5800-N-29 National Resiliance Tech Correction Appendix G I - 12 17 14 FINAL.pdf

U.S. Department of Housing and Urban Development

Community Planning and Development

National Disaster Resilience Competition

Technical Correction

FR-5800-N-29

Program Office:

Funding Opportunity Title:

Announcement Type:

Funding Opportunity Number:

Primary CFDA Number: Due

Date for Applications:

Community Planning and Development

National Disaster Resilience Competition

Technical Correction

FR-5800-N-29

14.272

March 15, 2015 (Unchanged)

On September 17, 2014, HUD posted the National Disaster Resilience Competition Notice of

Fund Availability to Grants.gov. Today’s Notice provides several technical corrections to the original NOFA to: (1) identify in several paragraphs when a “sub-county” area is intended and to specify “most impacted and distressed target area” or “area for grant expenditure” where existing language is inadvertently ambiguous; (2) to clarify submission length with regard to target areas; (3) to clarify which governmental entities can be identified as a most impacted and distressed target area; (4) capitalize or use boldface type on certain words for emphasis or distinction; (5) to insert missing words or punctuation; and (6) to address other irregularities in the text as such may appear and result in ambiguity as to HUD’s submission requirements. For the ease of the reader, HUD is republishing both Appendix G and

Appendix I in their entirety in this Technical Correction.

FOR FURTHER INFORMATION CONTACT: Questions regarding specific program requirements should be directed to the agency contact identified in each program NOFA.

Questions regarding the FY2014 General Section should be directed to the Office of Strategic

Planning and Management, Grants Management and Oversight Division at 202-708-0667 (this is not a toll-free number). Persons with hearing or speech impairments may access this number via TTY by calling the Federal Relay Service at 800-877-8339.

SUPPLEMENTAL INFORMATION:

The following changes to Appendix G – Phase 1 and Phase 2 Most Impacted and Distressed and Unmet Recovery Needs Criteria and Instructions and to Appendix I – Phase 1 and

Phase 2 Consultation Summary are made by this notice.

Appendix G Introductory Paragraphs

The second sentence of the first paragraph is corrected to read as follows:

“Threshold requirements include the statutory mandate that the proposed program or project to be assisted with CDBG-NDR funds meets an Unmet Recovery Need in a most

From Public Law 113-2, “For an additional amount for Community Development Fund, $16,000,000,000, to remain available until September

30, 2017, for necessary expenses related to disaster relief, long-term recovery, restoration of infrastructure and housing, and economic revitalization 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 (42 U.S.C. 5121 et seq.) due to Hurricane Sandy and other eligible events in calendar years 2011, 2012, and 2013 for activities authorized under title I of the Housing and Community Development Act of 1974 (42 U.S.C. 5301 et seq.)” . . . Provided further, That funds provided under this heading 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. . . Provided further, That as a condition of making any grant, the Secretary shall certify in advance that such grantee has in place proficient financial controls and procurement processes and has established adequate procedures to prevent any duplication of benefits as defined by section 312 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5155):”

http://grants.gov/ impacted and distressed area resulting from a Qualified Disaster (See Appendix B for a list of Qualified Disasters).”

Second paragraph, second sentence: A typographical error is corrected by deleting the “s” from the word “exists”

Third paragraph, second sentence: A hyphen is inserted. The corrected sentence reads as follows:

“Note that CDBG-NDR-funded activities must address unmet needs in a most impacted and distressed area; however, the benefit does not have to be exclusive to that area.”

Third paragraph, third sentence: The word “meeting” is replaced with the word

“addressing”.

A sentence is added to the end of the paragraph, which reads:

“Further, the geography covered by an Applicant’s NDRC overall proposal target area may be the same as or larger than the target area eligible for CDBG-NDR grant assistance (the most impacted and distressed target area).”

Corrections to Appendix G, Section I. Threshold Submission Requirement

Subsection A. Phase 1: The second sentence has language inserted at the end. This sentence now reads as follows:

“We anticipate that your Phase 1 response addressing Unmet Recovery Needs and most impacted and distressed requirements will be approximately 5 pages for each sub-county area or group of similarly situated sub-county areas.”

Subsection A. Phase 1. Subparagraph 2: The phrase “or other sub-county area” is added after

“Census Tract Code” and the phrase “for grant expenditure” is added after “target area(s)”. The subparagraph now reads as follows:

“2. The Phase 1 Exhibit B narrative response also must identify, by place name and/or Census Tract code, or other sub-county area the subject target area(s) for grant expenditure that is most impacted and distressed resulting from a

Qualified Disaster.”

Subsection C. is corrected as follows: In the first sentence, ‘“most impacted and distressed” and

“Unmet Recovery Needs”’ has been inserted before “threshold requirements.”

The phrase, “for grant expenditure” has been inserted after “one area” in the same sentence.

The word, “target” has been inserted between the words “distressed” and “area” in the third sentence.

Finally, the following language has been inserted at the end of the last sentence of Subsection C:

“for each sub-county area or group of similarly situated sub-county areas.”

Corrections to Appendix G, Section II. Demonstrating Most Impacted and Distressed

Threshold

The word “your” has been inserted between the words, “in” and “Exhibit B” in the first sentence.

Subsection B. has been corrected to read as follows:

“B. A sub-county area (such as a place name, census designated place, tribal area, or census tract) within a county or county equivalent declared by the President to be a major disaster area under the Stafford Act for a disaster event occurring in calendar years 2011, 2012, or 2013 (see http://www.HUDUSER.org/CDBGRDR/AppendixB) that meets at least one Most Impacted Characteristic AND one Distressed Characteristic, as demonstrated in the application (applicants may include more than one characteristic):”

In paragraph 1 of this section, sub-paragraph (a) Housing., the word “Designated” is deleted from the phrase, “257 Census Designated Places.”

In paragraph 1 of this section, sub-paragraph (b) Infrastructure., the phrase, “or FEMA Project

Work Sheet” is inserted after the opening phrase of the second sentence of this sub-paragraph, “Applicants must provide either an engineering report.”

In paragraph 1 of this section, sub-paragraph (b) Infrastructure., the phrase, “along with a sources and uses statement for the project showing the funding shortfall” is deleted after the phrase, “with an estimated repair amount.”

In paragraph 1 of this section, sub-paragraph (c) Economic Revitalization., the term, “sub-county area” is underlined in the first sentence. Later in the first sentence, the word “and” is replaced with the word, “or.” The revised sentence reads as follows:

“A disaster in a sub-county area causing significant employment loss or extended harm to the local economy.”

A semi-colon is inserted after the first closed parenthesis of this Economic Revitalization sub-paragraph and after the subsequent phrase, “or other harm to the local economy.”

The word, “it” is replaced with the phrase, “the employment loss or harm” in the last series of the

Economic Revitalization sub-paragraph.

In paragraph 1 of this section, sub-paragraph (d), the second sentence is revised of this sub-paragraph to read as follows:

“A disaster resulting in significant degradation to the environment putting the housing, infrastructure, and/or economic drivers in the area or nearby areas at risk of great harm for a future disaster.”

In the last sentence of this sub-paragraph the phrase, “to the environment” is inserted after the word “damage.”

http://www.huduser.org/CDBGRDR/AppendixB

In the first sentence of paragraph 2 of this section, the phrase, “or high concentrations of damage” is inserted after the term, “Qualified Disaster.” The sentence now reads as follows:

“2. Distressed Characteristics considers stress or deficit factors prior to the Qualified Disaster or high concentrations of damage that research and experience indicate result in greater disaster impact or more costly and difficult recovery and revitalization (choose one or more):”

In paragraph 2 of this section, sub-paragraph (a) Disaster impacted low- and moderate-income households, has been amended to read as follows:

“(a) Disaster impacted low- and moderate-income households. Applicant can demonstrate with data that more than 50 percent of the people in the target area are at less than 80 percent of area median income (grantees may use CDBG low-and moderate-income summary data areas to demonstrate this characteristic- see www.HUDUSER.org/CDBGRDR/AppendixD; Under the heading “Data Sets” applicants may use the link for “All Block Groups by State” if the Most Impacted target area is a Block Group, Census Tract or aggregation of Census Tracts; use the link for “Local Government Summaries by State” if the target area is a sub-county place. To calculate the percent less than 80 percent of median income, sum the column “low mod” for each of the geographic components comprising the most impacted area and divide by the sum of the column “low mod univ” for the same area.)”

In paragraph 2 of this section, sub-paragraph (d) Disaster impacted an area with prior documented environmental distress, the phrase, “For example,” is inserted at the beginning of the first sentence and the phrase, “or is adjacent to and negatively affected by” is inserted after the phrase, “the affected area contains” The first sentence of this sub-paragraph now reads as follows:

“For example, the affected area contains or is adjacent to and negatively affected by a contaminated property cleaned, undergoing cleanup, or proposed for cleanup.”

At the end of this section the following new sub-paragraph is inserted:

“(e) Housing. A concentration of housing damage in a sub-county area due to the eligible disaster causing damage or serious damage to at least 10 percent of the homes located there. Appendix C provides a list of disasters with concentrations of housing damage meeting this requirement. Applicants may also submit local data, provided a) the data show concentrated damage meeting this standard, and b) HUD agrees with the validity of the data (see http://www.HUDUSER.org/CDBGRDR/AppendixC”

Corrections to Appendix G, Section III. Demonstrating Unmet Recovery Needs

Threshold Requirement

The introductory paragraph of Subsection A. has been amended to read as follows:

“A. For a target area that is within a County that was previously determined by HUD to file:///C:/Users/H49449/Desktop/www.HUDUSER.org/CDBGRDR/AppendixD http://www.huduser.org/CDBGRDR/AppendixC be most impacted (for Applicants with a previous allocation of CDBG Disaster

Recovery funds in response to major disasters in 2011, 2012 or 2013) Applicants need to provide information that meets a minimum of one of the following items for each target area in which the Applicant would expend CDBG-NDR funds:”

In Subsection 1. Housing of this section, the word, “each” is inserted and the “(s)” is deleted so that the first sentence reads as follows:

“Are prior CDBG-DR funding allocations, together with other funding sources, inadequate for addressing remaining housing repair needs in each most impacted and distressed target area?”

In the second sentence of Subsection 1. Housing, The phrase “for a target area” is inserted after the word, “no.”

In the next paragraph, the statement in parentheses is amended to read as follows:

“(Twenty or more households displaced by the disaster or twenty homes still damaged by the disaster must be documented to meet this requirement.)”

In Subsection 1. Housing., Paragraph (a), the phrase, “of aggregate” is inserted before the phrase, “average unmet repair needs” in the first sentence.

In Subsection 1. Housing., Paragraph (b) ii., the first sentence is amended to read as follows:

“A methodologically sound “windshield” survey of the target area within a HUD-identified most impacted county conducted since January 2014.”

In Subsection 2. Infrastructure., the first sentence is amended to read as follows:

“Is there damage to permanent public infrastructure (i.e. FEMA Category C to G) that has not yet been repaired due to inadequate resources (and for which no CDBG-DR funding has been identified in an action plan), in or serving the target area(s) within a HUD-identified most impacted county?”

In the second paragraph, the words and phrases “damage,” “damaged permanent public infrastructure,” and “repairs,” are inserted in the first sentence to replace the word, “project(s).”

The word “the” is inserted between the words “and” and “reason.” The amended sentence reads as follows:

“Describe the damage, the location of the damaged permanent public infrastructure relative to the most impacted and distressed target area(s), the amount of funding required to complete repairs, and the reason there are inadequate funds.”

In the third sentence of the second paragraph, open and closed parentheses are inserted around the sentence.

In the first sentence of the last paragraph, of Subsection 2. Infrastructure., the phrase, “or FEMA

Project Work Sheet(s),” is inserted after the phrase, “An engineering report.” The phrase, “along with” is replaced by the word, “AND” and the word, “project,” is replaced with the word, http://www.fema.gov/public-assistance-local-state-tribal-and-non-profit/categories-work

“repairs,” as they appear later in that sentence. The period at the end of this sentence is replaced with a comma and the phrase, “In addition,” at the beginning of the next sentence is replaced with the word, “AND.”

The revised sentences now read as follows:

“An engineering report or FEMA Project Work Sheet(s) with an estimated repair amount AND a sources and uses statement for the repairs showing the funding shortfall (total repair costs may include the extra cost to repair this infrastructure resiliently), AND your explanation of why existing CDBG-DR resources, together with other funding sources, are inadequate to meet this repair need.”

In Subsection 3. Economic Revitalization., the phrase “most impacted” is deleted and the phrase, “within a HUD-identified most impacted county,” is inserted in the first sentence so that the sentence now reads as follows:

“Are there continuing unmet economic revitalization recovery needs due to the disaster in the target area(s) within a HUD-identified most impacted county that cannot be addressed with existing resources, including CDBG-DR funds already allocated?”

In the first sentence of the second paragraph, the phrase “most impacted” is deleted and the phrase, “within a HUD-identified most impacted county,” is inserted so that the sentence now reads as follows:

“Describe the extent of those needs and how the needs are connected with the disaster and the target area within a HUD-identified most impacted county.”

The numbered series later in this paragraph has been indented.

In the second item of the series, a hyphen is inserted between the words, “modest” and “sized.”

A semi-colon is inserted at the end of the second item of the series.

A new number, “(iii)” is inserted before the last item in the series.

In Subsection 3. Economic Revitalization., Paragraph (a), the period is deleted at the end of the paragraph, a comma is inserted, and is followed by the word, “OR.”

In Subsection 3. Economic Revitalization., Paragraph (b), the phrase, “within a HUD-identified most impacted county,” is inserted in the first sentence after the words, “target area.”

In the first sentence of the second paragraph of Subsection 4., Environmental Degradation, the phrase “most impacted” is deleted and the phrase, “within a HUD-identified most impacted county,” is inserted so that the sentence now reads as follows:

“Describe the remaining damage and how the damage is connected with the disaster and the target area within a HUD-identified most impacted county.”

In the second sentence, the phrase, “to the environment” is inserted after the phrase, “remaining damage” and the phrase, “or restoration” is inserted after the phrase, “for making repairs.”

The introductory paragraph of Subsection B. has been amended to read as follows:

“B. Applicants without a previous allocation of CDBG Disaster Recovery funds in response to major disasters in 2011, 2012 or 2013 proposing a sub-county most impacted and distressed target area, OR Applicants with a previous allocation proposing a sub-county target area that lies outside of a HUD-determined most impacted county (MIC), must provide information that meets a minimum of one (1) of these items:”

In the first sentence of the first paragraph in Subsection 1. Housing, the phrase, “impacted area” is replaced with the phrase, “most impacted and distressed sub-county target area.”

In the first sentence of the second paragraph in Subsection 1. Housing, the phrase, “that will not be served by existing programs, including CDBG-DR programs, due to inadequate funding,” is inserted at the end of the sentence.

In the last sentence of the second paragraph the word, “twenty” is inserted after the conjunction and the conjunction is changed. The sentence now reads as follows:

“Twenty or more displaced households or twenty still damaged homes must be documented to meet this requirement.”

Paragraphs (a) and (b) in Subsection 1. Housing, are replaced in their entirety with the following:

“(a) If you are running a CDBG-DR or other recovery housing program, an analysis that shows that the program waiting list and a reasonable estimate of aggregate average unmet repair needs (after insurance, FEMA, SBA) exceeds the existing CDBG-DR funds available. (Total repair costs can include the reasonable extra cost to buyout homes or repair homes resiliently, e.g., extra cost to elevate or build a safe room.)

(b) If not running a CDBG-DR or other recovery housing program currently, briefly explain why prior allocations of CDBG-DR funding, together with other funding sources, are inadequate to provide a housing program AND provide:

(i) Recent emergency management data indicating households are still displaced from the disaster. This might include information from FEMA on number of households still receiving emergency rental assistance or living in a FEMA

Transitional Housing Unit. This could also include information from homeless providers indicating that they are still serving households that lost their housing due to the disaster; OR

(ii) A methodologically sound “windshield” survey of the most impacted and distressed target area conducted since January 2014. A list of addresses needs to be provided to HUD of units identified with remaining damage. A survey of 9 of these addresses confirming (i) the damage is due to the disaster and (ii) they have inadequate resources from insurance/FEMA/SBA for completing their repairs.

Statistical accuracy is not required, so this can be a purposive sample of easy to contact residents.”

In the first sentence of the first paragraph in Subsection 2. Infrastructure, the phrase, “(and, if you have a CDBG-DR allocation, for which no CDBG-DR funding has been identified in an action plan)” is inserted between the words, “resources” and “in.”

Later in that same sentence, the phrase, “and distressed sub-county” is inserted between the words, “impacted” and “target.” The revised sentence reads as follows:

“Is there damage to permanent public infrastructure (i.e. FEMA Category C to G) that has not yet been repaired due to inadequate resources (and, if you have a CDBG-DR allocation, for which no CDBG-DR funding has been identified in an action plan) in or serving the most impacted and distressed sub-county target area?”

In the second paragraph, the words and phrases “damage,” “damaged permanent public infrastructure,” and “repairs,” are inserted in the first sentence to replace the word, “project(s).”

The word “the” is inserted between the words “and” and “reason.” The amended sentence reads as follows:

“Describe the damage, the location of the damaged permanent public infrastructure relative to the most impacted and distressed target area(s), the amount of funding required to complete repairs, and the reason there are inadequate funds.”

In the third sentence of the second paragraph, open and closed parentheses are inserted around the sentence.

In the first sentence of the last paragraph, of Subsection 2. Infrastructure., the phrase, “or FEMA

Project Work Sheet(s),” is inserted after the phrase, “An engineering report.” The phrase, “along with” is replaced by the word, “AND” and the word, “project,” is replaced with the word, “repairs,” as they appear later in that sentence. The period at the end of this sentence is replaced with a comma and the following additional language is added: “AND your explanation of why existing CDBG-DR resources (if any), together with other funding sources, are inadequate to meet this repair need.”

The revised sentence now reads as follows:

“An engineering report or FEMA Project Work Sheet(s) with an estimated repair amount AND a sources and uses statement for the repairs showing the funding shortfall (total repair costs may include the extra cost to repair this infrastructure resiliently), AND your explanation of why existing CDBG-DR resources (if any), together with other funding sources, are inadequate to meet this repair need.”

In Subsection 3. Economic Revitalization., the phrase, “most impacted target area,” at the end of the first sentence of the first paragraph is replaced with the following phrase:

“most impacted and distressed sub-county target area that cannot be addressed with existing resources, including CDBG-DR funds already allocated (if any)?”

In the first sentence of the second paragraph, the phrase “and distressed sub-county” is inserted between the words “impacted” and “target” so that the sentence now reads as follows:

“Describe the extent of those needs and how the needs are connected with the disaster and the most impacted and distressed sub-county target area.”

The numbered series later in this paragraph has been indented.

In the second item of the series, a hyphen is inserted between the words, “modest” and “sized.”

A semi-colon is inserted at the end of the second item of the series.

A new number, “(iii)” is inserted before the last item in the series.

At the end of Paragraph (a) in Subsection 3. Economic Revitalization., the words, “provided;

OR” are inserted.

In the first sentence of Paragraph (b) in Subsection 3. Economic Revitalization., the phrase, “most impacted and distressed sub-county,” is inserted between the phrases, “continuing economic damage to the” and “target area.”

In the first sentence of the second paragraph of Subsection 4., Environmental Degradation, the phrase, “to the environment” is inserted after the phrase, “remaining damage” and the phrase, “and distressed sub-county” is inserted after the phrase, “most impacted.” The sentence now reads as follows:

“Describe the remaining damage to the environment and how the damage is connected with the disaster and the most impacted and distressed sub-county target area.”

In the second sentence of the second paragraph, of Subsection 4., Environmental Degradation, the phrase, “or reconstruction,” is inserted after the phrase, “for making repairs.”

Corrections to Appendix I, Phase 1 and Phase 2 Consultation Summary

The title on page three of this appendix is changed to “Eligible Local Government Applicants:”

Appendix G

Most Impacted and Distressed and Unmet Recovery Needs Threshold Criteria and

Instructions

To be rated and ranked, all Applicants and applications must meet all threshold requirements of this NOFA. Threshold requirements include the statutory mandate that the proposed program or project to be assisted with CDBG-NDR funds meets an Unmet Recovery Need in a most impacted and distressed area resulting from a Qualified Disaster (See Appendix B for a list of

Qualified Disasters). This document identifies the required Phase 1 and Phase 2 demonstrations that applicants must submit to satisfy these thresholds.

Public Law 113-2 requires that HUD make allocations based on “best available data” to State and local governments. HUD has determined that the data available for the earliest disasters, in particular, no longer credibly represents additional current unmet recovery needs, but no other reasonably current data sources common to all possible eligible jurisdictions exist. HUD decided that a competition framework would elicit the best data to inform allocations and ensure that the unmet disaster recovery and revitalization needs of communities around the country are appropriately considered.

The “most impacted and distressed” and “Unmet Recovery Needs” threshold requirements, as described below, are designed to facilitate the maximum participation, allowable by law, of communities across the country.

Note that CDBG-NDR-funded activities must address unmet needs in a most impacted and distressed area; however, the benefit does not have to be exclusive to that area. While co-benefits may accrue to neighboring areas, Applicants must identify leveraging funds to pay for costs attributable to any portion of a proposed mitigating action that is not for the purpose of addressing an Unmet Recovery Need in the most impacted and distressed area resulting from a Qualified Disaster because such costs cannot be charged to a

CDBG-NDR grant. Further, the geography covered by an Applicant’s NDRC overall proposal target area may be the same as or larger than the target area eligible for CDBG-NDR grant assistance (the most impacted and distressed target area).

I. Threshold Submission Requirement

A. Phase 1. Applicants must meet the threshold requirement with a Phase 1 submission.

We anticipate that your Phase 1 response addressing Unmet Recovery Needs and most impacted and distressed requirements will be approximately 5 pages for each sub-county area or group of similarly situated sub-county areas.

From Public Law 113-2, “For an additional amount for Community Development Fund, $16,000,000,000, to remain available until September

30, 2017, for necessary expenses related to disaster relief, long-term recovery, restoration of infrastructure and housing, and economic revitalization 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 (42 U.S.C. 5121 et seq.) due to Hurricane Sandy and other eligible events in calendar years 2011, 2012, and 2013 for activities authorized under title I of the Housing and Community Development Act of 1974 (42 U.S.C. 5301 et seq.)” . . . Provided further, That funds provided under this heading 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. . . Provided further, That as a condition of making any grant, the Secretary shall certify in advance that such grantee has in place proficient financial controls and procurement processes and has established adequate procedures to prevent any duplication of benefits as defined by section 312 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5155):”

1. For Phase 1, each applicant must submit in its Exhibit B narrative response, together with responses to other threshold requirements identified in Section

III.C.3. of the CDBG-NDR NOFA, a narrative submission that addresses each of the requirements explained below in Sections II. and III. of this Appendix.

Although your narrative submission must be included within the page limit for the

Phase 1 submission, your narrative submission may summarize required support data rather than including the data in its entirety. If you choose to summarize the data, your narrative must provide HUD a link to publicly available data from a reputable source, or you may provide a password-protected link to access other data stored on a cloud storage service such as Dropbox, Google Drive, Microsoft

OneDrive, Box, or Bitcasa. In either case, include the link in your narrative. You may email the password for any cloud storage link to ResilientFuture@hud.gov.

Include Applicant’s name in the Subject line of the email. Include Applicant’s name, a contact person’s name and telephone number, and a list of the relevant filenames in the body of the email.

2. The Phase 1 Exhibit B narrative response also must identify, by place name and/or Census Tract code, or other sub-county area the subject target area(s) for grant expenditure that is most impacted and distressed resulting from a

Qualified Disaster.

B. Phase 2. Your Phase 1 submission will still be sufficient to demonstrate that your application meets the basic NOFA threshold requirements. For Phase 2, you will update the Unmet Recovery Need and most impacted and distressed submission, as necessary.

HUD will award more points to a more accurate, detailed, and robust description that addresses the criteria in Phase 2 Factor 2. You may reference specific portions of your

Phase 1 submission in your Phase 2 submission rather than repeating information previously provided. You may also provide links to data, as above.

C. To meet the “most impacted and distressed” and “Unmet Recovery Needs” threshold requirements, you only need to demonstrate that one area for grant expenditure is most impacted and distressed and has Unmet Recovery Need. HUD encourages you to consider resilience in a wider area, such as in other most impacted and distressed areas, regionally, or statewide. If you want to use CDBG-NDR funds in an additional area, you must identify the area(s) and demonstrate how it meets the most impacted and distressed target area thresholds covered in this Appendix. HUD prefers that you make this demonstration during Phase 1. If you add a most impacted and distressed target area(s) in

Phase 2, HUD will expect your Factor 2 and Factor 3 submissions to specifically address how the residents and stakeholders of the additional area participated in the Phase 1 framing and consultation processes. HUD anticipates that the Phase 2 narrative response to address the Unmet Recovery Needs and most impacted and distressed requirements will be approximately 10 pages for each sub-county area or group of similarly situated sub-county areas.

II. Demonstrating Most Impacted and Distressed Threshold

Each of the elements of the “most impacted and distressed” definition must be addressed in your

Exhibit B narrative response (including links to data, as required below).

For this competition, “most impacted and distressed” is defined as either:

A. A County that was previously determined by HUD to be most impacted (see http://www.HUDUSER.org/CDBGRDR/AppendixA); OR

B. A sub-county area (such as a place name, census designated place, tribal area, or census tract) within a county or county equivalent declared by the President to be a major disaster area under the Stafford Act for a disaster event occurring in calendar years 2011, 2012, or 2013 (see http://www.HUDUSER.org/CDBGRDR/AppendixB) that meets at least one Most Impacted Characteristic AND one Distressed Characteristic, as demonstrated in the application (applicants may include more than one characteristic):

1. Most Impacted Characteristics considers the damage resulting from the Qualified

Disaster (choose at least one for threshold purposes) :

(a) Housing. A concentration of housing damage in a sub-county area due to the eligible disaster causing damage to either a minimum of 100 homes or serious damage to a minimum of 20 homes. Appendix C provides a list of disasters with concentrations of housing damage meeting this requirement. Applicants may also submit local data, provided a) the data show concentrated damage meeting this standard, and b) HUD agrees with the validity of the data (see http://www.HUDUSER.org/CDBGRDR/AppendixC that shows 741 Census

Tracts and 257 Census Places that meet this standard outside of the already determined most impacted counties.)

(b) Infrastructure. Damage to permanent infrastructure (i.e. FEMA Category C to G) in a sub-county area estimated at $2 million or greater. Applicants must provide either an engineering report or FEMA Project Work Sheet with an estimated repair amount (total repair costs can include the extra cost to repair this infrastructure resiliently) or other evidence of an estimate of expenditures to make repairs that support this claim.

(c) Economic Revitalization. A disaster in a sub-county area causing significant employment loss or extended harm to the local economy. Applicants must briefly demonstrate employment loss (a one percentage point or greater higher local unemployment rate in the impacted area six to 12 months after a disaster compared to the same month in the year prior to the disaster in that area; or specific information that 50 or more people were no longer employed in or near the most impacted area for six months or longer due to the disaster); or other harm to the economy; and describe how the employment loss or harm stems from the

Qualified Disaster (applicant may support a short description with local data or surveys).

(d) Environmental Degradation. Environmental Degradation that threatens long-term recovery of critical natural resources and places housing, infrastructure, and/or economic revitalization at risk. A disaster resulting in significant degradation to http://www.huduser.org/CDBGRDR/AppendixA http://www.huduser.org/CDBGRDR/AppendixB the environment putting the housing, infrastructure, and/or economic drivers in the area or nearby areas at risk of great harm for a future disaster. Examples include a fire destabilizing a watershed creating flood risk downstream or threatening economic revitalization by harming recreational activities that support to local economies; damage to stream beds from a severe flooding event damaging a containment dike or dam increasing risk of more flood damage to property; damage to wetlands or barrier islands from a Hurricane reducing protection from future Hurricanes or harming local economies such as fishing and eco-tourism. Applicants must describe the damage to the environment and support with references to any studies supporting the claim of future risk.

2. Distressed Characteristics considers stress or deficit factors prior to the Qualified

Disaster or high concentrations of damage that research and experience indicate result in greater disaster impact or more costly and difficult recovery and revitalization

(choose one or more)

(a) Disaster impacted low- and moderate-income households. Applicant can demonstrate with data that more than 50 percent of the people in the target area are at less than 80 percent of area median income (grantees may use

CDBG low-and moderate-income summary data areas to demonstrate this characteristic- see www.HUDUSER.org/CDBGRDR/AppendixD; Under the heading “Data Sets” applicants may use the link for “All Block Groups by

State” if the Most Impacted target area is a Block Group, Census Tract or aggregation of Census Tracts; use the link for “Local Government Summaries by State” if the target area is a sub-county place. To calculate the percent less than 80 percent of median income, sum the column “low mod” for each of the geographic components comprising the most impacted area and divide by the sum of the column “low mod univ” for the same area.)

(b) Loss/shortage of affordable rental housing. There is a severe shortage of affordable rental housing (there are a minimum of 100 renters with income less than 50 percent of median in a target area AND 60 percent or more of these have a severe housing problem - paying more than half their income for rent, overcrowded, or without kitchen or plumbing based on 2007-11 ACS data provided by HUD) or as a result of the effects of the disaster there is a new high risk of damage to more than 100 assisted rental housing units from a future event the intended intervention would protect against. Applicants must provide a 1-2 paragraph description, with supporting data, to demonstrate this characteristic.

(c) Disaster impacted a federal target area or economically fragile area. The affected area is a tribal area, contains a Promise Zone, is in a Strong Cities

Strong Communities site, and/or has an unemployment rate more than 125 percent of the national average unemployment rate. Applicants must demonstrate this characteristic and provide supporting documentation.

(d) Disaster impacted an area with prior documented environmental distress. For example, the affected area contains or is adjacent to and negatively affected by a contaminated property cleaned, undergoing cleanup, or proposed for cleanup. States maintain a list of “brownfield” sites, many of which are linkable via this source:

http://www.huduser.org/CDBGRDR/AppendixD http://www.hud.gov/promisezones/ http://www.huduser.org/portal/sc2/home.html http://www.huduser.org/portal/sc2/home.html http://www.epa.gov/brownfields/state_tribal/state_map.htm. Applicants must demonstrate the prior documented environmental distress.

(e) Housing. A concentration of housing damage in a sub-county area due to the eligible disaster causing damage or serious damage to at least 10 percent of the homes located there. Appendix C provides a list of disasters with concentrations of housing damage meeting this requirement. Applicants may also submit local data, provided a) the data show concentrated damage meeting this standard, and b) HUD agrees with the validity of the data (see http://www.HUDUSER.org/CDBGRDR/AppendixC

III. Demonstrating Unmet Recovery Needs Threshold Requirement

To meet the Unmet Recovery Need threshold requirement, the applicant must submit an Exhibit

B narrative that demonstrates, with the criteria described in A or B below, that the applicant has

Unmet Recovery Needs in the area(s) identified as “most impacted and distressed” that have not been addressed by other sources. Other sources include but are not limited to insurance, state and local funds, SBA disaster loans, FEMA, Army Corps of Engineers, non-profit contributions, or prior allocations of CDBG funds.

Applicants may choose to submit information separately quantified for each of the areas identified as “most impacted and distressed” in which the applicant wishes to expend grant funds; however, Unmet Recovery Needs information aggregated for all identified most impacted and distressed areas will also be accepted for threshold purposes. Note that, for construction projects or programs you may include the reasonable extra costs related to implementing the project or program in a prudent, resilient manner. Also, you only need to respond to the minimum requirements for threshold purposes, but for purposes of responding fully to the Phase

1 and Phase 2 factors in the NOFA, you must identify and demonstrate all Unmet Recovery

Needs you intend to use CDBG-NDR funds to address.

A. For a target area that is within a County that was previously determined by HUD to be most impacted (for Applicants with a previous allocation of CDBG Disaster Recovery funds in response to major disasters in 2011, 2012 or 2013) Applicants need to provide information that meets a minimum of one of the following items for each target area in which the Applicant would expend CDBG-NDR funds:

1. Housing. Are prior CDBG-DR funding allocations, together with other funding sources, inadequate for addressing remaining housing repair needs in each most impacted and distressed target area? If no for a target area, you do not have Unmet Recovery Needs for this subfactor. If yes:

Indicate the number of households that would continue to be displaced or homes or rental units that will not be served by existing programs due to inadequate funding.

(Twenty or more households displaced by the disaster or twenty homes still damaged by the disaster must be documented to meet this requirement.)

Acceptable data sources (any one of these is sufficient for threshold purposes):

(a) If you are running a CDBG-DR or other recovery housing program, an analysis that http://www.epa.gov/brownfields/state_tribal/state_map.htm shows that the program waiting list and a reasonable estimate of aggregate average unmet repair needs (after insurance, FEMA, SBA) exceeds the existing CDBG-DR funds available. (Total repair costs can include the reasonable extra cost to buyout homes or repair homes resiliently, e.g., extra cost to elevate or build a safe room.)

(b) If not running a CDBG-DR or other recovery housing program currently, briefly explain why prior allocations of CDBG-DR funding, together with other funding sources, are inadequate to provide a housing program AND:

i. Recent emergency management data indicating households are still displaced from the disaster. This might include information from FEMA on number of households still receiving emergency rental assistance or living in a FEMA Transitional

Housing Unit. This could also include information from homeless providers indicating that they are still serving households that lost their housing due to the disaster; OR

ii. A methodologically sound “windshield” survey of the target area within a HUD-identified most impacted county conducted since January 2014. A list of 20 addresses needs to be provided to HUD of units identified with remaining damage.

A survey of at least 9 of these addresses confirming (i) the damage is due to the disaster and (ii) they have inadequate resources from insurance/FEMA/SBA for completing their repairs. Statistical accuracy is not required, so this can be a purposive sample of easy-to-contact residents.

2. Infrastructure. Is there damage to permanent public infrastructure (i.e. FEMA Category

C to G) that has not yet been repaired due to inadequate resources (and for which no

CDBG-DR funding has been identified in an action plan), in or serving the target area(s) within a HUD-identified most impacted county? If no, then you do not have Unmet

Recovery Needs for this subfactor. If yes:

Describe the damage, the location of the damaged permanent public infrastructure relative to the most impacted and distressed target area(s), the amount of funding required to complete repairs, and the reason there are inadequate funds. There must be a minimum of $400,000 in unfunded permanent infrastructure repair needs to meet this requirement, this “unfunded” amount can include the local match requirement for

FEMA Public Assistance or Department of Transportation permanent infrastructure projects. (If you include the amount of cost share for a U.S. Army Corps of Engineers project, note that no more than $250,000 of CDBG-DR or CDBG-NDR may be used for such a cost share (per project). This is not waiveable.)

Acceptable data source: An engineering report or FEMA Project Work Sheet(s) with an estimated repair amount AND a sources and uses statement for the repairs showing the funding shortfall (total repair costs may include the extra cost to repair this infrastructure resiliently), AND, your explanation of why existing CDBG-DR resources, together with other funding sources, are inadequate to meet this repair need.

3. Economic Revitalization. Are there continuing unmet economic revitalization recovery needs due to the disaster in the target area(s) within a HUD-identified most impacted county that cannot be addressed with existing resources, including CDBG-DR funds already allocated? If no, you do not have Unmet Recovery Need for this subfactor. If yes:

Describe the extent of those needs and how the needs are connected with the disaster and the target area within a HUD-identified most impacted county. Any one of the following, together with a narrative statement describing how the need results from the impacts of the disaster, would satisfy this requirement:

(i) a minimum of 5 businesses with remaining repair needs;

(ii) business revenues continued to be decreased by 10 percent or more relative to revenues prior to the disaster for one or more modest-sized employers (10 or more employees) due to the disaster; OR

(iii) three or more smaller businesses show revenues 10 percent less than prior revenues.

Acceptable data source (any one of these is sufficient for threshold purposes) HUD recognizes that information related to specific businesses may be sensitive, so is explicitly noting that you may submit documentation for this factor via a password-protected data link, as described above. Clearly label any sensitive information and HUD will limit disclosure of covered information as required by federal FOIA requirements.

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

A narrative from the Applicant must describe how the need results from the impacts of the disaster based on:

(a) Unmet repair needs for businesses: “Windshield” survey showing a minimum of 5 businesses with remaining repair needs AND a survey of 5 business owners confirming damage due to the disaster and repairs not completed due to not receiving adequate resources from insurance and (if applicable) other federal funds including

CDBG, CDBG-DR, and/or SBA funds. Addresses of businesses with continuing needs must be provided, OR

(b) Decreased revenues for business (es): Analysis by a reputable public or private source showing continuing economic damage to the target area within a HUD-identified most impacted county due to the disaster or a survey of business (es) who provide (i) number of employees before storm and current; (ii) total gross revenues in year before disaster and total gross revenues in most recent year; and (iii) a description of how the reduction in revenues is related to the disaster. To meet this criteria – one modest size employer (10 or more employees) or three smaller businesses (fewer than 10 employees) must show most recent year total gross revenues of 10 percent less than the year before the disaster and there needs to be a clear connection to the disaster. Names and addresses of impacted businesses must be provided.

4. Environmental Degradation. Environmental Degradation that threatens long-term recovery of critical natural resources and places housing, infrastructure, and/or economic revitalization at risk. Is there environmental damage from the disaster that has not yet been addressed and cannot be addressed with existing resources? If not, you do not have Unmet Recovery Needs for this subfactor. If yes:

Describe the remaining damage and how the damage is connected with the disaster and the target area within a HUD-identified most impacted county. Applicants must describe the remaining damage to the environment with a cost estimate for making repairs or restoration that is $400,000 or greater and support with references to any studies supporting the claim.

Acceptable data source (any one of these) is a detailed report from a reputable public or private organization describing the remaining damage with a certification after March

2014 indicating that there is remaining damage of $400,000 or more.

B. Applicants without a previous allocation of CDBG Disaster Recovery funds in response to major disasters in 2011, 2012 or 2013 proposing a sub-county most impacted and distressed target area, OR Applicants with a previous allocation proposing a sub-county target area that lies outside of a HUD-determined most impacted county (MIC), must provide information that meets a minimum of one (1) of these items:

1. Housing. Are households still displaced from housing due to the disaster or are there housing units in or near the most impacted and distressed sub-county target area that were damaged by the disaster and have not yet been repaired? If no, you do not have Unmet

Recovery Needs for this subfactor. If yes:

Indicate the number of households still displaced or homes with remaining repair needs that will not be served by existing programs, including CDBG-DR programs, due to inadequate funding. Twenty or more displaced households or twenty still damaged homes must be documented to meet this requirement.

Acceptable data sources (any one of these is sufficient for threshold purposes):

(a) If you are running a CDBG-DR or other recovery housing program, an analysis that shows that the program waiting list and a reasonable estimate of aggregate average unmet repair needs (after insurance, FEMA, SBA) exceeds the existing CDBG-DR funds available. (Total repair costs can include the reasonable extra cost to buyout homes or repair homes resiliently, e.g., extra cost to elevate or build a safe room.)

(b) If not running a CDBG-DR or other recovery housing program currently, briefly explain why prior allocations of CDBG-DR funding, together with other funding sources, are inadequate to provide a housing program AND provide:

(i) Recent emergency management data indicating households are still displaced from the disaster. This might include information from FEMA on number of households still receiving emergency rental assistance or living in a FEMA Transitional Housing

Unit. This could also include information from homeless providers indicating that they are still serving households that lost their housing due to the disaster; OR

(ii) A methodologically sound “windshield” survey of the most impacted and distressed…