delegation secures directly for specific projects in their district or state, outside the normal competitive process.
Michigan communities are already using it. But the process has rules, timelines, and realities that can trip up first-timers.
How It Works
CDS requests go through individual congressional offices—your two U.S. Senators and your U.S. House Representative. Each office sets its own submission process, priorities, and deadlines. There is no universal template; what works for one office may not apply to another.
Typically, offices open their request windows in late winter or early spring, with deadlines often falling in March. The member’s staff reviews submissions, vets projects for eligibility and alignment with the member’s priorities and selects which requests to champion through the appropriations process.
If your project is selected and survives the appropriations process, funding is included in the relevant spending bill—usually signed into law the following fiscal year. But selection is not a guarantee. Projects can be awarded funding on paper and never see a dollar delivered. The appropriations process has multiple points where things can stall, shift, or fall out entirely.
The Timeline Reality: CDS is not fast money.
The FY2024 appropriations bills were signed in March 2024. Projects funded through those bills are just now seeing money flow. That means a request submitted in March 2023 resulted in funding available in spring 2024—a minimum 12-18 month lag, and that assumes the appropriations process runs smoothly (which it often does not).
If you are hoping to fund a project that breaks ground next summer, CDS is not your path. But if you are planning two, three, or five years out, earmark funding can be a powerful piece of your capital strategy.
What Makes a Good Candidate?
Congressional offices receive far more requests than can be funded. Projects that rise to the top typically share these characteristics:
- Clear public benefit: Infrastructure, public safety, environmental protection, community facilities. Private benefit projects rarely make the cut.
- Shovel-ready or nearly so: Projects with engineering complete, permits in hand, and local match committed demonstrate readiness.
- Local investment: Requests that show significant local match not just the minimum required signal community commitment.
- Reasonable scope: Requests in the $500K-$3M range are more likely to succeed than $20M requests.
- Alignment with member priorities—and values: Each congressional office has focus areas, but the label does not tell the whole story. A member on an environmental subcommittee could prioritize conservation. Another could prioritize energy production. Both fall under “environment”—but a project emphasizing one approach may not resonate with a member who champions the other. Do the homework. Review the member’s public statements, past CDS requests they have supported, and legislation they have sponsored. Then look at the other members of the subcommittee or caucus. If your project runs counter to the prevailing values of the group, it faces an uphill battle regardless of how well it fits the topic category.
Example: A treatment plant upgrade could be framed as a local infrastructure need. But if the committee includes members with stakes in Great Lakes water quality, the smarter play is to frame it as regional stewardship—one community doing its part to protect a shared resource that spans multiple states. Same project. Different narrative. Different outcome.
Nonsupplanting: What Is It?
Federal funds must supplement, not replace, existing funding. If local dollars have been budgeted for a project, federal money cannot be swapped out and local funds redirected elsewhere. CDS funding needs to enable something that would not otherwise happen—an expanded scope, an accelerated timeline, or a project that was unfunded entirely.
Michigan’s Funding Landscape
Michigan’s transportation funding picture just got more complicated. The Citizens Research Council recently noted that 70 percent of the state’s new road revenue streams face uncertainty—marijuana tax revenue is being challenged in court, and corporate income tax threshold changes remain unsettled.
In this environment, communities need every funding tool available. CDS will not solve the infrastructure backlog on its own, but a well-timed earmark for a signature project can move something off the wish list and into construction.
Communities that win are those that have their projects documented, their engineering advanced, and their requests ready when the submission window opens.
Thinking Beyond the Obvious Category
CDS funding flows through multiple federal agencies—Transportation, HUD, Defense, and others. A single project can often be framed to fit more than one. The category you choose affects which funding stream you tap, and which congressional subcommittee reviews it.
Example: A road upgrade in a small community might struggle to compete as a standalone transportation project. But that same road, reframed as access infrastructure for a senior housing development, could find traction under HUD—where the narrative shifts from “road maintenance” to “community development serving vulnerable populations.”
Before defaulting to the obvious fit, ask: Is there another door that might open more easily?
Getting Started
- Identify candidate projects: What is on your capital plan that has clear public benefit and could use a federal boost?
- Advance your engineering: Preliminary design, cost estimates, and environmental review make your request credible.
- Build your case: Document community need, economic impact, and alignment with regional or state priorities.
- Watch the calendar: Congressional offices announce their CDS request windows—typically late winter. Miss the deadline, wait another year.
- Cultivate relationships: The communities that get funded are often the ones that have built ongoing relationships with their congressional delegation, not just showing up when they need money.
Bottom Line
This is not a funding source reserved for those with inside knowledge or decades of experience—because that expertise largely does not exist anymore. Everyone is learning. Everyone is rebuilding. The difference will come down to who prepares, who builds the relationships, and who shows up ready. Readiness wins.
Every community has projects waiting for the right funding opportunity. If you want to explore how CDS funding could work for yours, reach out to your Prein&Newhof project manager or contact Jason Washler at 616-364-8491. We can help you identify which programs align with your goals and navigate the application process. The best funding strategies start long before any shovels break ground.
