ndrc unmet recovery need and most impacted and distressed ... · the “most impacted and...

Community Development Block Grant National Disaster Resilience (CDBG-NDR)

Competition Unmet Recovery Need and Most

Impacted and Distressed Threshold Criteria Briefing

Todd Richardson – Office of Policy Development and Research Carey Whitehead – Office of General Counsel

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Agenda 1. CDBG-NDR NOFA Overview

2. Unmet Recovery Needs and Most Impacted and Distressed Threshold Criteria

3. Request for HUD review during 45 days

4. Resources

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NOFA Overview

• General Background

• Community Development Block Grant Disaster Recovery Supplemental Appropriation under the Disaster Relief Appropriations Act, 2013 (Public Law 113-2)

• CDBG-NDR NOFA Purpose

• Two Phases

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“Most Impacted and Distressed” and “Unmet Needs” Thresholds

The “most impacted and distressed” threshold:

• This appropriation provides for certain recovery assistance “in the most impacted and distressed areas resulting from a major disaster declared pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act” due to Hurricane Sandy and other eligible events in calendar years 2011, 2012, and 2013 . . .

The unmet needs threshold:

• This appropriation makes funds available “for necessary expenses related to disaster relief, long-term recovery, restoration of infrastructure and housing, and economic revitalization . . .

• These funds “may not be used for activities reimbursable by or for which funds are made available by the Federal Emergency Management Agency or the Army Corps of Engineers. . . “

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Unmet Recovery Need and Most Impacted and Distressed Threshold Criteria

• HUD Disaster Recovery allocations must be based on “best available data”

• No current data for remaining unmet recovery needs for 2011, 2012 and 2013 disasters

• CDBG-NDR NOFA allocations will factor in estimates of unmet recovery need in most impacted and distressed areas using data provided by applicants and found acceptable to HUD.

• Threshold Criteria described in CDBG-NDR NOFA - Appendix G

• HUD will review one unmet recovery need response per applicant during the first 45-days after NOFA publication and confirm or reject whether information provided meets the thresholds [discussed further later in this briefing]

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Most Impacted and Distressed – Phase 1

• Narrative response must be submitted in Exhibit B to the CDBG-NDR NOFA Response must address:

• Must identify by place name and/or Census tract code the target area(s) that is(are) most impacted and distressed resulting from the Qualified Disaster AND

• Must demonstrate unmet recovery need

• Exhibit B narrative response will not count against page limit

• Narrative must provide a link to data supporting the applicant’s framing of unmet recovery needs as described in the NOFA

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Most Impacted and Distressed – Phase 2

• Phase 2 submissions will update Phase 1 Unmet Recovery Need and most impacted and distressed submission as necessary

• HUD will award more points to more accurate, detailed and robust description of unmet recovery needs

• As applicable the Phase 1 assessment may be referenced rather than restating

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Most Impacted and Distressed Areas with Unmet Recovery Need Threshold Requirement:

Most Impacted Distressed Unmet Recovery

Need

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AND AND

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Already demonstrated by HUD

Already demonstrated by HUD Demonstrate at least

one category of unmet recovery need in Most Impacted and Distressed Areas: • Housing • Infrastructure • Economic

Revitalization • Environmental

Degradation

No

CD

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A sub-county area within a Presidentially declared major disaster area that demonstrate at least one Most Impacted Characteristic AND at least one Distressed characteristic:

Most Impacted Characteristics: • Housing Damage • Infrastructure

Damage • Economic Impact • Environmental

Degradation

Distressed Characteristics : • Low- and moderate

income area • Loss/shortage of

Affordable Housing • Federal target/

economically fragile area • Prior environmental

distress

Group 1: Already Most Impacted and Distressed Counties - still must demonstrate continuing unmet needs

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States (Most Impacted Counties) Local Jurisdictions

Alabama (7) Tuscaloosa, AL

Colorado (3) Birmingham, AL

Connecticut (2) Jefferson County, AL

Illinois (2) Chicago, IL Louisiana (5) Cook County, IL Massachusetts (1) Du Page County, IL

Maryland (1) Jefferson Parish, LA

Missouri (2) New Orleans, LA

North Dakota (1) St. Tammany Parish, LA

New Jersey (12) Springield, MA New York (15) Joplin, MO Oklahoma (2) Minot, ND Pennsylvania New York City, NY Rhode Island (4) Moore, OK Tennessee (1) Luzerne County, PA Texas (1) Dauphin County, PA

Vermont (3) Shelby County, TN

Group 2: Must demonstrate Most Impacted and Distressed as well as continuing unmet needs

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Alaska Mississippi

Arkansas Montana

Arizona North Carolina

California Nebraska

District of Columbia New Hampshire

Delaware New Mexico

Florida Ohio

Georgia Oregon

Hawaii Puerto Rico

Iowa South Dakota

Idaho Utah

Indiana Virginia

Kansas Washington

Kentucky Wisconsin

Maine West Virginia

Michigan Wyoming

Minnesota

Threshold Requirements:

Demonstrating an Area is Most Impacted:

• CDBG-DR Allocation

• Counties previously determined by HUD to be most impacted as the basis for prior CDBG-DR allocations

• No CDBG-DR Allocation

• Area must meet one of the following “most-impacted” characteristics as a result of the Qualifying Disaster

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Need AND AND

Housing • Minimum 100 homes damaged; OR • Minimum 20 homes seriously damaged

Infrastructure • $2 million or greater damage to permanent infrastructure

Economic Revitalization

• 1% or greater higher unemployment rate six-12 months after disaster; OR • 50 or more people no longer employed for six months or longer; OR • Other harm to the economy

Environmental Degradation

• Damage to natural resources; AND • Places housing, infrastructure and/or economic revitalization at risk


Demonstrating an Area is Distressed:

• CDBG-DR Allocation

• Counties previously determined by HUD to be distressed as the basis for prior CDBG-DR allocations

• No CDBG-DR Allocation

• Area must meet one of the following “distressed” characteristics as a result of the Qualifying Disaster

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Need AND AND

Low/Mod Area • More than 50% of people earn less than 80% of median income

Shortage of Affordable Rental Housing

• At least 100 renters with income less that 50% of target area median income; AND 60% of these renters have a severe housing problem; OR

• More than 100 assisted rental housing units are at high risk of damage from a future event

Federal Target or Economically Fragile Area

• Tribal Area • Contains a Promise Zone • Strong Cities Strong Communities Site; AND/OR • Unemployment rate greater than 125% of national average

Prior Environmental Distress

• Contains a contaminated property cleaned, undergoing or proposed for cleanup


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Need AND AND

Applicants with a previous CDBG-DR allocation

Applications without a previous CDBG-DR allocation

Housing: Demonstrating unmet recovery need

How are other CDBG-DR allocations inadequate for addressing remaining housing repair needs?

How many households are still displaced from housing due to the disaster, or how many housing units that were damaged by the disaster have not yet been repaired?

• Number of households that would continue to be displaced; or

• At least 20 households and/or still damaged homes must be documented to meet this requirement

• Number of homes or rental units that will not be served.


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Need AND AND



Infrastructure: Demonstrating unmet recovery need What damage to permanent public infrastructure has not been repaired due to inadequate resources in or serving the most impacted and distressed area (and for which no CDBG-DR has been identified in an action plan)?

What damage to permanent infrastructure has not yet been repaired due to inadequate resources in or serving the most impacted and distressed area?

Describe: • Project(s) and its location relative to most impacted and distressed area • Amount of funding required to complete • Reason funding is inadequate

$400,000 minimum unfunded permanent infrastructure repair need

• Can include local match requirement for FEMA or DOT permanent infrastructure projects

• No more than $250,000 of CDBG-DR or CDBG-NDR per project may be used toward US Army Corps of Engineers cost share requirement


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Need AND AND



Economic Revitalization: Demonstrating unmet recovery need

What is the extent of continuing unmet economic revitalization recovery need due to the qualifying disaster in most impacted and distressed target area(s) that cannot be addressed with existing funds?

What is the extent of continuing unmet economic revitalization recovery need due to the qualifying disaster in most impacted and distressed target area(s)?

• Minimum of five businesses with remaining repair needs OR

• At least 10% continuing decreased business revenue for:

o one or more businesses with 10 or more employees OR

o three or more smaller businesses

• Must include narrative describing how needs result from impacts of the qualifying disaster


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Need AND AND



Environmental Degradation: Demonstrating unmet recovery need

What environmental damage from the qualifying disaster has not been addressed and cannot be addressed with existing resources?

• Environmental degradation must threaten long-term recovery of critical natural resources and place housing, infrastructure and/or economic revitalization at risk

• Must demonstrate $400,000 or more remaining damage

Acceptable Data Sources:


Housing:

If applicant is running a CDBG-DR or other recovery housing program:

• Provide an analysis that shows program waiting list and a reasonable estimate of unmet repair needs after insurance, FEMA and SBA benefits

• Analysis must demonstrate that need exceeds applicant’s prior CDBG-DR allocation

If applicant is not running a CDBG-DR or other recovery housing program:

• Explain why prior CDBG-DR allocations, together with other funding are inadequate AND provide an analysis based on:

• Recent emergency management data OR

• A methodologically sound windshield survey

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Need AND AND


Applicants without previous CDBG-DR allocation

Housing:

• Recent emergency management data indicating households still displaced by the disaster

• Methodologically sound “windshield: survey of the impacted area conducted since January 2014

• Must include a list of addresses of units identified with remaining damage

• A survey of nine of these addresses confirming that: • The remaining damage is due to the disaster

• Households have inadequate resources to complete repairs

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Need AND AND


Applicants with or without a previous CDBG-DR allocation

Infrastructure:

• Engineering report with estimated repair amount

• Sources and uses statement for project that demonstrates funding shortfall

• Total repair cost may include cost to repair infrastructure resiliently

• Explanation of why existing CDBG-DR resources, together with other funding sources are inadequate to meet repair need

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Need AND AND



Economic Revitalization:

• Applicants must supply a narrative describing how these needs result from the disaster based on:

• For Unmet Repair needs for Businesses:

• Windshield survey showing minimum of five businesses with remaining repair needs AND

• A survey of five businesses confirming damage and repairs not completed due to not receiving adequate resources

• Include addresses of businesses with continuing needs

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Need AND AND



Economic Revitalization (Cont.):

• Applicants must supply a narrative describing how these needs result from the disaster based on: • For decreased revenues for business(es)

• Analysis showing continuing economic damage OR

• A survey of businesses who provide: • Number of employees before disaster and current

• Total gross revenues in the year before the disaster and most recent year

• A description of how the reduction in revenues is related to the diaster

• Survey must demonstrate 10% total gross revenue reduction due to disaster for:

• One business with 10 or more employees OR

• Three smaller businesses

• Names and addresses of businesses surveyed must be

provided

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Need AND AND



Economic Revitalization (cont.):

• Due to the potentially sensitive nature of this data, documentation for this characteristic may be submitted via a password-protected link

• Sensitive information should be clearly labeled

• HUD will limit disclosure of covered information as required by federal Freedom of Information Act requirements

• HUD is requiring this information to ensure use of the best available data, as opposed to simple assertion

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Need AND AND



Environmental Degradation:

• A detailed report from a reputable public or private organization describing damage with a certification date after March 2014 indicating remaining damage of $400,000 or more

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Need AND AND

RECAP: Most Impacted and Distressed Areas with Unmet Recovery Need Threshold Requirement:


Need

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AND AND

Co

un

ties

w

/CD

BG

-DR

A

lloca

tio

n

Already demonstrated by HUD

Already demonstrated by HUD Demonstrate at least

one category of unmet recovery need in Most Impacted and Distressed Areas: • Housing • Infrastructure • Economic

Revitalization • Environmental

Degradation

No

CD

BG

-DR

Allo

cati

on

A sub-county area within a Presidentially declared major disaster area that demonstrate at least one Most Impacted Characteristic AND at least one Distressed characteristic:

Most Impacted Characteristics: • Housing Damage • Infrastructure

Damage • Economic Impact • Environmental

Degradation

Distressed Characteristics : • Low- and moderate

income area • Loss/shortage of

Affordable Housing • Federal target/

economically fragile area • Prior environmental

distress

HUD Review in First 45 Days

• One written request per applicant • Send to [email protected] • Must be submitted on or before November 3, 2014 • Sample letter available online:

https://www.hudexchange.info/cdbg-dr/resilient-recovery • “Most impacted and distressed” and “unmet needs” threshold responses

may be submitted for one or more potential target areas • HUD will respond within 15 working days • HUD Response will:

– Only be provided one time – Confirm or reject whether the information provided for each

area meets the thresholds – Provide specific reasons for any rejection – Explain how a submission is deficient

• HUD Response will not: – Explain how to remedy any deficiencies in the submission.

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mailto:[email protected]

Resources Grants.gov

• http://www.grants.gov/web/grants/home.html • Download the NOFA and supporting documents

– Click “Apply for Grants” in the “Applicants” menu – Click “Download an Application Package” – Enter the CDFA Number to download (CDFA#: 14.272)

NOFA website • https://www.hudexchange.info/cdbg-dr/resilient-recovery • Link to NOFA on grants.gov • All webinar recordings will be posted online

Data Resources • http://www.huduser.org/portal/CDBGRDR.html

Resilient recovery website • https://www.hudexchange.info/cdbg-dr/resilient-recovery • Resources and research on disaster resilience

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http://www.grants.gov/web/grants/home.html

https://email.hud.gov/OWA/redir.aspx?C=0vfBPed9mkCJqZVyHL0qU-lGlBNvodFITIhHQtwVNfUe-kN7SoVTJN6mmfsxmxg7Q8s5XCXgjw8.&URL=https://www.hudexchange.info/cdbg-dr/resilient-recovery





http://www.huduser.org/portal/CDBGRDR.html

http://www.huduser.org/portal/CDBGRDR.html

https://www.hudexchange.info/cdbg-dr/resilient-recovery







Questions?

Send all questions about the NOFA, including threshold requirements, to:

[email protected]

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