Action Plan Amendment No. 1 Community Development Block Grant Funds in response to the Great Floods of 2016 By: Contributor (Contributor) Comments 610 views #APA Location: LA DR-4277 DR Date: 9/13/2016 Published: 6-12-2018 Updated: 6-15-2018 Disaster: Floods and flash floods Dept.: OCD-DRU Print View Ocd Dru index View PDF × No Supported Browser PDF viewer. Action Plan Amendment No. 1 for the utilization of Community Development Block Grant Funds (CDBG) in response to the Great Flood of 2016 Public Comment Period: February 1 to 15, 2017 DISASTER RECOVERY INITIATIVEU.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Allocations, Waivers and Alternative Requirements for Grantees Receiving Community Development Block GrantDisaster Recovery Funds in Response to Disasters Occurring in 2016The Continuing Appropriations Act, 2017 (Public Law 114-223 and 114-254)Federal Register Docket No.FR-5989-N-01 and FR–6012–N–01LOUISIANA OFFICE OF COMMUNITY DEVELOPMENT, DISASTER RECOVERY UNIT STATE OF LOUISIANA PROPOSEDACTION PLAN AMENDMENT NO. 1FOR THE UTILIZATION OFCOMMUNITY DEVELOPMENT BLOCK GRANT FUNDSIN RESPONSE TO THE GREAT FLOODS OF 2016Public Comment Period: February 1 – 15, 2017 John Bel EdwardsGovernorBilly NungesserLieutenant Governor Table of Contents 1. Summary of Changes ........1 2. Executive Summary..........3 A. March Storm (DR-4263)......3 B. August Storm (DR-4277).....3 C. Anticipated Unmet Needs Gap .....4 D. Conclusion ......................5 E. Maps......6 1. FEMA Impacted Parishes and Federal Declarations: DR-4263 (March 2016 floods).....6 2. FEMA Impacted Parishes and Federal Declarations: DR-4277 (August 2016 floods)....7 3. Army Corps of Engineers Map – August Deluge Amounts................8 3. Impact and Unmet Needs Assessment.....9 A. Background...................9 B. Housing Impact & Needs ......................9 1. Demographic Profile of the Affected Areas..............9 2. Statewide Housing Damage and Loss Assessment .16 3. Unmet Housing Needs....................51 C. Economic Impact & Needs..................56 1. Statewide Economic Damage & Loss Assessment..56 2. Unmet Economic Needs..................60 D. Infrastructure Impact & Needs...........63 1. Statewide Infrastructure Damage & Loss Assessment ...................63 2. Unmet Infrastructure Needs...........63 3. Resilience Gaps .......65 E. Public Service Unmet Needs...............70 F. Summary of Unmet Needs & Additional Considerations....................71 G. Anticipated Unmet Needs Gap...........73 4. Method of Distribution and Connection to Unmet Needs.....................74 A. Method of Distribution Process..........74 B. Connection to Unmet Needs ..............74 C. Allocation of Funds .....75 5. Proposed Use of Funds ...76 A. State Implemented Programs.............76 1. Housing ...................76 2. Economic Revitalization..................92 3. Infrastructure ..........98 4. Vulnerable Populations...................99 B. Leveraging Funds......100 1. Housing .................100 2. Economic Development................101 3. Infrastructure ........101 4. Mitigation..............101 5. Other Sources of Funds.................101 C. Contractor Standards and Appeals Process..............101 D. Planning and Coordination...............102 6. Citizen Participation......104 A. Citizen Participation Plan..................104 1. Citizen Input..........105 2. Louisiana Disaster Housing Task Force .................105 3. Restore Louisiana Task Force........105 4. Consultation with Units of Local Government, Tribes and Stakeholders.............106 B. Citizen Complaints....108 C. Receipt of Comments108 D. Amendments to the Disaster Recovery Action Plan.108 1. Substantial Amendments..............108 2. Submittal of Amendments............108 1. Summary of Changes The sections below outline the State of Louisiana's plan to utilize the full amount of funding appropriated to date. Unmet NeedsThe state amended the following areas of the unmet needs from the initial Action Plan: In 82 FR 5591, HUD identified four additional parishes (Acadia, St. Tammany, Vermilion, and Washington). The state refreshed all charts and maps referencing most impacted and distressed areas to include the additional parishes. The state updated the calculation methodology for rental housing unmet needs. The state shifted $30,000,000 initially allocated to the Restore Louisiana Homeowner Program tothe rental housing programs. The state included updated Small Business Administration data for both homeowners and business data in all unmet need calculations. The state included updated NFIP data for both homeowners and business for Disaster 4277 in all unmet need calculations. The state included an update on the impact of the storms on the homeless population including the Temporary Shelter Assistance population. Method of Distribution and Connection to Unmet Needs The state refreshed the Method of Distribution and Connection to Unmet Needs to include the updatedunmet needs numbers based on the new data and the connection to the second allocation of funding. Proposed Use of Funds Restore Louisiana Homeowner Rehabilitation, Reconstruction and Reimbursement Program The state provided an updated summary of the program and with the increase in funding expanded the prioritization Phases to include Phases II-VI. The state also added a methodology for ensuring the benefit cost analysis was completed to determine if a voluntary acquisition or buyout should be considered. Restore Louisiana Rental Housing Programs The state updated the summary of the programs, eligible activities, and expanded the budget to includethe second allocation of funds. Infill and Rehabilitation Rental Program This program name was changed along with a change to the eligibility criteria for the program. Multifamily Rental Gap Program The state updated the summary of the program, the eligible applicants and the prioritization to include affordability requirements. Additionally, the state changed the maximum award to a per unit maximum award rather than a project maximum award. Piggyback Program The state added in a Piggyback program which will leverage CDBG-DR with low income housing tax credits (LIHTCs) or other sources to address the longer-term affordable housing recovery needs of the impacted communities. Rapid Rehousing Program The state added the Rapid Rehousing Program to address the needs of the homeless and persons at risk of becoming homeless by providing a combined solution of affordable housing and support services that assist displaced households in their endeavors to become self-sufficient. Permanent Supportive Housing Services Program The state added a Permanent Supportive Housing Program to further address the unmet needs of those experiencing homelessness and the at-risk homeless population. The model described will assist individuals in transitioning into Permanent Supportive Housing and maintaining successful, long-term tenancies. Restore Louisiana Economic Revitalization Programs The state updated the summary of the programs, eligible activities, and expanded the budget to include the second allocation of funds. Additionally, the state further described the tie of the impact of the Economic Revitalization Programs to meeting the unmet housing needs. Small Business Loan and Grant Program The state updated the Small Business Loan and Grant Program to include updated eligible activities, additional information regarding the eligibility criteria and a change in the maximum award. Small Business Technical Assistance Program The state updated the Small Business Loan and Grant Program to include updated eligible activities and additional information regarding the eligibility criteria. Small Business Bridge Loan Program The program description was updated to note that the state will not administer the program at this time. Louisiana Farm Recovery Grant Program To address the unmet needs of the Agricultural sector, the state has added the Louisiana Farm Recovery Grant Program. The program will assist individual farm enterprises impacted by the great floods of 2016. FEMA Public Assistance Nonfederal Share Program To meet the unmet infrastructure needs outlined in the Action Plan and Action Plan Amendment, the state has created the FEMA Public Assistance Nonfederal Share Match Program. This program will work with eligible entities to pay the nonfederal share cost of the disaster cleanup and recovery efforts. Leverage of Funds The Action Plan Amendment provides updates regarding the leverage of funding sources identified. Citizen Participation The Citizen Participation section provides updates to the process for the Action Plan Amendment. Additionally, as part of the outreach and consultation with local governments, the state has continued the resilient long-term recovery planning. This section reflects the additional work and efforts the state has undertaken, and demonstrates the commitment to continue efforts throughout the state. 2. Executive Summary In 2016, Louisiana had two separate events that qualified for appropriation under Public Laws 114-223 and 114-254. The state experienced severe storms and flooding in both March (Disaster Number 4263) and August (Disaster Number 4277) 2016 – collectively referred to as the 2016 Severe Storms and Flooding – resulting in 56 of the state's 64 parishes receiving a federal disaster declaration. From the March event, more than 16,462 homes have Federal Emergency Management Agency (FEMA) Verified Loss and 5,222 renters have FEMA Verified Loss (FVL), for a total of 21,684 households. The National Weather Service designated the August flooding event that dropped an unprecedented 7 trillion gallons of rainwater in South Louisiana as a “1,000-year” rainfall event. It resulted in the flooding of more than 68,380 homes with FVL and 23,248 renters with FVL, for a total of 91,628 households. The August storm claimed 13 lives. A. March Storm (DR-4263)In early March 2016, a storm system brought heavy thunderstorms from west to east across most ofLouisiana. In addition to wind damage, record flooding occurred along the Bogue Falaya River in Covingtonand Bayou Dorcheat at Lake Bistineau. Governor John Bel Edwards declared a state of emergency forseveral parishes and sent the National Guard to help with search-and-rescue missions.The State of Louisiana estimates that this storm caused damage to more than 21,684 residences, forced13,000 evacuations and 2,780 rescues, damaged another 6,143 structures, and caused numerous roadclosures. Road and bridge damage estimates totaled $20 million. Agricultural losses totaled approximately$15 million, with long-term impacts to farmers estimated at $80 million. In addition, more than 40,000citizens registered for FEMA Individual Assistance (IA).Thirty-six Louisiana parishes were declared eligible for FEMA IA: Allen, Ascension, Avoyelles, Beauregard,Bienville, Bossier, Caddo, Calcasieu, Caldwell, Catahoula, Claiborne, DeSoto, East Carroll, Franklin, Grant,Jackson, LaSalle, Lincoln, Livingston, Madison, Morehouse, Natchitoches, Ouachita, Rapides, Red River,Richland, Sabine, St. Helena, St. Tammany, Tangipahoa, Union, Vernon, Washington, Webster, WestCarroll and Winn. Seven of these parishes also flooded in August: Ascension, Avoyelles, Livingston, St.Helena, St. Tammany, Tangipahoa and Washington. B. August Storm (DR-4277)In mid-August 2016, a slow-moving storm impacted multiple South Louisiana parishes with sustainedheavy rain. In what was a 1,000-year flood, within two days more than two feet of rain was measured insome areas, causing extensive surface and river flooding. Both the Amite and Comite rivers overtopped,as well as numerous bayous, lakes and canals located within these drainage basins. Governor John BelEdwards declared a state of emergency for several parishes and sent the National Guard to help withsearch-and-rescue missions. An estimated 8,000 people were evacuated to emergency shelter sites. The American Red Cross, the stateand faith-based organizations operated these sites. A state-operated medical site was established to serveindividuals with medical needs. Roughly 30,000 search and rescues were performed, with 11,000 citizenssheltered at the peak of the flood.The damage to infrastructure, businesses and homes across the southern region of the state wasextensive. Large sections of state roads remained under water for extended periods. An estimated 30state roads washed out and 1,400 bridges require inspection. Along with more than 200 highways thatclosed during the event, sections of Interstates 10 and 12 closed for multiple days due to floodwaters.Some stretches of I-10 remained closed for nearly a week, significantly interrupting interstate commerce. More than 91,628 homes have documented damages to date, with the number expected to rise as FEMAregistrations and inspections conclude. An estimated 31 percent of homes in the declared parishes wereimpacted by flooding, with only 11 percent of households in these areas carrying flood insurance. Basedon current registration numbers and historic trends, it is estimated that nearly 200,000 households willapply for IA, with an estimated housing unmet need in excess of $2.7 billion.Immediately following the August 2016 flooding event, the Louisiana Department of EconomicDevelopment partnered with Louisiana State University to conduct an assessment of economic lossesresulting from the floods. Key details are:>> At the peak of the August event, 19,900 Louisiana businesses or roughly 20 percent of all Louisianabusinesses were disrupted by the flooding event. FEMA has since referred approximately22,000 businesses to SBA for recovery assistance.>> A disruption of 278,500 workers or 14 percent of the Louisiana workforce occurred at the peak ofthe flooding event.>> An economic loss estimated at roughly $300 million in labor productivity and $836 million interms of value added during the period immediately surrounding the flood.>> Approximately 6,000 businesses experienced flooding.>> The LSU Ag Center estimates Louisiana agricultural losses of over $110 million.Twenty-two Louisiana parishes were declared eligible for FEMA IA: Acadia, Ascension, Avoyelles, East andWest Baton Rouge, East Feliciana, Evangeline, Iberia, Iberville, Jefferson Davis, Lafayette, Livingston,Pointe Coupee, St. Helena, St. James, St. Landry, St. Martin, St. Tammany, Tangipahoa, Vermilion,Washington and West Feliciana. Seven of these parishes also flooded in March: Ascension, Avoyelles,Livingston, St. Helena, St. Tammany, Tangipahoa and Washington. C. Anticipated Unmet Needs GapDuring the October 10 Congressional Session, state government officials, including Gov. John Bel Edwards,traveled to Washington D.C. and worked collaboratively with Louisiana's Congressional Delegation tosecure long-term disaster recovery resources in response to DR-4263 and DR-4277. Working with limiteddisaster loss unmet need information, Louisiana's delegation proposed a relief package of nearly $3.8billion. This package focused primarily on housing needs, as the state has prioritized housing as the mosturgent and pressing recovery concern following the two flooding events. Through this Action Plan, thestate now presents revised unmet need estimates based on current best available data. Over time, thestate will likely continue to update these estimates as additional assessments are made and morecomplete data become available.Accounting for the initial appropriation of $437,800,000 and the second appropriation of $1,219,172,000for long-term recovery purposes, the state has calculated a remaining unmet need of $5,070,928,237. Summary of Total Unmet NeedsCategory Losses/GapsKnownInvestmentsRemaining UnmetNeed Owner-Occupied Housing $2,448,293,435 $2,448,293,435Homeowner Rehabilitation and Reconstruction (CDBG-DR) ($1,293,693,120) ($1,293,693,120)Rental Housing $254,798,970 $254,798,970In-fill and Repair Rental Program (CDBG-DR) ($45,000,000) ($45,000,000))Multi-family Gap Program (CDBG-DR) ($45,000,000) ($45,000,000)Piggyback Program (CDBG-DR) ($19,000,000) ($19,000,000)Public Housing $8,539,159 ($4,492,053) $4,047,106Homeless Assistance $5,250,232 $5,250,232Rapid Rehousing (CDBG-DR) ($16,000,000) ($16,000,000)PSH Support Services (CDBG-DR) ($5,000,000) ($5,000,000)Agriculture Losses (DR-4277) $110,244,069 $110,244,069Agriculture Losses (DR-4263) $80,285,185 $80,285,185Business Structures $595,600,000 $595,600,000Business Equipment $262,800,000 $262,800,000Business Inventories $1,425,500,000 $1,425,500,000Business Interruption Loss $836,400,000 $836,400,000SBA Business/EIDL Loans ($160,400,000) ($160,400,000)Small Business Program (CDBG-DR) ($51,200,000) ($51,200,000)Small Business Technical Assistance Program (CDBG-DR) ($800,000) ($800,000)Louisiana Farm Recovery Program ($10,000,000) ($10,000,000)PA State Share $106,096,475 $106,096,475FEMA PA Match Program (CDBG-DR) ($105,000,000) ($105,000,000)HMGP State Share $92,705,885 $92,705,885Resilience Gaps $600,000,000 $600,000,000Totals $6,826,513,410 ($1,755,585,173) $5,070,928,237*CDBG-DR investments are inclusive of program delivery costs. D. ConclusionAs a result of the 2016 Severe Storms and Flooding, the State of Louisiana received two allocations (PublicLaw 114-223 and 114-254) of Community Development Block Grant Disaster Recovery (CDBG-DR)funding. To fulfill the requirements of this allocation, the state must submit an Action Plan for DisasterRecovery that identifies its unmet recovery and resilience needs to the Department of Housing and UrbanDevelopment (HUD). Governor Edwards has designated the state Office of Community Development -Disaster Recovery Unit (OCD-DRU) as the administering agency for these recovery funds. On behalf of theState of Louisiana, OCD-DRU developed the following Action Plan to outline the proposed use of theCDBG-DR funds and eligible activities available to assist declared parishes to meet unmet housing,economic revitalization, public service, infrastructure, planning and other needs that arose as a result ofthese two storm events. E. Maps1. FEMA Impacted Parishes and Federal Declarations: DR-4263 (March 2016 floods)72. FEMA Impacted Parishes and Federal Declarations: DR-4277 (August 2016 floods)83. Army Corps of Engineers Map – August Deluge Amounts 93. Impact and Unmet Needs AssessmentA. BackgroundIn accordance with HUD guidance, the State of Louisiana completed the following unmet needsassessment to identify priorities for CDBG-DR funding allocated as a result of two separate significant rainand flooding events, DR-4263 in March and DR-4277 in August. Combined, these disasters affected 56 ofthe state's 64 parishes, with 51 parishes declared eligible for FEMA IA. The assessment below utilizesfederal and state resources, including data provided by FEMA, HUD and the Small Business Administration(SBA), among other sources, to estimate unmet needs in three main categories of damage: housing,economy and infrastructure. HUD has identified the 10 most impacted parishes from these two events asAcadia, Ascension, East Baton Rouge, Lafayette, Livingston, Ouachita, St. Tammany, Tangipahoa,Vermilion and Washington. This unmet needs assessment focuses on statewide impacts, with specificsections detailing particular needs within the most impacted areas, and where relevant, smallergeographic units.B. Housing Impact & Needs1. Demographic Profile of the Affected AreasMore than 72 percent of the state's population is located within the 51 IA parishes affected by DR-4263or DR-4277 floods. Of this total, 48 percent of the population residing in the 51 IA parishes is locatedwithin one of the 10 parishes identified by HUD as most impacted, including three of the state's largestmetropolitan areas, Baton Rouge, Lafayette and Monroe, as well as two parishes currently experiencingsignificant population growth, Ascension and Livingston. It is important to note that the populationresiding within the 10 most impacted parishes comprises 34.84 percent of the state's total population. 10Although the affected region tends to share similar demographic trends with the state as a whole, thereare several key areas (African-American population, education level, and poverty indicators) in which thedata differ. Unless otherwise noted, all data cited in this section are from the Census Bureau's 2014 fiveyearestimates from the American Community Survey (ACS).With respect to the parishes HUD has designated as most impacted, six were included in the initialallocation of CDBG-DR funding and an additional four were included in the second allocation. A breakdownof the parishes designated in each allocation is in the table below:HUD-Designated Most Impacted ParishesInitial Allocation Second AllocationAscension AcadiaEast Baton Rouge St. TammanyLafayette VermilionLivingston WashingtonOuachitaTangipahoaOf the 10 most impacted parishes, six parishes, including Ascension, East Baton Rouge, Lafayette,Livingston, Ouachita and Tangipahoa were more severely impacted than Acadia, St. Tammany, Vermilionand Washington. The initial six most impacted parishes have a slightly larger African-American populationcompared to the balance of state and the other IA parishes. By percentage, 32.31 percent of thepopulation in the six most impacted parishes is African-American, which is roughly 1 percentage pointmore than that of the state as a whole (31.91 percent) and almost 2 percentage points more than that ofthe 51 IA parishes (30.67 percent). By comparison, the African American population of the additional fourmost impacted parishes is 15.1 percent. At the parish level, East Baton Rouge (45.20 percent) andOuachita (37 percent) parishes have the largest proportion of African-American residents, while anothermost impacted parish, Livingston is only 6 percent African-American.Within the initial six most impacted parishes, 27.74 percent of the population age 25 years or older hadattained a bachelor's degree or higher. This number is roughly 5 percentage points more than both thestatewide total (22.55 percent) and the 51 IA parishes (22.13 percent). Educational attainment for theadditional four most impacted parishes was also higher than both the state and the 51 IA parishes (25.10percent). This may be attributable to the presence of five major universities within the most impactedparishes. Louisiana State University (East Baton Rouge), Southern University (East Baton Rouge), theUniversity of Louisiana at Lafayette (Lafayette), the University of Louisiana Monroe (Ouachita) andSoutheastern Louisiana University (Tangipahoa) are five strategically important educational institutionsas well as significant economic drivers for their regions and the state as a whole.Of the initial six most impacted parishes, there are significant outliers worth noting in reference toeducational attainment. For example, in Tangipahoa Parish 19.45 percent of the population aged 25 orolder has a bachelor's degree or higher, proportionally 14.86 percentage points less than that of EastBaton Rouge Parish and 8.29 percentage points less than the six most impacted parishes combined. Ofthe 10 most impacted parishes, East Baton Rouge had the highest proportion of population age 25 orolder with a bachelor's degree or more at 34.31 percent, followed by St. Tammany Parish at 30.37 percent.11Housing and income demographics also highlight differences between the 51 IA parishes and the state asa whole. For instance, the 51 IA parishes have a median owner-occupied housing unit value and medianhousehold income that are significantly lower than that of the state. The median value of owner-occupiedhousing units in the 51 IA parishes is $91,225, $49,175 less than the statewide total ($140,400).Meanwhile, the most impacted parishes collectively have a higher median owner-occupied housing unitvalue than the statewide total. The median owner-occupied housing unit value for the initial six mostimpacted parishes is $157,450, $17,050 higher than statewide. Those same parishes also have a largerproportion of renters than both the state and the other IA parishes. At 30.87 percent, the initial six mostimpacted parishes collectively are home to a renter population that is almost 3 percentage point higherthan the other IA parishes (27.73 percent) and more than 1 percentage point higher than the statewidetotal (29.12 percent). Renter population for the additional four parishes is 21.7 percent.The 51 IA parishes have a median household income of $39,347, $5,644 less than the statewide medianhousehold income of $44,991. In addition to a lower median household income, the 51 IA parishes havea per capita income that is significantly less than that of the state as a whole. The 51 IA parishes have aper capita income of $21,456, $3,319 less than the statewide per capita income of $24,775.Poverty indicators across the affected area also deviate from statewide totals. In the initial six mostimpacted parishes, the proportion of people with income below the poverty line is higher than the otherIA parishes or statewide totals. 27.22 percent of households in the most impacted area have incomesbelow the poverty line, 8.21 percentage points more than statewide totals and 7.89 more than the otherIA parishes, respectively. Comparatively, 14.8 percent of households in the additional four most impactedparishes had incomes below the poverty line.Demographic Profile2010-2014 American Community Survey 5-Year EstimatesLouisiana 51 PDD Parishes 10 Most Impacted ParishesDemographics Estimates % of State Estimates% of 51PDD Estimates % of 10 MITOTALPOPULATION: 4,601,049 100.00% 3,317,519 100.00% 1,602,912 100.00%Under 5 years 311,324 6.77% 227,206 6.85% 109,202 6.81%65 years and over 593,807 12.91% 430,421 12.97% 191,914 11.97%White alone 2,748,538 59.74% 2,084,305 62.83% 1,086,731 67.80%Black or AfricanAmerican alone 1,468,208 31.91% 2,084,305 30.67% 449,596 28.05%American Indianand Alaska Nativealone 25,498 0.55% 13,542 0.41% 4,420 0.28%Asian alone 74,878 1.63% 41,325 1.25% 26,133 1.63%Native Hawaiianand Other PacificIslander alone 1,604 0.03% 1,147 0.03% 391 0.02%Two or more races 64,641 1.40% 45,508 0.99% 24,929 1.56%Hispanic or Latino 210,524 4.58% 109,878 3.31% 59,724 3.73%12Population 16 yearsand over in civilianlabor force 2,192,054 47.64% 1,555,399 46.88% 769,514 48.01%Louisiana 51 PDD Parishes 10 Most Impacted ParishesHousingDemographics Estimates % of State Estimates% of 51PDD Estimates % of 10 MITOTAL HOUSINGUNITS: 1,988,460 100.00% 1,410,498 100.00% 665,392 100.00%Average HouseholdSize 2.61 (X) 2.60 (X) 2.66 (X)Owner-occupied 1,139,756 57.32% 836,710 59.32% 405,347 60.92%Renter-occupied 579,120 29.12% 391,076 27.73% 189,930 28.54%Median Value ofowner-occupiedhousing units (in2014 dollars) $140,400.00 (X) $ 91,225.00 (X) $143,250 (X)Median gross rent(in 2014 dollars) $ 786.00 (X) $ 614.25 (X) $ 759.00 (X)TOTALHOUSEHOLDS: 1,718,876 100% 1,227,786 71% 595,277 89.5%Civiliannoninstitutionalizedpopulation withouthealth insurance 747,454 16.25% 527,873 15.91% 245,780 15.53%Estimate ofnoninstitutionalizedpopulation with adisability* 674,156 15% 495,017 15% 221,242 9.79%Language otherthan EnglishSpoken at Home,Over Age of 5* 369,719 9% 221,293 7% 120,374 8%2015 BuildingPermits** 12,222 (X) 10,264 (X) 6,726 (X)Louisiana 51 PDD Parishes 10 Most Impacted ParishesIncome/EconomicDemographics Estimates % of State Estimates% of 51PDD Estimates % of 10 MIMedian householdincome (in 2014dollars) $ 44,991.00 (X) $ 39,347.75 (X) $ 47,939.50 (X)Per capita income(in 2014 dollars) $ 24,775.00 (X) $ 21,456.25 (X) $ 24,405.50 (X)Income in the past12 months belowpoverty level: 874,638 19.01% 641,395 19.33% 273,554 17.46%Louisiana 51 PDD Parishes 10 Most Impacted Parishes13EducationDemographics Estimate % of State Estimate% of 51PDD Estimates % of 10 MIPopulation 25 yearsand over: 2,932,993 100.00% 2,081,554 100.00% 1,026,485 100.00%Less than highschool graduate 486,080 16.57% 333,637 16.03% 140,378 13.68%High schoolgraduate (includesequivalency) 991,471 33.80% 718,245 34.51% 322,095 31.38%Some college,associate's degree 793,996 27.07% 568,935 27.33% 284,411 27.71%Bachelor's degreeor higher 661,446 22.55% 460,737 22.13% 268,800 26.19%Source: U.S. Census Bureau, 2010-2014 American Community Survey 5-Year Estimates**U.S. Census Bureau, 2015 Building Permits, Reported Units, http://censtats.census.gov/bldg/bldgprmt.shtmlTABLES: B17001, S1701, DP03, DP04, DP05Social Vulnerability Index (SoVI)SoVI is a tool for assessing pre-existing vulnerabilities to environmental hazards. The index is acomparative metric that facilitates the examination of differences in social vulnerability at a certain levelof geography. The index, in this iteration, synthesizes 27 socioeconomic variables, which, with supportfrom research literature, can contribute to a reduction in a community's ability to prepare for, respond toand recover from hazards. The SoVI built in this assessment is primarily derived from U.S. Census Bureaudata. SoVI uses a combined assessment of 2010 U.S. Census data and the Five-Year American CommunitySurvey (2010-2014) and pulls from the mentioned 27 individual data points across geographic boundariesto determine relative social vulnerability across any given geography and is always relative to whateverspecific geography being analyzed. These 27 individual data points cut across six component groups: Classand Race, Non-Extractive (less rural) and Race, Age, Ethnicity and Race, Gender, Housing Characteristics(proportion of renters, occupants per unit, female heads of household, etc. For modeling purposes, both2010 U.S. Census data and the Five-Year Community Survey are current until the 2020 Census is completedand released.The SoVI created for the 51 IA parishes affected by DR-4263 or DR-4277 incorporates six generalcomponents synthesizing these 27 socioeconomic variables:>> Class and race>> Non-extractive (less rural)>> Age>> Ethnicity>> Gender>> Housing characteristics (persons per unit, renters, unoccupied units, female-headed households)SoVI has high utility as a decision-support tool for emergency management. The tool shows where thereis uneven capacity for preparedness and response and where resources might be used most effectively toreduce the pre-existing vulnerability. The SoVI metric turns historical disaster impact measures intoactionable information for emergency managers, recovery planners, and decision makers as a whole. It 14empirically measures and visually depicts a population's inability and/or ability to adequately prepare for,respond to, and rebound from disaster events.By coupling SoVI with other data sources, such as the IA dataset, NFIP data and SBA data, the state iscapable of identifying concentrations of greatest need for additional recovery resources. The state hascollaborated with its counterparts in South Carolina, who used this methodology to plan long-termrecovery efforts following its 2015 flooding events, to strategize how SoVI can be an apolitical approachfor distributing scarce disaster recovery dollars to provide optimal benefit to the places that were worstimpacted and least able to recover on their own from this disaster.A SoVI analysis of the 51 IA parishes indicates the areas with the highest levels of pre-existing socialvulnerability are in the metropolitan areas of Alexandria, Baton Rouge, Lafayette, Lake Charles, Monroeand Shreveport. For example, there are total of 38 “high” SoVI census tracts in these six metropolitanareas, representing more than 80 percent of the 47 “high” SoVI census tracts across the total 51 IAparishes. This is significant due to large concentrations of damage found in a few of these areas, notablyBaton Rouge, Lafayette and Monroe. Specifically, there are 18 “high” SoVI tracts in these three impactedmetropolitan areas. The six impacted metropolitan areas also have a high proportion of “medium high”SoVI tracts. Of the 140 total “medium high” SoVI tracts in the 51 IA parishes, 119 of those census tracts,or more than 66 percent, are within these six metropolitan areas. 66 of these “medium high” SoVI tractsare located within Baton Rouge, Lafayette and Monroe.The state will use the information from the SoVI analysis as a planning and implementation tool to ensurethe most vulnerable populations are engaged in the programs. Understanding the locations of the“medium high” to “high” SoVI census tracts will equip the state's outreach team with the informationneeded to further engage local governments, non-profits and other stakeholders representing these areasin order to coordinate efforts and understanding as how to best serve “medium high” to “high” SoVIcensus tracts residents. Additionally, the state will be able to use the SoVI analysis as a tool to ensurerobust engagement and participation of “medium high” to “high” SoVI census tracts through thetargeted efforts of the homeowner program manager who will ensure vulnerable populations areprovided the support needed to access the program. Another way in which the SoVI analysis will bedeployed as a useful tool for program planning is in the state's assessment and strategy for thedevelopment of affordable housing. Using the SoVI bivariate analysis will allow the state to considerracial, ethnic and low-income concentrations in order to work to provide affordable housing in lowpoverty,non-minority and low-risk areas.SoVI Summary:>> Alexandria – 3 “high” SoVI tracts (6 percent of the IA parish total) and 13 “medium high” SoVItracts (7 percent of the IA parish total).>> Baton Rouge – 8 “high” SoVI tracts (17 percent of the IA parish total) and 38 “medium high”SoVI tracts (21 percent of the IA parish total).>> Lafayette – 5 “high” SoVI tracts (11 percent of the IA parish total) and 16 “medium high” SoVItracts (9 percent of the IA parish total).>> Lake Charles – 2 “high” SoVI tracts (1 percent of the IA parish total) and 14 “medium high” SoVItracts (8 percent of the IA parish total).>> Monroe – 5 “high” SoVI tracts (11 percent of the IA parish total) and 12 “medium high” SoVItracts (7 percent of the IA parish total). 15>> Shreveport – 15 “high” SoVI tracts (32 percent of the IA parish total) and 26 “medium high”SoVI tracts (14 percent of the IA parish total).>> There are a total of 710 census tracts in the 51 IA parishes.>> There are 47 “high” SoVI tracts in the 51 IA parishes.>> There are 180 “medium high” SoVI tracts in the 51 IA parishes.Housing AffordabilityThe state is specifically concerned about housing affordability and the high proportion of householdsstatewide and in the affected area considered to be “cost burdened.” The standard measurement of rentalunaffordability considers any household that spends more than 30 percent of its pre-tax income onhousing as having an affordability problem. Housing is considered “affordable” if the rent (includingutilities) is no more than 30 percent of its pre-tax income. Households spending more than 30 percent are“cost burdened” or “rent-stressed,” and those spending more than 50 percent are labeled “severely costburdened” or “severely rent-stressed.”In a recent report released by the National Low Income Housing Coalition (NLIHC), in no state can aminimum wage worker afford a two-bedroom rental unit at the average fair market rent, working astandard 40-hour work week, without paying more than 30 percent of their income for housing. Theminimum wage in Louisiana is $7.25 per hour; however a household must earn $15.81 per hour to avoid 16paying more than 30 percent of income on housing (and utilities) to afford a 2-bedroom unit at the fairmarket rent of $822 per month.According to ACS data, 46 percent of Louisiana renters and 21 percent of homeowners are cost burdened,while 25 percent of renters and 9 percent of homeowners are severely cost burdened. In total, 501,610households statewide are cost burdened and 241,725 are severely cost burdened.Within the 51 IA parishes, a similar percentage of renters experience cost burden (45 percent) or severecost burden (23 percent) as compared to the state overall. Similarly, a comparable percentage ofhomeowners are cost burdened (19 percent) or severely cost burdened (8 percent) compared to the stateoverall. In total, 337,380 households in IA parishes are cost burdened, and 157,187 are severely costburdened.By comparison, renters in the 10 ten most impacted parishes experience cost burden (47 percent) andsevere cost burden (25 percent) at slightly higher rates than the state or IA areas overall. Homeownerswithin the most impacted parishes experience similar levels of cost burden (21 percent) and severe costburden (8 percent) compared to the IA parishes and state overall. In total, 173,139 households in the mostimpacted parishes are cost burdened, and 81,522 are severely cost burdened.Cost Burdened Renters and OwnersState ofLouisianaPresidentially DeclaredDisaster Areas10 Most ImpactedParishesCost Burdened Renters 267,146 174,938 88,921Percent of Renters with CostBurden 46% 45% 47%Severe Cost Burden Renters 144,224 91,611 48,308Percent of Renters with SevereCost Burden 25% 23% 25%Cost Burdened Owners 234,464 162,442 84,218Percent of Homeowners withCost Burden 21% 19% 21%Severely Cost Burdened Owners 97,501 65,576 33,214Percent of Homeowners withSevere Cost Burden 9% 8% 8%Source: U.S. Census Bureau, 2010-2014 American Community Survey 5-Year EstimatesMortgage Status by Selected Monthly Owner Costs as a Percentage of Household Income in the Past 12Months for Owner Occupied HousingGross Rent as a Percentage of Household Income in the Past 12monthsNote: Cost Burden is defined as renter or owner households spending over 30 percent of householdincome on rent or mortgage.2. Statewide Housing Damage and Loss AssessmentTo articulate the extent of damage, the state compiled information to document damages across severaldifferent population stratifications, including owner-occupied and renter households, households withoutflood insurance, households located outside of the Special Flood Hazard Area (SFHA), households withinthe six most impacted parishes, Low and Moderate Income (LMI) households, households with Access andFunctional Needs (AFN) and households with applicants aged 62 and older. 17For the purposes of this analysis, the state used full applicant-level data collected through FEMA's IAprogram. DR-4263 IA data were pulled on Nov. 10, 2016 and DR-4277 IA data were pulled on Nov. 3, 2016.Unless otherwise noted, all housing summary data were compiled from these two datasets.Furthermore, unless otherwise specifically noted, the state has defaulted to HUD's definitions of unmetneed for owner-occupied and renter households. For rental properties, to meet the statutory requirementof “most impacted,” homes are determined to have a high level of damage if they have damage of "majorlow"or higher. That is, they have a FEMA personal property damage assessment of $2,000 or greater orflooding over 1 foot. Furthermore, landlords were presumed to have adequate insurance coverage unlessthe unit is occupied by a renter with income of $20,000 or less. Units occupied by a tenant with incomeless than $20,000 were used to calculate likely unmet needs for affordable rental housing.To calculate the level of damage for rental households, the state used the following criteria:>> Minor-Low: Less than $1,000 of FEMA inspected personal property damage>> Minor-High: $1,000 to $1,999 of FEMA inspected personal property damage>> Major-Low: $2,000 to $3,499 of FEMA inspected personal property damage or more than 1 footof flooding on the first floor.>> Major-High: $3,500 to $7,499 of FEMA inspected personal property damage or 4 to 6 feet offlooding on the first floor.>> Severe: Greater than $7,500 of FEMA inspected personal property damage or determineddestroyed and/or 6 or more feet of flooding on the first floor.To calculate the level of damage for owner-occupied households, the state used the following criteria:>> Minor-Low: Less than $3,000 of FEMA inspected real property damage>> Minor-High: $3,000 to $7,999 of FEMA inspected real property damage>> Major-Low: $8,000 to $14,999 of FEMA inspected real property damage and/or more than 1 footof flooding on the first floor.>> Major-High: $15,000 to $28,800 of FEMA inspected real property damage and/or 4 to 6 feet offlooding on the first floor.>> Severe: Greater than $28,800 of FEMA inspected real property damage or determined destroyedand/or 6 or more feet of flooding on the first floor.The average cost for full home repair to code for a specific disaster within each of the damage categoriesnoted above is calculated using the average real property damage repair costs determined by the SBA forits disaster loan program for the subset of homes inspected by both SBA and FEMA for 2011 to 2013disasters. Because SBA inspects for full repair costs, it presumes to reflect the full cost to repair the home,which is generally more than FEMA estimates on the cost to make the home habitable.For each household determined to have unmet housing needs, their estimated average unmet housingneed less assumed assistance from FEMA, SBA, and Insurance was calculated at $27,455 for major damage(low); $45,688 for major damage (high); and $59,493 for severe damage. Unless otherwise noted, whenquoting an estimated total for unmet housing need, the state has relied on these estimates to calculate aspecific dollar amount. Data is not currently available from HUD respective to estimated needs at theminor-high and minor-low categories. 1819Owner-Occupied Households Estimated Unmet Need BaselineDamage Category Estimated NeedsSevere $ 59,493Major-High $ 45,688Major-Low $ 27,455Minor-High $ -Minor-Low $ -The state reserves the right to revisit this methodology, once it has conducted its own analysis specific toDR-4263 and DR-4277 comparing damages documented through FEMA's real property inspections,inspections conducted in response to claims made to the National Flood Insurance Program (NFIP) andinspections conducted for the purposes of the SBA disaster loan program. Additionally, the state intendsto use real-time unmet needs assessments gathered through its own program intake and inspectionprocess to further inform this analysis over time.Total Impact (Owner-Occupied and Renter Households)The information below outlines the total household population with documented damages. For thepurposes of this analysis, the state has concluded a household has documented damage if FEMA reporteda FEMA FVL of greater than $0. Across both disasters, 113,312 households were found to have some levelof documented damage, including 84,842 owner-occupied and 28,470 renter households. While themajority of instances of housing damage can be attributed to DR-4277 (91,628 of 113,312, or 81 percent),the state is aware this is at least partially attributable to the fact DR-4277 generally affected largerpopulation centers like Lafayette and metropolitan Baton Rouge, while DR-4263 generally affected morerural parishes and communities.While these data validate HUD's identification of the ten most impacted parishes, the state is alsoconcerned about levels of damage in several parishes just below this most impacted threshold, specificallyIberia, Morehouse, St. Landry and St. Martin, parishes. The map below includes all documented instancesof housing damage, irrespective of the level of damage.20Households with DamageDisaster Parish Owners Renters Total4263 Ouachita 3,449 2,684 6,133Tangipahoa 2,378 769 3,147Washington 1,133 303 1,436Morehouse 1,021 290 1,311St. Tammany 933 178 1,111Caddo 594 120 714Bossier 612 78 690Natchitoches 613 76 689Richland 451 147 598Webster 533 50 583Livingston 453 72 525Union 412 33 445West Carroll 351 31 382St. Helena 342 25 367Vernon 320 34 354Calcasieu 286 38 32421Households with DamageDisaster Parish Owners Renters TotalGrant 296 27 323East Carroll 241 53 294Bienville 214 17 231Claiborne 203 23 226Winn 183 33 216Lincoln 156 17 173Rapides 151 21 172De Soto 145 14 159Caldwell 148 9 157Beauregard 127 17 144Ascension 109 21 130Sabine 102 2 104Madison 86 16 102Allen 77 6 83LaSalle 76 7 83Jackson 73 4 77Catahoula 74 1 75Franklin 62 3 65Red River 46 3 49Avoyelles 12 - 12Total 16,462 5,222 21,6844277 East Baton Rouge 24,255 12,683 36,938Livingston 15,972 4,746 20,718Ascension 6,395 1,438 7,833Tangipahoa 4,655 1,104 5,759Lafayette 4,798 852 5,650Vermilion 1,819 360 2,179Acadia 1,555 445 2,000St. Landry 1,600 398 1,998Iberia 1,466 400 1,866St. Martin 1,339 120 1,459St. Helena 922 105 1,027East Feliciana 653 102 755Evangeline 531 142 673Jefferson Davis 507 62 569Pointe Coupee 451 100 551Iberville 356 39 395Avoyelles 262 75 337St. Tammany 216 18 234Washington 199 28 22722Households with DamageDisaster Parish Owners Renters TotalWest Feliciana 160 11 171St. James 159 10 169West Baton Rouge 107 10 117Calcasieu 2 - 2Rapides 1 - 1Total 68,380 23,248 91,628Grand Total 84,842 28,470 113,312Impact on Owner-Occupied HouseholdsBy far, the greatest number of instances of significant owner-occupied housing damage occurred in theBaton Rouge Capital Region, specifically in East Baton Rouge, Livingston, Ascension and Tangipahoaparishes. Other population centers around Monroe (Ouachita Parish) and Lafayette (Lafayette Parish) alsoexperienced significant owner-occupied housing damages. Finally, the state is mindful of two additionalpockets of significant damage along the Sabine River, in Calcasieu and Vernon parishes, respectively.For the purposes of this section, the state includes all documented damages to the owner-occupiedhousehold population at all levels of damage in tabular format. For mapping purposes, this analysis onlyincludes those households with “major-low,” “major-high” and “severe” levels of damage at the censustract. This map illustrates those housing units with significant and likely unmet needs.23Owner-Occupied Households with DamageDisaster Damage Category Households4263 Severe 675Major-High 2,276Major-Low 3,979Minor-High 1,503Minor-Low 8,029Total 16,4624277 Severe 11,249Major-High 24,270Major-Low 15,182Minor-High 3,849Minor-Low 13,830Total 68,380Grand Total 84,842This analysis generally assumes areas with greatest need are going to be those that have both highconcentrations of damage as well as a high level of pre-existing social vulnerability. Utilizing this bivariateapproach identifies specific corridors of concern. For owner-occupied household populations, aconcentration of need is found in corridors throughout the Baton Rouge Capital Region. There are a totalof six census tracts in the 51 IA declared parishes classified as having high levels of damage as well as highlevels of social vulnerability. All six of these census tracts are located within the Capital Region. Five of thecensus tracts are located within East Baton Rouge Parish, specifically, and one is located in LivingstonParish. These census tracts are all within a five-mile area and five of the six census tracts are located in aline along the I-12/Florida Boulevard corridor that runs between Baton Rouge and Denham Springs. Thestate will note these particular areas of interest as it conducts programmatic outreach and intake.24Owner-Occupied Households with Damage (SoVI Designation)Disaster SoVI (5-Class) Households4263 High 659Medium-High 4,122Medium 3,743Medium-Low 7,515Low 423Total 16,4624277 High 895Medium-High 10,335Medium 18,994Medium-Low 32,424Low 5,732Total 68,380Grand Total 84,84225Of particular concern is the high proportion of owner-occupied households with damage who did notreport carrying insurance through the National Flood Insurance Program (NFIP). In total, 72 percent of allimpacted owner-occupied households, or 61,069, did not report having insurance. This represents aunique situation for the state, as in previous significant disaster events – hurricanes Katrina, Rita, Gustav,Ike and Isaac - there was a reasonable anticipation some damages may have been attributable to wind orother events that may have been covered by a homeowner's hazard insurance policy. As these eventswere flood-exclusive, the state has no such reasonable anticipation any of the losses incurred by thispopulation were met by other insurance policies.Additionally, it is important to note the high instances of owner-occupied households with significantlevels of damage who were uninsured. 36,510 households of the 61,069 uninsured total had damagelevels of “major-low,” “major-high” or “severe,” accounting for more than 59 percent of the affected anduninsured owner-occupied population.Owner-Occupied Households with No Flood InsuranceDisaster Damage Category Households Percent of Total Damaged4263 Severe 481 71%Major-High 1,448 64%Major-Low 3,079 77%Minor-High 1,258 84%Minor-Low 7,563 94%26Owner-Occupied Households with No Flood InsuranceDisaster Damage Category Households Percent of Total DamagedTotal 13,829 84%4277 Severe 6,071 54%Major-High 14,470 60%Major-Low 10,961 72%Minor-High 3,130 81%Minor-Low 12,608 91%Total 47,240 69%Grand Total 61,069 72%To drilldown on affected owner-occupied populations in the ten-parish most impacted area, the stateprepared the following detailed maps illustrating instances of owner-occupied household damages at thecensus tract. As the state conducts housing program intake, it will attempt to coordinate outreach effortsin accordance with locales with high-levels of documented damages.It is important to note 68,319 of the total 84,842 owner-occupied households with damage are locatedwithin the ten-parish most impacted area, representing more than 81 percent of the total. Additionally,51,742 households within that population are likely to have unmet needs, with damage levels at “majorlow,”“major-high” or “severe.” This population represents more than 90 percent of the 57,631 affectedowner-occupied households likely to have unmet needs.27Represents households with “major-low,” “major-high” and “severe” levels of damage.28Represents households with “major-low,” “major-high” and “severe” levels of damage.29Owner-Occupied Households in 10 Most Impacted ParishesDisaster Damage Category Households4263 Severe 226Major-High 1,339Major-Low 2,297Minor-High 906Minor-Low 3,687Total 8,4554277 Severe 11,107Major-High 23,657Major-Low 13,116Minor-High 3,075Minor-Low 8,909Total 59,864Grand Total 68,319Represents households with “major-low,” “major-high” and “severe” levels of damage.30The rainfall events associated with DR-4263 and DR-4277 were each considered to be, in some areas, “onein 1,000 year” events, or events with an annual expected occurrence rate of 0.001 percent. As a result, anunusually high proportion of affected owner-occupied households were located outside of the 100-yearfloodplain, or the Special Flood Hazard Area (SFHA). Accordingly, these households were not required tocarry flood insurance if they had a mortgage. Combined with the high proportion of affected householdswithout flood insurance, the state believes these factors have exacerbated housing unmet needs relativeto past disasters.Specifically, 46,016 impacted owner-occupied households were located outside of the SFHA, representingmore than 54 percent of the total affected owner-occupied household population. Additionally, 24,615 ofthese households are likely to have unmet housing needs, with damage levels of “major-low,” “majorhigh”or “severe.” This represents more than 42 percent of the owner-occupied population likely to haveunmet needs.Owner-Occupied Households Outside SFHADisaster Damage Category Households4263 Severe 292Major-High 1,043Major-Low 2,116Minor-High 1,03131Minor-Low 6,800Total 11,2824277 Severe 2,896Major-High 10,395Major-Low 7,873Minor-High 2,513Minor-Low 11,057Total 34,734Grand Total 46,016Given HUD requirements associated with this CDBG-DR allocation, the state must expend at least 70percent of its allocation toward the benefit of LMI populations. 43,643 affected owner-occupiedhouseholds are LMI, or more than 51 percent of the total affected owner-occupied population.Additionally, only 25,157 of this total are households expected to have remaining unmet needs (based onHUD's methodology), with damage levels of “major-low,” “major-high” or “severe.” This representsapproximately 43 percent of the affected population likely to have remaining unmet needs. As such, if thestate receives substantially greater resources, in addition to the $1.6 billion already allocated by Congress,to address unmet needs in a more comprehensive fashion, it anticipates it may face a challenge in meetingits requirement to expend at least 70 percent of its CDBG-DR allocation toward the benefit of LMIpopulations.32LMI Owner-Occupied HouseholdsDisaster Damage Category Households4263 Severe 282Major-High 999Major-Low 2,293Minor-High 909Minor-Low 5,934Total 10,4174277 Severe 4,088Major-High 9,495Major-Low 8,000Minor-High 2,116Minor-Low 9,527Total 33,226Grand Total 43,643As the state attempts to prioritize the expenditure of CDBG-DR resources that are dwarfed by the totalanticipated unmet needs from DR-4263 and DR-4277, one area of prioritization will be elderly householdsas it conducts program intake. There are at least 26,783 households with members aged 62 or older in 33the impacted owner-occupied population, accounting for the limitation that IA data only includes date ofbirth for the applicant representing the entire household. Using this figure as a baseline, however, at least31 percent of the affected owner-occupied household population has a member that is 62 or older.Isolating just those households likely to have unmet needs, at least 18,997 have a household memberaged 62 or older. This is at least 32 percent of the owner-occupied household population likely to haveunmet needs.Owner-Occupied Households with Applicant Aged 62+Disaster Damage Category Households4263 Severe 262Major-High 927Major-Low 1,363Minor-High 478Minor-Low 2,491Total 5,5214277 Severe 4,069Major-High 8,132Major-Low 4,244Minor-High 1,139Minor-Low 3,678Total 21,262Grand Total 26,783 34In addition to those households with a member aged 62 or older, the state will also prioritize thosehouseholds with persons with disabilities, as identified initially by those households that indicated theyhad access and/or functional needs through their IA applications. According to the FEMA data, there are2,590 owner-occupied households with documented access and/or functional needs, representing morethan 3 percent of the total impacted owner-occupied household population. 1,900 of these householdshave levels of damage indicating they likely have remaining unmet needs, accounting for more than 3percent of the total owner-occupied household population likely to have unmet needs.Owner-Occupied Households with Access/Functional NeedsDisaster Damage Category Households4263 Severe 28Major-High 77Major-Low 108Minor-High 33Minor-Low 176Total 4224277 Severe 474Major-High 835Major-Low 378Minor-High 95Minor-Low 386 35Total 2,168Grand Total 2,590Impact on Renter HouseholdsThe greatest number of instances of renter household damages occurred in Ouachita (DR-4263), EastBaton Rouge and Livingston (both DR-4277) parishes. Other parishes with significant impacts to renterpopulations include Ascension and Tangipahoa parishes.For the purposes of this section, the state has included all documented damages to the renter householdpopulation at all levels of damage in tabular format. For mapping purposes, this analysis only includesthose households with “major-low,” “major-high” and “severe” levels of damage.Renter Households with DamageDisaster Damage Category Households4263 Severe 279Major-High 1,204Major-Low 1,309Minor-High 876Minor-Low 1,554Total 5,2224277 Severe 3,838Major-High 8,097Major-Low 6,182Minor-High 1,81836Minor-Low 3,313Total 23,248Grand Total 28,470This analysis generally assumes areas with greatest need are going to be those that have both highconcentrations of damage as well as a high level of pre-existing social vulnerability. Utilizing a bivariateapproach for rental household populations and SoVI census tracts, the Baton Rouge Capital Region andthe Monroe metropolitan area have large concentrations of damage as well as areas with notably highlevels of social vulnerability. In the Capital Region, there are a total of nine census tracts (8 in East BatonRouge and 1 in Livingston) classified as having high levels of both damage and social vulnerability. Mostof these census tracts are located within a five-mile area in a line along the I-12/Florida Boulevard corridorthat runs between Baton Rouge and Denham Springs; however, there are two census tracts meeting thesecharacteristics in northern Baton Rouge. Both are located south of the Baton Rouge Metropolitan Airport,one of which is in a neighborhood west of Howell Park and the other is located west of Airline Highwaybetween the Airline Highway and I-110 and the Airline Highway and Prescott Road intersections.In the Monroe metropolitan area, there are five total census tracts classified as having both highconcentrations of rental household damage as well as high levels of social vulnerability. Three of thesecensus tracts are within a three-mile area. These tracts run north and south along Highway 165 from southof the University of Louisiana Monroe at the intersection of Martin Luther King Jr. Drive (Highway 165)and DeSiard Street down to Richwood. The other two census tracts are outliers, but still within six milesof each other. One of the outliers is located between Glenwood Regional Medical Center and the OuachitaRiver. For reference, West Monroe High School is roughly the center point of this census tract. The secondoutlier is located north of the University of Louisiana Monroe. It is bounded by Sterlington Road (Highway165) to the west, Chauvin Bayou to the south, and the winding Bayou DeSiard to the north, northeast, andeast. The state will note these particular areas of interest as it conducts programmatic outreach andintake.37Renter Households with Damage (SoVI Designation)Disaster SoVI (5-Class) Households4263 High 555Medium-High 2,343Medium 1,076Medium-Low 1,193Low 55Total 5,2224277 High 659Medium-High 6,543Medium 6,973Medium-Low 8,066Low 1,009Total 23,250Grand Total 28,472To drilldown on affected renter populations in the 10-parish most impacted area, the state has preparedthe following detailed maps illustrating instances of renter household damages at the census tract level. 38As the state conducts housing program intake, it will attempt to coordinate outreach efforts in accordancewith locales with high-levels of documented damages.It is important to note 25,701 of the total 28,470 renter households with damage are located within the10-parish most impacted area, representing more than 90 percent of the total.Represents households with “major-low,” “major-high” and “severe” levels of damage.39Represents households with “major-low,” “major-high” and “severe” levels of damage.40Renter Households in 10 Most Impacted ParishesDisaster Damage Category Households4263 Severe 214Major-High 968Major-Low 1,061Minor-High 697Minor-Low 1,087Total 4,0274277 Severe 3,778Major-High 7,895Major-Low 5,801Minor-High 1,508Minor-Low 2,692Total 21,674Grand Total 25,701Represents households with “major-low,” “major-high” and “severe” levels of damage.41Like the owner-occupied household population, an unusually high proportion of affected renterhouseholds were located outside of a Special Flood Hazard Area (SFHA). As such, while this may notinherently indicate exacerbated need for the renter population itself, it may indicate an enhanced needfor landlords who may not have carried flood insurance. Furthermore, as has been discussed previously,there was a lack of affordable housing stock prior to the 2016 flooding events. The impacts describedbelow have further exacerbated the need for an increase in affordable housing options across the state.Specifically, 12,921 impacted renter households were located outside of the SFHA, representing morethan 45 percent of the total affected renter household population.Renter Households Outside SFHADisaster Damage Category Households4263 Severe 119Major-High 532Major-Low 619Minor-High 541Minor-Low 1,160Total 2,9714277 Severe 940Major-High 2,80242Renter Households Outside SFHADisaster Damage Category HouseholdsMajor-Low 2,728Minor-High 1,148Minor-Low 2,332Total 9,950Grand Total 12,921Per HUD requirements associated with this CDBG-DR allocation, the state must expend at least 70 percentof its allocation toward the benefit of LMI populations. 21,806 affected renter households are LMI, ormore than 76 percent of the total affected renter population.LMI Renter HouseholdsDisaster Damage Category Households4263 Severe 205Major-High 916Major-Low 1,037Minor-High 737Minor-Low 1,35043LMI Renter HouseholdsDisaster Damage Category HouseholdsTotal 4,2454277 Severe 2,850Major-High 5,822Major-Low 4,717Minor-High 1,441Minor-Low 2,731Total 17,561Grand Total 21,806As the state prioritizes the expenditure of CDBG-DR resources that are dwarfed by the total anticipatedunmet needs from DR-4263 and DR-4277, it may prioritize elderly households as it conducts programintake. There are at least 2,642 households with applicants aged 62 or older in the impacted renterpopulation, accounting for the limitation that IA data only includes data of birth for the applicantrepresenting the entire household. Using this figure as a baseline, however, at least 9 percent of theaffected renter household population has a member that is 62 or older. 44Renter Households with Applicant Aged 62+Disaster Damage Category Households4263 Severe 15Major-High 121Major-Low 130Minor-High 76Minor-Low 117Total 4594277 Severe 265Major-High 951Major-Low 575Minor-High 146Minor-Low 246Total 2,183Grand Total 2,642In addition to those elderly households, the state may also prioritize those populations with access and/orfunctional needs to prioritize how it will assist the affected population. There are 1,268 renter householdswith documented access and/or functional needs, representing more than 4 percent of the total impactedrenter household population. 45Renter Households with Access/Functional NeedsDisaster Damage Category Households4263 Severe 12Major-High 54Major-Low 57Minor-High 38Minor-Low 55Total 2164277 Severe 197Major-High 407Major-Low 233Minor-High 70Minor-Low 145Total 1,052Grand Total 1,26846Impact on Public Housing AuthoritiesThe Louisiana Housing Corporation (LHC), in conjunction with HUD's New Orleans Field office, hasremained in constant contact with Public Housing Authorities (PHAs) throughout the impacted area. Intotal, 13 of the state's 102 PHAs reported some disaster impact, impacting 132 households and displacing95 households. Additionally, 16 Housing Choice Voucher (HCV) properties were affected, impacting 864households and displacing 850 households.Public Housing Assessment (Statewide)Public Housing Housing Choice Vouchers TotalTotal Properties/PHAs 102 91 193Units 19,988 54,357 74,345Properties/PHAs Impacted 13 16 29Households Impacted 132 864 996Households Displaced 95 850 945HUD's New Orleans Field office provided an update relative to PHA damages and unmet needs on Jan. 17,2017 (see table below). The state is committed to continued coordination with PHAs, particularly withrespect to assessing the unmet repair and rebuilding needs not otherwise covered by insurance or FEMA.In addition, the state is committed to working with PHAs to develop and implement measures that willmake their units more resilient in the wake of future storms. With an understanding that many of theindividuals who reside in subsidized housing represent the most vulnerable residents of our state, it is ofthe utmost importance to ensure that impacted PHAs are provided the tools and resources they need torebuild effectively and sustainably.Seven multifamily public housing developments reported damage attributable to DR-4263 or DR-4277.These facilities hold 619 total units, of which 300 were damaged. Two facilities, Livingston Manor andCharleston Oaks, suffered damage to all of their units, while a third development, Tangi Village, suffereddamage to all but four units. Tangi Village, in particular, is notable as it was impacted by both disasterHA NameInsuranceAwardFEMAAwardCFPReallocatedFundsOperatingFundsAvailableCOCCDamagesPublicHousingDamagesPHRelocationCostsAdditionalFundsNeededMonthstoCompleteModEunice $0 $0 $162,263 $750,000 $0 $2,297,500 $34,000 $1,419,237 24New Iberia $0 $0 $0 $0 $0 $213,380 $0 $213,380Rayne $0 $0 $0 $75,000 $0 $75,000 $2,000 $2,000 5Crowley $73,864 $0 $0 $0 $0 $71,800 $0 $0 4Ville Platte $0 $77,000 $0 $0 $0 $56,000 $1,619 $0 3Welsh $0 $0 $0 $0 $0 $20 $0 $20 0Lake Arthur $33,610 $0 $0 $0 $0 $44,937 $0 $11,327Donaldsonville $0 $0 $26,858 $0 $0 $203,000 $0 $176,142 60Erath $455,027 $0 $0 $0 $0 $406,903 $0 $0 5Opelousas $0 $0 $0 $0 $0 $0 $0 $0Denham Springs $2,900,000 $0 $0 $0 $265,000 $4,770,000 $0 $2,135,000 15Jennings $0 $0 $8,000 $0 $0 $98,000 $0 $90,000Duson $0 $0 $0 $0 $0 $0 $0 $0Totals $3,462,501 $77,000 $197,121 $825,000 $265,000 $8,236,540 $37,619 $4,047,106 47events (DR-4263 and DR-4277). Also notable, Cypress Gardens tested positive for mold, and will need tobe remediated. With the exception of Cypress Gardens, all units are expected to be back online by Q22017.Multifamily Assessment (Statewide)Total Units Total Damaged Percent DamagedBacmonila Gardens 150 35 23%Tangi Village 96 92 96%Livingston Manor 45 45 100%St. Edwards Subdivision 98 38 39%Charleston Oaks 30 30 100%Cypress Gardens 100 4 4%Shady Oaks 100 56 56%Total 619 300 48%The multi-family developments noted above are utilizing a number of funding sources to repair damagedunits, including flood insurance, USDA Rural Development loans, and HOME (via LHC). LHC is workingdirectly with the property management firms to determine where funding gaps exist and how to fill thosegaps.Impact on Homeless PopulationsThe Point-in-time count is an annual count of sheltered and unsheltered homeless persons on a singlenight conducted by Continuums of Care (CoC) across the United States. Louisiana has nine Continuums ofCare, which are regional planning bodies that coordinate housing and services for homeless families andindividuals. The list below provides the name of each CoC in the state, along with parishes and major citiesincluded within each CoC (http://www.dhh.louisiana.gov/assets/docs/OAAS/publications/regionalcontinuum-of-care-list.pdf).>> Lafayette/Acadiana CoC - City of Lafayette, Acadia, Evangeline, Iberia, Lafayette, St. Landry, St.Martin, St. Mary, Vermillion>> Shreveport/Bossier/Northwest Louisiana CoC - City of Shreveport, Bossier City, Bienville, Bossier,Caddo, Claiborne, DeSoto, Natchitoches, Red River, Sabine, Webster>> New Orleans/Jefferson Parish CoC - City of New Orleans, Orleans, Jefferson, St. John, St. Charles,St. James, Metairie>> Baton Rouge CoC - East Baton Rouge, Ascension, West Baton Rouge, East and West Feliciana,Iberville, Pointe Coupee>> Monroe/Northeast Louisiana CoC - City of Monroe, Caldwell, East and West Carroll, Franklin,Jackson, Lincoln, Madison, Morehouse, Ouachita, Richland, Tensas, Union>> Alexandria/Central Louisiana CoC - City of Alexandria, Avoyelles, Catahoula, Concordia, Grant,LaSalle, Rapides, Vernon, Winn>> Houma-Terrebonne, Thibodaux CoC - Lafourche, Terrebonne, Assumption>> Louisiana Balance of State CoC – Beauregard, Allen, Calcasieu, Jefferson Davis, Cameron, City ofLake Charles, Plaquemines, St. Bernard, Natchitoches, and SabineAccording to the Jan. 25, 2016, Point-in-time count, a total of 3,994 people were counted as homeless,with 1,444 counted in emergency shelters, 1,409 in transitional housing and 1,141 unsheltered. 48To understand the homeless population prior to flooding within IA parishes and the 10 most impactedparishes, this analysis counts CoCs that contain at least one IA or most impacted parish. Eight CoC'scontain IA parishes, with a total of 3,848 people counted as homeless (1,414 in emergency shelters, 1,296in transitional housing, and 1,138 unsheltered). Four CoCs contain the 10 most impacted parishes, with atotal of 1,398 people counted as homeless (422 counted in emergency shelter, 719 in transitional housing,and 257 unsheltered). 96 percent of people counted as experiencing homelessness on Jan. 25, 2016 werewithin IA parishes, and 35 percent of the state's total people experiencing homelessness were within mostimpacted parishes.2016 Point in Time CountType of Shelter State of LouisianaContinuums of CareContaining IA ParishesContinuums of CareContaining 10 MostImpacted ParishesEmergency Sheltered 1,444 1,414 422Transitional Housing 1,409 1,296 719Unsheltered 1,141 1,138 257Total Homeless Persons 3,994 3,848 1,398Source: Department of Housing and Urban Development, CoC Housing Inventory Count Reports, 2016https://www.hudexchange.info/programs/coc/coc-housing-inventory-count-reports/To respond to DR-4263 and DR-4277, the LHC deployed staff of the Louisiana Housing Authority (LHA) intodisaster shelters to assist with closing those shelters without leaving affected populations homeless. Inresponse to the need of those who were pre-disaster homeless and precariously housed before theflooding events, LHC/LHA set up two different programs that can be expanded to meet the needs of otherhouseholds that may find themselves in similar situations.>> HOME TBRA – LHC allocated $500,000 of HOME funds to provide Tenant-Based Rental Assistance(TBRA). To be eligible for assistance, households must be elderly or disabled, 30 percent AreaMedian Income (AMI) or below and lack the financial resources to obtain the necessary housing.There are currently 63 households issued a voucher. In order to provide these households with ayear of rental assistance and case management services, an additional $481,436 in unmet needremains. There are 56 households currently on the waiting list for HOME TBRA. $2,209,116 is thetotal budget to assist all 119 households with a year of rental assistance and case managementservices, or $1,709,116 in unmet need. However, HOME TBRA allows up to two years of rentalassistance, requiring a total budget of $4,418,232, an unmet need gap of $3,918,232.>> Rapid Re-Housing – LHC allocated $320,000 of Emergency Solution Grant (ESG) funds to providea Rapid Re-Housing (RRH) program for pre-disaster homeless and precariously housed floodsurvivors. All households must have income at or below 30 percent AMI. There are currently 55households issued a voucher for rental assistance and 19 households on a waiting list. LHC willassist the 48 households with RRH for five months with the $320,000 allocation. Due to the lackof long-term affordable rental units in the affected region, five months is an insufficient amountof time to provide assistance. LHC anticipates adding an additional $200,000 from its FY2016allocation to the RRH program. Even with the addition of these funds, there is still an unmet gapof $1,332,000 to assist all 74 households for a 12-month period. 49Daily phone calls and emails from flood impacted households that are now experiencing homelessnesscontinue to occur. The households that have reached out to LHC are actively added to the waiting list.Other organizations assisting in flood recovery are also getting emails and phone calls. Additionally, thenumber of households in need of RRH will continue to rise once FEMA's Transitional Sheltering Assistance(TSA) ends. As of Jan. 19, 2017, there 1,093 households, representing 3,633 individuals checked in to theTSA program. Households that are currently staying with family and friends are another population thatare at risk of homelessness as are households that are living in flooded and moldy homes. As the livingsituations for these households become untenable, they will require alternate living arrangements andwill be in need of rental assistance.The state understands that the full impact of the storms on the pre-disaster homeless and precariouslyhoused population will not be known for some time. Through the resources provided below, LHA is ableto provide interim assistance as the long-term housing solutions are finalized. The state is committed toensure that the needs of this population are met and will identify programs in future Action PlanAmendments.Additionally, there have been impacts to service providers. The Salvation Army in Baton Rouge, one of theCapital Region's largest emergency shelters, flooded during DR-4277, taking on up to 7.5 feet of water. Allclients and staff were relocated. As a result, currently 24 emergency shelter beds and 50 transitionalhousing units are offline. As the weather turns colder, more flood impacted households that are living inuntenable environments, like cars and tents, are expected to seek warmer places to stay, exacerbatingthe need for safe housing options. With the Salvation Army rendered inoperable and unable to expandfor freeze night capacity, the state is concerned substantial populations at risk of homelessness will remainunserved.Focusing further on Baton Rouge, the City has surveyed some of the major homeless support agencies todetermine their client's needs post-flooding. The Volunteers of America (VOA) and the Bishop Ott St.Vincent de Paul both reported a 29 – 30 percent increases in persons seeking housing and homelessservices. VOA reported that the number of calls per day seeking housing services have doubled from 100to 200 and that they have no resources available to which to refer clients. In addition, VOA reported a 60percent increase in persons classified with special needs requesting housing services. They have a waitinglist which continues to grow. Prior to the flood, VOA served 86 clients with mental health and substanceabuse issues. They have turned away 28 persons because of a lack of staff and operating funds to assistthese individuals. Currently, there are 58 persons on the emergency shelter grant waiting list.Bishop Ott St. Vincent de Paul, with the help of the Red Cross, increased shelter beds for men by 58percent after the flood. Monies to support the extra beds will end Dec. 30, 2016. Bishop Ott St. Vincentde Paul serves between 1,300 – 1,400 homeless persons per year. Staff reported that, of the number ofnew unique persons entering the shelter post-flood, between 20 – 50 percent of the extra beds are filledwith first-time homeless clients.While the City has made great progress in reducing the number of homeless persons over the past 10years, the flood has brought those numbers back to where they were in 2015. Additional shelter beds andextended shelter stays are required because of the impact of the flood on pre-flood, precariously housedresidents, the shortage of housing, the increase in rental costs, and the reduction and termination ofFEMA, HUD, and Red Cross emergency services. All agencies reported the need for funding to increaseshelter beds, increase the number of case managers and support services needed to help the vulnerablehomeless in accessing housing and navigating the complex post-flood housing programs and resources.During the East Baton Rouge Metro Council meeting in December 2016, the Council approved the 50allocation of approximately $1 million of its CDBG-DR funding to provide funding to homeless agencies tosupport the homeless. As of the date of this document, decisions regarding the specific uses of theallocated funding have not yet been made. The state is currently working closely with East Baton RougeParish to develop the final homelessness support program and will provide additional details as theybecome available.The state is actively working to gather additional information relative to the impacts to and unmet needsof homeless populations across the state. LHA is in the process of reaching out to the CoCs identifiedabove to determine the extent of the need across the state.Furthermore, the state is working in close coordination with the Disaster Case Management (DCM)program, particularly as it relates to the households in the TSA program. Based on reports from the DCMservice providers, there are 678 renters and 415 homeowners in the TSA population.Due to a host of factors, most notably the lack of available affordable rental units, the most vulnerable,and potentially at-risk of homelessness, of the TSA population are those who are renters. They are unlikelyto be eligible for a number of housing solutions typically made available to homeowners and many nolonger have the FEMA Rental Assistance funds provided to them. In many cases, the rental assistancefunds were not utilized for the appropriate purpose due to other needs, meaning those individuals areunlikely to be eligible for additional Rental Assistance funding.The state recognizes the challenge of ascertaining the vulnerability index relative to predictinghomelessness. It is difficult to determine if the renters currently in TSA were independently housed withany stability prior to the disaster or if they were precariously housed prior to the disaster. In addition, itis not clear as to which of these were living in some sort of pre-disaster subsidized or supported housingsituation. These variables and situations, coupled with a reduction in available and affordable rental stock,are ultimately what will be the best predictors of homelessness from within the TSA population.FEMA staff working directly with households in the TSA program conducted overt 2,500 face-to-face visitswith applicants in hotels since Oct. 10, 2016. From those meetings, 515(21 percent) stated their primarybarrier was not being able to afford rentals. An additional 203 (8 percent) said they can't find rentals,which often means they can't find rentals they can afford.The state reviewed the data collected on the TSA population in an effort to determine which householdsare most at-risk of homelessness once TSA benefits are no longer available. Due to the reasons statedabove, the state contends that uninsured renters are the most likely to be at-risk of homelessness oncethe TSA program concludes. The chart below provides a breakdown of key aspects of the data collectedon the current TSA population.51The state is committed to providing temporary housing solutions and, wherever possible, permanenthousing to households that are homeless or at-risk of homelessness. Recognizing that, while a temporaryhousing solution may meet an immediate need, the ultimate goal is to find permanent housing solutionsfor individuals and families that are currently homeless or at-risk of homelessness. To that end, the statewill submit a formal request in the coming weeks for 1,000 permanent supportive housing vouchers.Moving forward, the information gathered through the CoC outreach, coordination with the DCMprogram, and other efforts will serve as the basis for additional requests and future allocation decisions.Furthermore, the state received an extension to TSA until February 2017. With the approval of theextension, the state has engaged with federal, state and local public and private agencies to work throughpossible interim and long-term solutions for this population. The state has proposed two programs- theRapid Rehousing and Permanent Supportive Housing Support Services- within the Method of Distributionwhich specifically address housing unmet needs faced by vulnerable populations either currentlyexperiencing homelessness or at-risk of becoming homeless. Additional long-term solutions that areimplemented by partner organizations and/or the state will be outlined in subsequent Action PlanAmendments.3. Unmet Housing NeedsIn discussing a full scope of unmet housing needs, it is imperative to understand other resources that haveand will be expended, and where those resources have been and will be geographically deployed. To thiseffect, as of Jan. 12, 2017, SBA has approved $664,634,100 in real estate structural loans.Real Estate Structural Loans Approved by SBA (as of 1/12/17)Disaster ParishApproved StructuralLoan AmountNumber ofApproved Loans524263 Allen $135,600 10Ascension $496,300 32Avoyelles $96,7002Beauregard $506,800 37Bienville $269,000 29Bossier $2,219,700 190Caddo $1,629,900 148Calcasieu $2,106,600 103Caldwell $531,700 51Catahoula $1,500 12Claiborne $489,500 34De Soto $223,100 21East Carroll $30,600 29Franklin $07Grant $587,400 62Jackson $00LaSalle $235,400 18Lincoln $73,700 19Livingston $1,114,700 154Madison $04Morehouse $1,944,400 208Natchitoches $1,984,600 113Ouachita $20,285,700 1,224Rapides $509,000 29Red River $07Richland $567,100 90Sabine $112,300 16St. Helena $48,600 77St. Tammany $5,450,700 339Tangipahoa $5,160,500 599Union $1,819,800 119Vernon $2,435,100 93Washington $2,585,900 241Webster $2,899,100 149West Carroll $338,700 69Winn $805,600 42Total $57,695,300 4,3774277 Acadia $3,184,600 285Ascension $72,686,100 2,915Avoyelles $221,200 26Calcasieu $0053Cameron $0 0East Baton Rouge $274,243,000 12,766East Feliciana $1,603,800 152Evangeline $897,400 67Iberia $1,388,900 237Iberville $849,100 82Jefferson Davis $742,200 62Lafayette $32,953,500 1,520Livingston $187,068,300 7,260Pointe Coupee $646,200 73Rapides $0 0St. Helena $1,198,800 198St. James $102,500 18St. Landry $2,424,700 217St. Martin $2,976,300 241St. Mary $0 1St. Tammany $939,700 75Tangipahoa $15,819,700 1,269Vermilion $6,364,000 393Washington $219,100 35West Baton Rouge $36,600 10West Feliciana $373,100 28Total $606,938,800 27,930Grand Total $664,634,100 32,307Additionally, FEMA has provided housing assistance to eligible households through the IA program. As ofNov. 22, 2016, FEMA had approved $651,261,396 in housing assistance through the IA program.IA Housing Assistance Approved (as of 11/22/16)Disaster Total ApprovedDR-4263 $ 72,992,887DR-4277 $ 578,268,509Total $ 651,261,396As previously presented, to calculate anticipated unmet needs for the owner-occupied householdpopulation, this analysis defers to HUD's methodology described in the Federal Register Notice (FRN) forthese two disaster events. Under this methodology, for each household determined to have unmethousing needs, their estimated average unmet housing need less assumed assistance from FEMA, SBA,and Insurance was calculated at $27,455 for major damage (low); $45,688 for major damage (high); and$59,493 for severe damage. Therefore, as this methodology already contemplates unmet needsaccounting for other forms of assistance, this analysis does not incorporate resources deployed by FEMA,SBA or NFIP. Data is not currently available respective to estimated needs at the minor-high and minorlowcategories. While the state is currently relying on the best available data from federal agencies for 54this information, ultimately the assessment of the homeowner unmet needs will be updated once theprogram has conducted a survey of impacted homeowners and started application intake. It is anticipatedthe program survey and first phase of applications will be launched in the second quarter of calendar year2017.Owner-Occupied Households Unmet Need CalculationDisaster Damage Category Households Estimated Needs4263 Severe 675 $ 40,157,775Major-High 2,276 $ 103,985,888Major-Low 3,979 $ 109,243,445Minor-High 1,503 $ -Minor-Low 8,029 $ -Total 16,462 $ 253,387,1084277 Severe 11,249 $ 669,236,757Major-High 24,270 $ 1,108,847,760Major-Low 15,182 $ 416,821,810Minor-High 3,849 $ -Minor-Low 13,830 $ -Total 68,380 $ 2,194,906,327Grand Total 84,842 $ 2,448,293,435Additionally, the FRN methodology contemplates unmet needs for rental housing units occupied byhouseholds with incomes less than $20,000. As outlined in the map and table below, there are 13,721such households impacted by DR-4263 or DR-4277, with high concentrations of these populations locatedin the Monroe and Baton Rouge metropolitan areas. However, the FRN methodology does notcontemplate a specific dollar amount for these unmet rental needs. Therefore, in the Initial Action Plan,the state used the best available data from the Disaster Housing Task Force, a task force that includesrepresentatives from the Louisiana Housing Corporation, HUD, FEMA and other state, federal and localpartners. According to this task force, the average unmet need to repair a rental unit is $17,000.The state has updated its analysis to include an average cost of unmet need per rental unit to include datareceived from the SBA on businesses listed under NAICS code 531110 (lessors of residential buildings anddwellers). Using aggregated and average information on SBA verified real estate loss for rental properties($20,431), multiplying that average loss by the number of rental housing units with a FEMA verified loss(28,470), the total loss and need for rental repair is estimated to be $581,670,570. When the statesubtracts the total actual amount of funding approved by SBA for real estate assistance to residentiallandlords ($47,942,000), there is an estimated unmet need of $533,717,970, or an average of $18,570 perunit. This estimate does not include a deduction for assumed proceeds from NFIP or private floodinsurance. Using this assessment, the state has updated the estimated unmet needs of rental repair unitsfrom $17,000 per unit to $18,570. Using this revised average unmet need to repair a rental unit ($18,570)and multiplying it by the population identified and contemplated through the FRN (13,721), the totalunmet rental repair need for the March and August 2016 flooding events is estimated to be $254,798,970.55Renter Households Income <$20kDisaster Damage Category Households4263 Severe 128Major-High 619Major-Low 737Minor-High 566Minor-Low 1,074Total 3,1244277 Severe 1,397Major-High 3,238Major-Low 2,999Minor-High 975Minor-Low 1,988Total 10,597Grand Total 13,721This analysis estimates a rental and owner housing unmet need of $2,708,342,637. Given the uniqueattributes of these two disasters (low rates of affected populations with flood insurance, high rates ofaffected populations located outside the SFHA), it is reasonable to view this unmet need estimation as a 56floor, rather than a ceiling. Additionally, over time, and as more detailed information becomes available,the state will continue to work with various stakeholder groups, affected populations and HUD itself tofurther refine this estimate.Housing Unmet Need SummaryCategory Amount Relative Percentage ofUnmet Housing NeedOwner-Occupied $ 2,448,293,435 90.4%Renter $ 254,798,970 9.4%Homeless Assistance and Prevention $$5,250,232 0.2%Total $2,708,342,637 100%C. Economic Impact & Needs1. Statewide Economic Damage & Loss AssessmentImmediately following the August event, the Louisiana Department of Economic Development (LED)partnered with Louisiana State University (LSU) to conduct an assessment of economic damages resultingfrom the DR-4277 flooding event. Key details are:>> At the peak of the August event, 19,900 Louisiana businesses or roughly 20 percent of all Louisianabusinesses were disrupted by the flooding event. FEMA has since referred approximately 22,000businesses to SBA for recovery assistance.>> A disruption of 278,500 workers or 14 percent of the Louisiana workforce occurred at the peak ofthe flooding event.>> An economic loss estimated at roughly $300 million in labor productivity and $836 million in termsof value added during the period immediately surrounding the flood.>> Approximately 6,000 businesses experienced flooding.>> The LSU Ag Center estimates Louisiana agricultural losses of over $110 million.Throughout the event, severe weather, flooding and resources redirected to response efforts led tobusiness interruption losses across the region. To characterize those losses, LED and LSU estimated thepercent of businesses closed each day based on the extent of flooding drawn from the Governor's Officeof Homeland Security and Emergency Preparedness (GOHSEP) and FEMA flood maps as well as theduration of the flooding based on flood level exceedances from USGS streamgages along rivers and bayousacross the impacted area. However, closures extended beyond those businesses directly impacted byflooding due to road closures and the severe weather that disrupted travel for both employees andcustomers. To assess these broader disruptions, LED and LSU reviewed situation reports from theGOHSEP, school closures and government closures.These estimated industry closures were then adjusted by industry sector to account for the fact that somesectors were closed entirely while other sectors (e.g. large manufacturing facilities) generally continuedto operate at normal, or close to normal capacity. To characterize these business interruption losses, LEDand LSU estimated the number of businesses and employees impacted each day as well as the lost workerproductivity, measured in terms of wages. While a number of these employees receive pay even if theywere not working, the worker's productivity is lost to the employer – thus creating losses to the region. 57Of the most impacted parishes, East Baton Rouge and Livingston had the greatest impacts. Livingston,specifically, was acutely impacted with peak impacts in that parish occurring later in the event, asfloodwaters continued to rise and also receded more slowly in some areas. Livingston was also mostacutely impacted with a large majority of businesses disrupted to some degree, and more than half ofbusinesses potentially flooded. The severity of flooding creates a greater risk of long-term closure, whichcan lead to business failure and long-term negative impacts to the region's economy.Peak Disruption by Parish (DR-4277)Parish Businesses EmployeesEast Baton Rouge 8,000 143,700Lafayette 3,100 40,000Livingston 1,800 18,700Tangipahoa 1,500 17,000Ascension 1,200 17,100St. Tammany 900 8,000Iberia 600 8,200St. Landry 600 6,300Acadia 400 3,900Vermilion 400 3,700St. Martin 400 3,100Jefferson Davis 300 2,200Evangeline 200 1,500Iberville 100 2,000Avoyelles 100 1,200East Feliciana 100 800Pointe Coupee 100 400Washington <100 300St. Helena <100 200West Feliciana <100 200Total 19,900 278,500Business & Wage LossesAs flooding impacted different areas at different times, the peak number of businesses and employeesimpacted by DR-4277 is larger than was seen at any specific point in time. In total, approximately 19,900businesses in Louisiana experienced temporary closures, or significant operational reductions. Thesebusinesses employ approximately 278,500 workers. While many employers may have continued payingemployees during closures, some hourly workers may have experienced reduced pay. LED and LSUestimated that 45,000 to 75,000 of these employees work at businesses that experienced flooding andperiods without pay, or with reduced pay. At this time, the State does not have access to comparable lossdata for DR-4263.Lost Productivity and Value Added (DR-4277)Parish Lost Labor Productivity Lost Value-AddedEast Baton Rouge $ 213,000,000 $ 540,200,000Livingston $ 27,000,000 $ 97,800,000Ascension $ 24,900,000 $ 68,500,000 58Tangipahoa $ 17,400,000 $ 62,200,000Lafayette $ 8,600,000 $ 31,100,000St. Tammany $ 2,900,000 $ 8,400,000Iberia $ 1,800,000 $ 8,000,000Iberville $ 1,100,000 $ 2,900,000St. Landry $ 1,000,000 $ 3,300,000Vermilion $ 700,000 $ 2,700,000Acadia $ 600,000 $ 2,400,000St. Martin $ 500,000 $ 2,500,000Avoyelles $ 400,000 $ 1,600,000Jefferson Davis $ 300,000 $ 1,700,000East Feliciana $ 300,000 $ 900,000Evangeline $ 200,000 $ 900,000Pointe Coupee $ 100,000 $ 500,000Washington $ 100,000 $ 400,000St. Helena $ 100,000 $ 200,000West Feliciana $ 100,000 $ 200,000Total $ 300,900,000 $ 836,400,000Total regional impacts attributable to lost labor productivity and lost value-added were compiled for thefirst three weeks of the event, providing a rough picture of the gross negative impacts of disruptions tothe area. Lost labor productivity is estimated to be $300 million and lost value-added is estimated to be$836 million. During the three-week period measured, this represented approximately 6 percent of alleconomic activity in the state.To estimate damage to businesses, LED and LSU relied on GOHSEP flood maps and FEMA flood maps, aswell as flood maps published by parishes in the flooded area. Researchers then overlaid infoUSA pointlevel data on business locations for the impacted parishes to estimate the extent of business flooding ineach parish. The total number of businesses estimated to have flooded is 6,100 across the 20 parish area.It is worth noting that 60 percent of businesses in Livingston parish are estimated to have experiencedsome flooding and 19 percent of those in Ascension as well as 15 percent of those in East Baton Rouge,the parish with by far the largest overall number of businesses in the impacted area.Data from the Bureau of Economic Analysis was used to estimate the value of business structures andequipment based on the size of employer and industry. LED and LSU estimated damage to businessstructures totaled $595.6 million and damage to fixed equipment will add another $262.8 million tobusiness losses.Many businesses experiencing flooding lost substantial inventories, which were estimated based on thesales of impacted businesses and data from the Bureau of Economic Analysis that relates averageinventories to sales for businesses in manufacturing, wholesale trade and retail trade. LED and LSUestimated a total of $1.4 billion in inventory damaged by DR-4277 flooding. This figure represents anaverage of over $200,000 in inventory for each flooded business. While many impacted businesses werelikely smaller businesses that would have significantly lower inventories, a relatively small number of largewholesalers and retailers with substantial inventories can heavily skew the average relative to the typicalloss. For example, the Dixie RV Superstore, a recreational vehicle dealership in Hammond estimated asmuch as $30 million in damage attributable to a large portion of their vehicular inventory being flooded. 59Similarly, stores like the Walmart and Home Depot in Denham Springs flooded and would have lostinventory values much higher than what is typical across the 6,000 businesses that flooded.Agricultural LossesIn response to DR-4263 and DR-4277, Kurt M. Guidry of the LSU AgCenter conducted impact estimates onLouisiana's agriculture sector. Following DR-4263, 24 parishes reported agribusiness impacts totaling anestimated loss of $80 million. The March 2016 flood event occurred at the beginning of the year's plantingseason, impacting pasture and livestock infrastructure, causing livestock deaths and requiring extensivereplanting of crops. Extensive rainfall after the event further exacerbated crop problems, delayingreplanting past normal planting windows and reducing crop yields.The LSU AgCenter and Farm Service Agency surveyed damages specific to DR-4263. The table belowprovides details on the acreage impacted by crop. Overall, almost 90,000 acres of crops were impactedby the flooding event.DR-4263 Crops ImpactedCrop Acres ImpactedCorn 7,545Cotton 7,960Soybeans 18,000Pasture 52,200Rice 2,000Sorghum 2,000Total 89,705Following DR-4277, the LSU AgCenter estimated impacts to the agricultural sector to exceed $110 million.This estimate is conservative, as it only included selected commodities including rice, soybeans,sugarcane, sweet potatoes, fruits and vegetables, corn, sorghum, cotton and lost grazing days forlivestock. The economic estimates used acreage, historic yields and pricing data to predict yield lossresulting from DR-4277.Estimated Agricultural LossesCrop DR-4263 DR-4277Corn $43,454,125 $10,901,631Soybeans $25,182,504 $46,754,976Cotton $117,077 $3,695,816Sorghum $251,771 $417,931Rice $7,240,111 $33,624,629Sweet Potatoes $401,200 $4,465,247Wheat $3,638,397 N/ASugarcane N/A $3,203,320Grazing N/A $1,973,528Fruits/Vegetables N/A $5,206,991Total $80,285,185 $110,244,069OCD-DRU is working with the LSU AgCenter and its partners to gain a clearer understanding of impactsand unmet needs across Louisiana's agriculture sector. To that end, information is being collected relativeto crop loss insurance policies, the Non-insured Crop Disaster Assistance Program (NAP) and any payments 60made to livestock, aquaculture, bee keepers and others under permanent disaster assistance programs.A coordination of efforts and sharing of information amongst USDA' Risk Management Agency, the FarmService Agency, and LSU AgCenter will enable OCD-DRU to assess the impacts of DR-4263 and DR-4277and accurately target recovery funds to address the greatest needs.Combined LossesEconomic Loss SummaryCategory Loss EstimateAgriculture (DR-4277) 110,200,000Agriculture (DR-4263) $ 80,285,185Business Structures $ 595,600,000Business Equipment $ 262,800,000Business Inventories $1,425,500,000Business Interruption Loss $ 836,400,000Total $3,310,829,2542. Unmet Economic NeedsAs with housing, in discussing a full scope of unmet economic needs, it is imperative to understand otherresources that have and will be expended, and where those resources have been and will begeographically deployed. To this effect, as of Dec. 30, 2016, SBA had approved $160,400,000 in Businessand Economic Injury Disaster Loans (EIDL) to affected populations from DR-4263 and DR-4277. Highestconcentrations of these approvals have been in the Baton Rouge Capital Region and in the metropolitanLafayette region. In addition, OCD-DRU is working to gather data relative to private insurance claims inorder to more accurately identify the remaining unmet needs of the business community. 61SBA Business/EIDL Loans (as of 12/30/17)Disaster ParishNumberof LoansTotal LoanAmount4263 Ascension 2 $39,700Ashley 1 $18,200Beauregard 1 $39,000Bienville 1 $25,000Bossier 8 $709,500Caddo 11 $537,100Caldwell 3 $79,400Cameron 1 $25,000Catahoula 1 $14,300Grant 1 $25,000Lincoln 3 $91,000Livingston 1 $25,400Morehouse 13 $1,240,600Natchitoches 8 $462,000Ouachita 84 $8,022,50062Rapides3 $100,700Red River1 $115,300Richland3 $101,400Saint Tammany 13 $1,903,100Tangipahoa 13 $528,700Union6 $242,800Vernon4 $201,300Washington 14 $557,500Webster5 $111,500West Carroll2 $54,000Winn3 $424,800Total 206 $15,694,8004277 Acadia 19 $755,300Ascension 111 $7,711,200Avoyelles1 $18,700Calcasieu2 $37,000East Baton Rouge 774 $77,951,500East Feliciana6 $284,300Evangeline4 $179,000Iberia 14 $802,500Iberville2 $76,000Jefferson1 $65,300Jefferson Davis4 $178,200La Salle1 $24,200Lafayette 95 $6,166,800Livingston 361 $41,577,400Orleans1 $15,100Pointe Coupee9 $751,300Saint Helena6 $432,700Saint Landry 10 $650,400Saint Martin 13 $1,232,200St John The Baptist1 $25,000Tangipahoa 48 $4,836,900Vermilion 16 $745,100Washington2 $34,300West Baton Rouge3 $225,200Total 1,504 $144,775,600Grand Total 1,710 $160,470,40063Accounting for resources disbursed through SBA loans, this analysis estimates an unmet economic needof $3,150,429,254. Note, this analysis contemplates that a portion of these needs may have beenmitigated by resources disbursed through NFIP. These resources are discussed in the subsequent sectionoutlining the state's total unmet need calculation.Economic Unmet Need SummaryCategory AmountAgriculture Losses $ 190,529,254Business Losses $ 3,120,300,000SBA Loans $ (160,400,000)Total $ 3,150,429,254D. Infrastructure Impact & Needs1. Statewide Infrastructure Damage & Loss AssessmentInfrastructure Systems affected by DR-4263 and DR-4277 included damage and disruptions to levees,roadways and bridges (especially rural roadways), culverts, utilities, wastewater treatment systems,drinking water treatment and collection systems. Across Louisiana, flood basins were overwhelmed byrecord-breaking or near record-breaking rainfall. In some of the coastal parishes, the runoff of rain wascompounded by southern winds that elevated tidal basins and thus inhibited drainage runoff.Damages to roadways and bridges inflicted the most significant damages. Impacts to Interstates 10, 49,and 20 rendered vehicle traffic into and out of Louisiana impossible for multiple days during the height ofeach flooding event. During and in the aftermath of DR-4263, the Red River was rendered unnavigable forseveral days. Multiple railways across the state were unable to safely pass cargo due to elevated floodwaters. In addition, data showed indications of stress and wear on many urban drainage systems.2. Unmet Infrastructure NeedsFEMA Public AssistanceThe FEMA Public Assistance (PA) Program is designed to provide immediate assistance to the impactedjurisdictions for emergency work and permanent work on infrastructure and community facilities. For DR4263,the state's obligation has been established as not less than 25 percent of eligible project costs. ForDR-4277, the state's obligation has been established as not less than 10 percent of eligible project costs.As of Nov. 21, 2016, $36,501,492 has been identified in PA need for DR-4263 and $247,039,464 has beenidentified for DR-4277. GOHSEP estimates these totals to rise to $93,751,791 for DR-4263 and$750,000,000 for DR-4277. Based on these data, the current unmet need is $12,167,167 for DR-4263 and$27,448,829 for DR-4277. Long term, based on GOHSEP's projections, the state estimates this unmet needto grow to $31,250,597 for DR-4263 and $83,333,333 for DR-4277, respectively, for a grand total of$114,583,930. The PA match unmet needs provided by GOHSEP and calculated by OCD-DRU are estimatesat this time, based on current best available data and an understanding of the match needs. However, thestate will work with GOHSEP, local governments, non-profit organizations and other entities eligible forFEMA PA to gather additional information related to needs as projects are reviewed and approvedthrough the Project Worksheet process. The state will be able to update and identify the actual unmetneeds related to the FEMA PA match once the CDBG-DR-funded FEMA PA Match program is underwayand the state receives information directly from the applicants to that program.64PA Intake & Projections (as of 12/28/16)Disaster Category Total PWs Federal Share State Share4263 (25% State Share) A 80 $4,016,450 $1,338,817B 214 $16,760,650 $5,586,883C 241 $12,861,249 $4,287,083D 10 $1,091,779 $363,926E 104 $3,031,827 $1,010,609F 65 $1,895,337 $631,779G 44 $2,849,768 $949,923Z 1 $792,857 $264,286Current 4263 Total 759 $43,299,917 $14,433,306Projected 4263 Total 909 $96,460,853 $31,096,4754277 (10% State Share) A 29 $59,113,326 $6,568,147B 165 $215,005,895 $23,889,544C 41 $1,637,874 $181,986D 5 $565,686 $62,854E 55 $4,165,270 $462,80865F 20 $488,875 $54,319G 2 $73,711 $8,190Z 1 $5,636,250 $626,250Current 4277 Total 318 $286,686,887 $31,854,099Projected 4277 Total 1,224 $750,000,000 $75,000,000Current Grand Total 1,077 $329,986,804 $46,287,404Current ProjectedGrand Total2,133 $846,460,853 $106,096,475Hazard Mitigation Grant ProgramThe Hazard Mitigation Grant Program (HMGP) will be a critical part of the long-term recovery process inboth rebuilding and protecting housing stock and vital infrastructure. These grant funds are calculated at15 percent of the total FEMA Individual Assistance and Public Assistance allocations attributable to DR4263and DR-4277. As of Nov. 15, 2016, the state had received an award letter from FEMA indicating a$26,117,655 grant in response to DR-4263. Additionally, the state estimates it will receive an additional$252 million HMGP grant in response to DR-4277.Unlike PA, the state's obligation for both DR-4263 and DR-4277 has been established as not less than 25percent of eligible project costs. Therefore, the state's unmet need estimate is $8,705,885 for DR-4263and $84 million for DR-4277, with a combined total in excess of $92.7 million.HMGP Award & State ShareDisaster Federal Share State ShareDR-4263 $ 26,117,655 $ 8,705,885DR-4277 $ 252,000,000 $ 84,000,000Total $ 278,117,655 $ 92,705,885Therefore, this analysis contemplates a total unmet infrastructure unmet need gap of $207,289,815.Infrastructure Unmet Need SummaryCategory AmountPA Cost Share $ 114,583,930HMGP Cost Share $ 92,705,885Total $ 207,289,8153. Resilience GapsBroadly, the state recognizes DR-4263 and DR-4277 have exposed a wide array of resilience gaps withinthe communities affected by these two events. Specifically, these gaps include needs for planning andimplementation of strategically-focused projects and programs at all scales, from individual investmentsat the household level to large-scale structural investments designed to impact entire watersheds. Thesewill include basin-wide planning and modeling initiatives in all impacted areas to provide the bestinformation necessary to make wise DR investment decisions delivering optimal benefits. The ultimatepurpose of the investments is to reduce floodplain risk exposure throughout the entire impacted region,reducing the necessity of structure elevations while protecting the substantial long-term recovery66investments to be made with private and public funds over the next several years as a result of DR-4263and DR-4277.Such an approach envisions need for both structural and nonstructural interventions. Structuralinvestments may include large-scale diversions, retention/detention ponds and canals, channelmodifications and other large and small-scale structural approaches. Nonstructural strategies may includean elevation program for those households substantially damaged within the floodplain, flood-proofing,voluntary buy-outs of high risk properties, modified building codes, land-use planning and management,targeted infrastructure investments, technical and staffing support, small-scale retention and detentiontechniques for homes and businesses and public outreach and education efforts. Nonstructuralapproaches are expected to reduce risk by reducing the need for elevations and by creating a greaterbuffer between assets and floodplains.Predicting what types of programs and projects will be funded and at what level is premature prior tomodeling for current and future risk within the state's affected watersheds and floodplains. Once theseefforts have been undertaken, and the state is able to apply specific measures within risk models todetermine optimal return on investment with respect to future damages and resilience, the state willpropose a full slate of resilience-oriented investments paired with demonstrable measures ofeffectiveness.It is important to note that the state is already applying planning funds to the process of betterunderstanding the impacted basins in anticipation of funding to implement these strategies.Generally, the state has identified five general types of resilience-building activities for potential CDBGDRinvestment:Structural Investments to Address Regional Watershed ProtectionCurrently, there are three major diversion projects under consideration across southern Louisiana. Twodiversion projects, which will be located at the southern reaches of the Mississippi River, have recentlyreceived $250M in funding as a result of the Deepwater Horizon settlement with British Petroleum. TheMississippi diversions are intended to divert sediment and create new land. There is also a project plan inplace to divert floodwaters from the Comite River in East Baton Rouge Parish to the Mississippi River.According to best data available to the state, the Comite River diversion project, if it had beenimplemented prior to the August flooding event, potentially could have substantially reduced thedisaster's impacts in the Baton Rouge metropolitan area.In addition to diversions, reservoir creation and channel modification projects have been used to helpreduce flood levels in the floodplain. Such projects have been identified within the most-affected areas,and like the Comite River diversion, could have substantially mitigated the disaster's impact had they beenimplemented prior to the August event.Resilience Add-Ons to Planned Public Infrastructure ProjectsThe state will strive for all public buildings erected with CDBG-DR funds to be certified LEED to ensurelower water and power bills as well as healthy indoor air quality for residents. In addition, the state willencourage the incorporation of a combined heat and power (CHP) system, which will be designed tocontinue providing a reduced level of electricity and cooling to the building in the event of a grid/poweroutage, in the construction of houses or complexes. By incorporating smart-grid designs, the state wouldseek to lower its overall energy risk profile, mindful of the frequency in which it experiences outagesattributable to significant disaster events. 67Stormwater Retention by HouseholdAt 62.45 inches of rain per year, Louisiana experiences some of the highest annual rainfall in the country,as evidenced by DR-4263 and DR-4277. Stormwater runoff during heavy rain events causes flooding thataffects the well-being, property, and livelihood of every inhabitant. Outdated stormwater and pumpingsystems, designed to alleviate flooding, are often overwhelmed during heavy rains. Not only are thesesystems costly, outdated, and inadequate for the high levels of rain, but they have become recognized asone of the main causes of subsidence.One approach to addressing the abovementioned issues is implementing stormwater managementprojects and programs at the individual household level. Individual household measures can help keeprainwater out of drainage systems, reducing overall system requirements.Like natural systems, stormwater management projects and programs can contribute to diverting,holding, and moving excess stormwater. If one household were to purchase and regularly use a rain barrelevery day, that household would likely not be able to fully address all of their stormwater needs. However,if all households were to implement stormwater management measures to help slow the flow of waterto the drainage system, the demands on the management system are dramatically decreased.According to sources at the Urban Conservancy (UC), a nonprofit in New Orleans that helps individualhouseholds address their stormwater management needs, this systematic approach can be done in steps.Step number one, according to the UC, is the elimination of excess paving. Large amounts of impermeableconcrete keeps water from flowing back into the natural system and quickly pushes large amounts ofwater to the drainage system where it can overload the system, causing flooding. Where hard surfacesare necessary, like for parking, installation of permeable pavement can reduce flow to drainage systems.Permeable paving uses interlocking, recycled materials to create a grid in place of the old impermeablesurfaces, and instead of filling that grid with concreate, they instead fill it with different types ofpermeable gravel. This gravel allows for the flow of rainwater back into the natural system. In other words,permeable paving functions practically like concrete, while allowing infiltration of the rain that falls on it.The third step recommended by the UC is to divert roof run-off into featuressuch as rain barrels, retentionponds and rain gardens where the water is held and then released or used at a later date.In anticipation of a large-scale suite of programs designed to effectuate rehabilitation of single-familyhomes and businesses impacted by the two flooding events, it would be prudent to embed theseresilience-building, flood-mitigating principles into the deployment of such a homeowner rehabilitationeffort.Community Stormwater RetentionThe recommendations made at the individual level, community level projects to address stormwaterretention and management must be addressed systematically. If one household were to implement all ofthe abovementioned recommendations their household would only be managing stormwater at a small,lot sized scale. If a community as a whole can begin implementing these projects on an intersection-byintersection,or the neighborhood-by-neighborhood scale, such activities can have a real, demonstrableimpact on the community's flood risk profile.Another way to promote resilient communities through community level projects can be found in theNDRC application for the City of New Orleans. In the application, the City of New Orleans made severalrecommendations for community level resilience measures. Below is a list:68>> Blue-Green Parklands – Construct a series of large-scale Blue-Green Parklands on underutilizedsites for significant water storage, ecological benefit and recreational opportunities.>> Blue-Green Corridors – Install blue or green infrastructure where underutilized sites are located.>> Neighborhood Networks – Develop a network of green infrastructure interventions in aconcentrated scale.>> Canals – Transform existing drainage canals into public waterfronts.Additional recommendations may include:>> Remove excess paving and impermeable surfaces and replace with permeable surfaces atlocations that are burdened with large amounts of concrete/asphalt such as: Churches,supermarkets, retail stores, schools, businesses, and community centers.>> Similar to the City of New Orleans' Blue-Green Parklands and Corridors, take empty lots and/orblighted properties, and turn them into green space, blue space, and public amenities.>> Other areas concrete would be used such as sidewalks, basketball or tennis courts, picnic sightsetc., use permeable surfacing.>> Leverage existing programs, such as the Urban Conservancy's Building Active Stewardship in NewOrleans (BASIN) program or Green Light New Orleans' rain barrel and green light bulbreplacement installation programs, to name a few.Planning and Flood-Risk ModelingPlanning with LA SAFEThrough this recovery efforts, the state would also seek to leverage its own activities through its NationalDisaster Resilience award. Already funded by HUD, the LA SAFE Framework focuses on three typologies –Reshaping, Retrofitting, and Resettlement – using a forward-thinking, risk-based approach to guide thestate's future land use and development patterns. Areas projected to experience in excess of 14 feet offlooding in a 100-year storm event 50 years from now are areas in which the state generally recommendscommunity resettlement projects, like the one it has commenced for the Isle de Jean Charles communityin Terrebonne Parish. Areas projected to experience between 3 feet and 14 feet of flooding in a 100-yearstorm event 50 years from now are those in which the state plans to facilitate holistic and strategicadaptations around the social, cultural and economic assets which it cannot abandon. Areas projected toexperience less than 3 feet of flooding in a 100-year storm event 50 years from now are those in whichthe state plans to incentivize future economic and population growth. We know we cannot eliminateLouisiana's flood-risk profile, but we must preserve – and when possible expand – economic andcommunity development opportunities in moderately vulnerable areas, while incentivizing populationand economic growth in those areas minimally at risk.Coastal Protection and Restoration Authority (CPRA) & CLARAThe 2012 Coastal Master Plan, which is being updated for 2017, was based on state-of-the art science andanalysis, and its modeling process provides a holistic understanding of our coastal environment todaywhile anticipating changes expected over the next 50 years. The Coastal Louisiana Risk Assessment(CLARA) model is a quantitative simulation model of storm surge flood risk developed by the RANDCorporation. In the Coastal Zone, this is the model upon which LA SAFE relies. However, the state musttake a more holistic, watershed-based approach to flood-risk modeling, especially in light of these tworain events in March and August.69Riverine Flood Modeling – USGSThe CLARA model outlined above does a good job of projecting risk for coastal Louisiana; however, thismodeling system does not consider the risk of riverine flooding from rainfall, which is what occurred inLouisiana in March and August. The United States Geological Survey (USGS), through their FloodInundation Mapping (FIM) Program, provides one option to help the state better understand its riverineflood risk in the future. Others include The Water Institute of the Gulf, and the Corps of Engineers, all ofwhich are under consideration at this time. All investments in protective and resilient infrastructure willbe made based on the results of extensive modeling and cost benefit analysis.Summary of Unmet Resilience Need GapsBased on the categories of resilience need gaps articulated above, the State anticipates a total unmetneed of $600,000,000. This total has been derived based on the following:>> Structural Investments ($75,000,000): This estimate is based on an assumption such structuralinvestments would be paired with other sources of funding, including but not exclusive to thosearticulated in the State's 2017 Coastal Master Plan.>> Resilience Add-Ons to Planned Infrastructure ($132,915,926): As outlined in the sectiondocumenting unmet infrastructure needs, the State anticipates a total investment of$1,329,159,261 through FEMA's PA and HMGP programs in conjunction with DR-4263 and DR4277recovery efforts. Based on similar initiatives in past disaster recovery environments, theState believes these resilience-building add-ons would increase total project costs by 10%.>> Household Stormwater Retention ($122,414,672): As outlined in the section documenting unmethousing needs, the State anticipates a total unmet need of $2,448,293,435 for affected owneroccupiedunits. The State believes retention adaptations would increase these project costs by5%.>> Community Stormwater Retention ($239,669,402): This estimate is based on the State'shistorical precedence in implementing neighborhood-level water management projects,specifically those following hurricanes Katrina, Rita, Gustav and Ike.>> Planning & Flood-Risk Modeling ($30,000,000): This estimate is comparable with scale of theState's Comprehensive Resiliency Pilot Program, implemented following hurricanes Gustav andIke. Given the comparable nature of the large geographic areas impacted by both Gustav and Ikeand DR-4263 and DR-4277, the State believes these needs are roughly comparable to one anotherin terms of programmatic scale.These gaps have been summarized as follows:Resilience Unmet Need GapsCategory AmountStructural Investments $ 75,000,000Resilience Add-Ons to PlannedInfrastructure $ 132,915,926Household Stormwater Retention $ 122,414,672Community Stormwater Retention $ 239,669,402Planning & Flood-Risk Modeling $ 30,000,000Total $ 600,000,000 70E. Public Service Unmet NeedsThrough the implementation of the National Disaster Recovery Framework (NDRF), the state, along withFEMA and GOHSEP, have held Community Planning and Capacity Building meetings state wide inaccordance with Recovery Support Function 1 (RSF 1). The RSF 1 meetings occurred with Ascension Parish,the Town of Sorrento, the City of Gonzales, the City of Denham Springs, Livingston Parish, and St.Tammany Parish. As a result of these meetings, the leadership and key staff of all impacted communitieshave identified needs in all service areas handled by a government entity, such as the flooding of fire,police stations and other government buildings, which provide key public services to citizens as well aslarge-scale infrastructure projects that will need to be implemented in order to recover.Funding is a severe handicap, especially compounded by the fact that sales tax and other revenue streamsto local government have declined, or are expected to decline, once the initial buying of cars, buildingmaterials, etc., subsides. Therefore, the approved budgets for the upcoming fiscal year are having to berevisited and modified, which includes the deferral of planned projects and a potential decrease in staffingfor fire and police and other services to meet the immediate recovery needs of the parishes. For example,in Livingston Parish alone, the parish lost a minimum of 10 fire trucks, 33 police vehicles, 61 school busesand 20 other parish-related vehicles which will need to be replaced, impacting the funding for otherprojects.Due to the limited funding available to address the full breadth of recovery needs, the state is notprioritizing funding to address the public service needs described above. However, in anticipation ofadditional funding being made available, OCD-DRU will be implementing a program by which it willprovide funding to cover the non-federal share of FEMA Public Assistance projects. Funds will be providedas payment to state or local entities for eligible activities within approved Project Worksheets. The matchfunding will lessen the financial burden placed on the entities and assist them to continue normaloperations and address recovery needs.In addition to those public services traditionally provided by units of local government, throughexperience with disaster events in the past, the state understands that following a storm event, there isan increased need for mental health services, legal counseling and title services, housing counseling, jobsearch and connection services as well as training for those residents who may have lost their source ofemployment as a result of the disaster events.The FEMA-funded Disaster Case Management (DCM) program implemented by the Louisiana Departmentof Health is a process whereby a qualified case manager serves as a single point of contact for individualsor families who were impacted by the floods. This person helps households return to a state ofindependence. The case manager can help families identify their unmet needs and then make referrals tothe appropriate agencies. This includes access to health care including mental health services, housing,home repairs, transportation and other essential services. It is estimated that over 1,500 families willreceive assistance through the Disaster Case Management program.In addition, the Southeast Louisiana Legal Services is providing free legal assistance to low incomehomeowners facing title challenges. These services will help assisted homeowners participate in thestate's homeowner program.However, the state also understands from past experience that, while some of these public services needsmay be addressed in the immediate aftermath of the flood event, additional unmet needs for these types 71of services will become apparent as the short-term funding for services ends and the lingering and longtermimpacts from the floods begin to take their toll on individuals and families. The state will continueto assess the need for public services, as it conducts program intake and continues outreach to localgovernments, non-profit and faith-based organizations and other community stakeholders. At this time,due to the limited funding available to address the full breadth of long term community service needs,the state is limiting access to CDBG-DR funded public services to the most vulnerable through the RapidRehousing and Permanent Supportive Housing Support Services programs.F. Summary of Unmet Needs & Additional ConsiderationsIn summary, and outlined in the sections above, through this analysis, the state has noted the followingsources of recovery expenditure through the FEMA IA program and through various SBA loan programs.IA Housing Assistance Approved (as of 11/22/16)Disaster Total ApprovedDR-4263 $ 72,992,887DR-4277 $ 578,268,509Total $ 651,261,396Summary of SBA Loans Approved (as of 12/30/17)Disaster All Loans Home Loans Business Loans EIDLDR-4263 $ 75,383,450 $ 57,695,300 $ 14,689,050 $ 2,999,100DR-4277 $ 749,650,650 $606,938,800 $ 111,228,750 $ 31,483,100GrandTotal $ 825,034,100 $664,634,100 $125,917,800 $34,482,200As of Nov. 22, 2016, there were 33,177 policy claims made through NFIP for DR-4263 and DR-4277 and$626,583,804 approved or disbursed through the program. As of Jan. 12, 2017, a total of $446,927,484has been paid for 26,626 NFIP claims for DR-4277, but as of the data of this publication, data from DR4263is not available. There is a 60-day delay from when a claim is processed and when it is reflected inNFIP data, so the data from Dec. 12, 2017, only reflects NFIP claims from 60 days prior.It should additionally be noted this total represents an initial sample of what will ultimately be claimedand disbursed through NFIP. As of Dec. 3, 2016, FEMA had granted Gov. John Bel Edwards request toextend the filing deadline by which those affected by DR-4277 must submit a proof of loss claim. With theextension, applicants will have 180 days from the date of the loss to provide the completed paperwork tothe insurer.NFIP Payouts for Residential Single Family (Structural Damage Only) –4277 Only (As of 1/12/17)Disaster Parish Number of Claims Total Amount Paid Out4277 Acadia 616 $5,505,109Allen 2 $36,000Ascension 3,610 $55,308,648Avoyelles 27 $168,818Bossier 3 $39,437Calcasieu 24 $41,33272Cameron 8 $17,000Concordia 1 $0East Baton Rouge 9,991 $185,306,197East Carroll 1 $0East Feliciana 17 $124,000Evangeline 61 $584,779Iberia 310 $2,755,212Iberville 61 $449,611Jefferson 27 $6,690Jefferson Davis 73 $343,250Lafayette 2,277 $39,430,297Lafourche 3 $38,466Lincoln 1 $0Livingston 6,852 $130,761,688Morehouse 1 $0Orleans 13 $0Ouachita 5 $10,000Pointe Coupee 135 $640,747Rapides 1 $0St. Bernard 2 $0St. Charles 7 $10,600St. Helena 25 $567,198St. James 26 $185,028St. John The Baptist 2 $0St. Landry 169 $1,247,005St. Martin 240 $1,752,801St. Mary 4 $786St. Tammany 129 $803,403Tangipahoa 985 $11,343,274Terrebonne 6 $1,751Vermilion 852 $9,026,305Washington 19 $9,000West Baton Rouge 23 $160,698West Feliciana 17 $252,355Total 26,626 $446,927,484Summary of Unmet NeedsType AmountHousing $1,288,696,623Economic $3,088,429,254Infrastructure $93,802,36073Resilience $600,000,000Total $5,070,928,237G. Anticipated Unmet Needs GapDuring the Oct. 10, 2016 Congressional Session, state government officials, including Gov. John BelEdwards, traveled to Washington D.C. and worked collaboratively with Louisiana's CongressionalDelegation to secure long-term disaster recovery resources in response to DR-4263 and DR-4277. Workingwith limited disaster loss unmet need information, Louisiana's delegation proposed a relief package ofnearly $3.8 billion. This package focused primarily on housing needs, as the state has prioritized housingas its most urgent and pressing recovery concern following the two flooding events. Through this ActionPlan, the state now presents revised unmet need estimates based on current best available data. Overtime, the state reserves the right to continue to update these estimates as additional assessments aremade and more complete data becomes available. The state will use information collected throughapplication intake and ongoing community outreach, coupled with updated data received on a weeklyand monthly basis from SBA, FEMA and NFIP to update its unmet housing, economic, public infrastructure,public services and planning needs assessments. As the unmet needs assessment is updated, the statewill review its programs to ensure they are best designed to meet the recovery needs of the state and itsresidents and businesses.Accounting for the initial appropriation of $437,800,000 and the second appropriation of $1,219,172,000for long-term recovery purposes, the state has calculated a remaining unmet need gap of $5,070,928,237.Summary of Total Unmet NeedsCategory Losses/GapsKnownInvestmentsRemaining UnmetNeedOwner-Occupied Housing $2,448,293,435 $2,448,293,435Homeowner Rehabilitation and Reconstruction (CDBG-DR) ($1,293,693,120) ($1,293,693,120)Rental Housing $254,798,970 $254,798,970In-fill and Repair Rental Program (CDBG-DR) ($45,000,000) ($45,000,000))Multi-family Gap Program (CDBG-DR) ($45,000,000) ($45,000,000)Piggyback Program (CDBG-DR) ($19,000,000) ($19,000,000)Public Housing $8,539,159 ($4,492,053) $4,047,106Homeless Assistance $5,250,232 $5,250,232Rapid Rehousing (CDBG-DR) ($16,000,000) ($16,000,000)PSH Support Services (CDBG-DR) ($5,000,000) ($5,000,000)Agriculture Losses (DR-4277) $110,244,069 $110,244,069Agriculture Losses (DR-4263) $80,285,185 $80,285,185Business Structures $595,600,000 $595,600,000Business Equipment $262,800,000 $262,800,000Business Inventories $1,425,500,000 $1,425,500,000Business Interruption Loss $836,400,000 $836,400,000SBA Business/EIDL Loans ($160,400,000) ($160,400,000)Small Business Program (CDBG-DR) ($51,200,000) ($51,200,000)Small Business Technical Assistance Program (CDBG-DR) ($800,000) ($800,000)Louisiana Farm Recovery Program ($10,000,000) ($10,000,000)74PA State Share $106,096,475 $106,096,475FEMA PA Match Program (CDBG-DR) ($105,000,000) ($105,000,000)HMGP State Share $92,705,885 $92,705,885Resilience Gaps $600,000,000 $600,000,000Totals $6,826,513,410 ($1,755,585,173) $5,070,928,237*CDBG-DR investments are inclusive of program delivery costs.4. Method of Distribution and Connection to Unmet NeedsA. Method of Distribution ProcessAll programs will be implemented by the State of Louisiana at this time. Depending on a continuedassessment of unmet needs and additional funding, the state may allocate funds to parishes or othersubrecipients through future substantial Action Plan Amendments. The programs established in thisAction Plan are not entitlement programs and are subject to available funding.B. Connection to Unmet NeedsBased on the unmet needs assessment and input from impacted communities throughout Louisiana, thestate has prioritized programs that will assist in meeting the short- and long-term recovery needs of itsresidents and communities. While the impact of the 2016 Severe Storms and Flooding was much greaterthan the resources available through these two HUD allocations, these programs will begin to address theunmet needs in homeowners' primary residences and rental housing, economic recovery andrevitalization, and damages to public infrastructure.The Continuing Appropriations Act, 2017, and the Further Continuing and Security AssistanceAppropriations Act, 2017, require that all CDBG-DR funded activities address an impact of the disaster forwhich funding was appropriated. The CDBG-DR provisions require that each activity: (1) be CDBG eligible(or receive a waiver); (2) meet a national objective as defined by 24 CFR 570.483; and (3) address a director indirect impact from the disaster in parishes declared by the President to have been impacted by thedisaster. A disaster impact can be addressed through a number of eligible CDBG activities listed in Section105(a) of the Housing and Community Development Act of 1974, as amended. The recovery activitiesdescribed herein will make full use of the three national objectives under 24 CFR 570.483 which includebenefitting low and moderate income persons, preventing or eliminating slums or blight, and meetingurgent needs to implement a robust and comprehensive recovery for the residents of Louisiana.As required by the Federal Register, 81 FR 83254, November 28, 2016, and 82 FR 5591, January 18, 2017,the state will spend 80 percent of the overall grant on activities undertaken in the HUD-identified “mostimpacted and distressed” area. The HUD-identified “most impacted and distressed” area for the 2016Severe Storms and Flooding consists of Acadia, Ascension, East Baton Rouge, Lafayette, Livingston,Ouachita, St. Tammany, Tangipahoa, Vermillion, and Washington parishes. However, the state maydetermine to make the remaining funds available for eligible program activities in all disaster-impactedparishes.Up to five percent of the overall grant will be used for administration of the grant. Also, as required by theFederal Register Notice, the state will spend no less than 70 percent of funds allocated on activities thatbenefit low to moderate income (LMI) households, or request a waiver of that requirement.75The 2016 Severe Storms and Flooding caused significant levels of damage to owner-occupied and rentalhousing within impacted parishes. Based on the state's review of the most recent data obtained fromFEMA and SBA, the unmet need for housing repair and replacement is more than $2.7 billion. The needfor safe, decent, and affordable housing is the state's top priority, which is why the state has allocated aproportion not equivalent to the unmet needs described above. Over 86 percent of the programmaticfunding from the total allocation of CDBG-DR funds goes to housing programs. Proposed housing activitiesare intended to assist homeowners in reconstructing, rehabilitating, and elevating homes as well asprovide affordable rental housing for persons displaced by the storm.In addition to implementing homeowner and rental programs, the state intends to implement programsthat benefit small businesses and state and local entities faced with covering a non-federal matchrequirement for FEMA Public Assistance projects.The state will dedicate the total allocation to date of $1,656,972,000 to address unmet housing, economic,and infrastructure recovery needs. Of this, $1,423,693,120 will be dedicated to the meet the unmethousing needs, including rehabilitation of owner-occupied households ($1,293,693,120) and the repairand increase of the stock of affordable rental housing for impacted renters ($130,000,000). Economicrecovery will be supported by $62,000,000dedicated to assist small businesses and farmers impacted bythe flood events. Local governments and entities eligible for FEMA Public Assistance will be eligible for thenon-federal cost share within the PA Match Program, totaling $105,000,000.Due to the limited funds received in the first two allocations, the state has prioritized vulnerablepopulations throughout each of the programs proposed in this Action Plan. For the owner-occupiedhousing programs, low-to-moderate income households, households with a head of household that is 62or older, or individuals with disabilities are prioritized. In the tenant-based programs, the state willprioritize these vulnerable populations as well as persons displaced by the disaster event in need ofaffordable housing. The programs that create or repair rental stock are designed to stretch limited fundingas far as possible and to maximize the number of affordable units that will be made available to low tomoderate income households. As mentioned in the unmet needs section above, as the state conductshousing program intake it will coordinate outreach efforts in accordance with locales with high-levels ofdocumented damages and social vulnerability.The state's economic recovery and revitalization programs will focus on small businesses, which areconsistently more vulnerable to the impacts of disasters. Small businesses are critical to the revitalizationof the households, neighborhoods and communities in which they are located. Historically, a sizableportion of small businesses are less able to secure assistance from other sources and struggle to reopenor maintain operations following a disaster event.With respect to public infrastructure, OCD-DRU will implement a program by which it will provide fundingto cover the non-federal share of FEMA Public Assistance projects. Funds will be provided as payment tostate or local entities for eligible activities within approved Project Worksheets. The match funding willlessen the financial burden placed on the entities and assist them to continue normal operations andaddress recovery needs.C. Allocation of FundsState of Louisiana CDBG-DR Total AllocationTotal Allocation $1,656,972,000Restore Louisiana Housing Programs $1,423,693,120Homeowner Program $1,293,693,12076Rental Housing Programs $ 130,000,000Restore Louisiana Economic Recovery and Revitalization Programs $62,000,000Infrastructure Program (PA Match) $105,000,000Administration and Planning $ 66,278,8805. Proposed Use of FundsA. State Implemented ProgramsAll programs outlined below will be implemented by the State of Louisiana. All eligible activities listedbelow are as provided by statute, as may have been amended by the Federal Register Notice or hereafteraffected by waivers from HUD.1. HousingThe state's housing programs will focus on assisting homeowners to reconstruct, rehabilitate, reimburse,and elevate their homes, as well as providing affordable rental housing for persons displaced by the stormthrough the rehabilitation and creation of rental housing stock and by providing rental assistance andsupport services to the most vulnerable persons displaced by the storm.Allocation for Housing Activities Relative PercentageTotal Allocation for Housing Activities: $1,423,693,120 100%Homeowner Program $1,293,693,120 90.87%Rental Housing and Homelessness PreventionPrograms $ 130,000,000 9.13%General Eligible Housing Activities: Rehabilitation, reconstruction, buyouts, and new construction;includes any rental housing for LMI households; public housing; emergency shelters and housing for thehomeless; any other HUD-assisted housing; moving expenses; rental assistance; interim mortgageassistance; housing counseling services; acquisition; and buyouts. Funds may also be used for the creationof new units or rehabilitation of units not damaged by the flood events if the activity can be clearly linkedto an impact generated by the flooding events in the Most Impacted/Distressed (MID) target area. Codeenforcement is an eligible activity that will be considered by the state for the slate of housing programs.The following activities under the Housing and Community Development Act of 1974 (HCDA) are eligible:105(a)1-11, 14-15; 18; 20; 23-25 as well as (42 U.S.C. 5305(a)(4)), (42 U.S.C. 5305(a)(6)); and FR 5989-N01VI.B.28.Ineligible Activities: Forced mortgage payoffs; SBA home/business loan payoffs; funding for secondhomes; compensation payments; and - as per 42 USC 5154a and the Federal Register Notice - no Federaldisaster relief assistance shall be made available in a flood disaster area to make a payment (including anyloan assistance payment) to a person for repair, replacement, or restoration for damage to any personal,residential, or commercial property if that person at any time has received Federal flood disasterassistance that was conditioned on the person first having obtained flood insurance under applicableFederal law and the person has subsequently failed to obtain and maintain flood insurance as requiredunder applicable Federal law on such property.77SBA Declined Loans: Homeowners and property owners approved for SBA loans who declined their loanswill be reviewed for eligible award amounts and duplication of benefits, per the state's program policiesand procedures.Elevation Requirements: New construction, substantially damaged, or substantial improvement ofstructures in the 1 percent annual (or 100 year) floodplain must be elevated (2' above Base FloodElevation), per federal rules and regulations and local code enforcement requirements. The state hasallocated other resources to a study that will assess the potential impacts of riverine basin projects on theflood levels of certain communities impacted by the 2016 Severe Storm and Flooding Events. While it isanticipated one or more infrastructure projects will have beneficial impacts on mitigating future floodingevents in the impacted communities, these projects may not be complete prior to the implementation ofthe programs described herein. Therefore, in those cases where the state determines the costreasonableness of rehab/reconstruction of an impacted structure, the state will follow federal elevationrequirements until further assessment and notice.Building Standards: New construction or replacement of substantially damaged buildings must meetgreen building standards and are strongly encouraged to meet a resilient home construction standard.Flood Insurance: Applicants living in a SFHA that receive federal assistance under these programs mustobtain and maintain flood insurance for rehabilitated or reconstructed properties.Restore Louisiana Homeowner Rehabilitation, Reconstruction and Reimbursement ProgramSummary: The state will enter into grant agreements with homeowners that result in the repair,reconstruction, elevation, acquisition and/or buyout of flood-damaged residential owner-occupiedstructures. Given the time elapsed from the March and August flooding events, homeowners are in variedstates of progress in their rebuilding process depending on the extent of damage and resources available.In response, the state will implement the Restore Louisiana Rehabilitation, Reconstruction andReimbursement Program to cover eligible costs for the repair or replacement of damage to real property;replacement of disaster-impacted residential appliances; and limited environmental health hazardmitigation costs related to the repair of disaster-impacted property.Eligible Activity Rehabilitation, Reconstruction, Buyouts and Acquisitions (42 U.S.C.5305(a)(4)); HCDA Sections 105 (a)(1), 105(a)(3-4), 105(a)(7-8)). HousingIncentive, as identified in Federal Register Docket No. FR-5989-N-01.Also eligible are elevation expenses related to rehabilitation andreconstruction activities and reimbursement of eligible rehabilitationand reconstruction activities.National Objective Urgent Need or benefit to low to moderate income personsGeographic Eligibility: Disaster-declared parishes impacted by the 2016 Severe Storms and FloodingAllocation for Activities:Program Area FirstAppropriationSecondAppropriationTotal % ofTotalHomeowner Rehabilitationand Reconstruction $385,510,000 $908,183,120 $1,293,693,120 80%78Administering Entity: State of LouisianaProposed Use of Funds: Homeowners will have four potential program solutions from which to choosebased on their progress in the rebuilding process and their capacity to complete the rebuilding process.The state's programs will give homeowners the option to select their own contractor who will follow thestate's requirements for rebuilding or work with a state-managed contractor. Additionally, homeownersthat have completed partial or full repairs on their home prior to applying to the program, may be eligibleto receive reimbursement for expenses incurred within HUD approved timelines. If homeowners havepartially completed repairs or reconstruction of their homes at the time of application to the program,they may be eligible for assistance for prospective work as well as reimbursement assistance for eligiblework completed within the HUD established reimbursement guidelines. Consistent with HUDreimbursement guidelines, certain limited reimbursement may become available for repairs performedafter the homeowner has applied to the program. More details, including when repairs may be made andwhich expenses are eligible for reimbursement, will be made available with the publishing of theprogram's Policies and Procedures.Elevations will be included for homeowners that meet requirements determined by the program,including substantially damaged properties in the floodplain. Elevation will be evaluated on a case-bycasebasis. Elevations will not be conducted on properties outside of the floodplain, with the possibleexception where elevation is required by local ordinance.State staff and/or contractors will provide guidance to homeowners on the guidelines and requirementsof each solution. Based on their individual conditions at the time of application, homeowners will choosethe program solution that best fits their need.Program Solutions:Solution 1: Program Managed: Homeowners may choose to have the state manage and completethe construction process for the rehabilitation or reconstruction of damaged homes on theirbehalf. The state will contract with a pool of contractors and assign them to repair or reconstructdamaged properties. Homeowners will not select their own contractors and will not contract withthe construction contractor. Homeowners will be required to enter into grant agreements withthe state. Homeowners who have partially completed repairs on their home at the time ofapplication may select to participate in Solution 1. These homeowners may also be eligible forassistance under Solution 3: Reimbursement for eligible costs incurred prior to application.Solution 2: Homeowner Contracted Program: Homeowners may choose to manage their ownrehabilitation or reconstruction process with the state providing construction advisory servicesfor all homeowners in this solution. Homeowners will select their own homebuilding contractor(s)and contract directly with homebuilding contractors to rebuild as well as enter a grant agreementwith the state for the CDBG-DR funding. The state will monitor all projects in the HomeownerContracted Program. Homeowners who have partially completed repairs on their home at thetime of application may select to participate in Solution 2. These homeowners may also be eligiblefor assistance under Solution 3: Reimbursement for eligible costs incurred prior to application.Solution 3: Reimbursement: Homeowners who have completed partial or full repairs on theirhome prior to applying to the program may be eligible to receive reimbursement for expensesincurred within HUD approved timelines. Furthermore, certain limited reimbursement may 79become available for repairs performed after the homeowner has applied to the program. Moredetails, including when repairs may be made and which expenses are eligible for reimbursement,will be made available at a later date with the publishing of the program's Policies and Procedures.Homeowners who have partially completed repairs to their homes prior to application may alsoparticipate in Solutions 1 or 2 in order to complete the repairs or reconstruction of their homes.The state will follow the guidance received from HUD and the CPD Notice 2015-07, "Guidance forCharging Pre-Application Costs of Homeowners, Businesses, and Other Qualifying Entities to CDBGDisaster Recovery Grants” when implementing Solution 3: Reimbursement. Furthermore, thestate is in the process of consulting with the State Historic Preservation Officer, Fish and WildlifeService and National Marine Fisheries Service, to obtain formal agreements for compliance withsection 106 of the National Historic Preservation Act (54 U.S.C. 306108) and section 7 of theEndangered Species Act (16 U.S.C. 1536).Solution 4: Voluntary Buyouts or Acquisitions: Based on further analysis of unmet needs, thestate may execute voluntary buyouts or acquisitions in limited situations where the statedetermines it is more cost effective to buyout or acquire a property from a homeowner.Using data from prior acquisition and buyout programs implemented by the state and other HUDgrantees, the program will establish an average cost of buyout that will be used as a threshold forcost effectiveness to determine whether voluntary acquisition or a buyout should be consideredin lieu of a rehabilitation or reconstruction.Generally, the state does not intend to elevate homes that are slab on grade and the state has putmechanisms in place to ensure all structures requiring elevation go through an analysis todetermine whether a) rehab and elevation or b) demolition, reconstruction and elevation of thestructure is the more cost effective approach to helping that homeowner get home. In both cases,the state will also evaluate the cost effectiveness of the chosen approach as compared to the costof buying out or acquiring the property from the homeowner.Through past experience, the state understands it can be more costly in the long-run to implementand maintain a buyout and acquisition program than a rehabilitation or reconstruction program;therefore when assessing the cost reasonableness of a buyout/acquisition approach as opposedto the a) rehab and elevation or b) demolition, reconstruction and elevation of a home, the statewill consider the costs of acquiring a property at pre-storm value, potentially providing interimhousing assistance to the family, ongoing property maintenance, title work, operational expensesand all other expenses necessary to reaching final disposition and national objective with theacquired property.Following recent changes to FEMA's Severe Repetitive Loss program, which limit buyouts toneighborhood solutions to reduce unintended negative consequences of single buyouts to aneighborhood or jurisdiction, the state reserves the right to continue with a rehabilitation orreconstruction if the impact of a buyout on the neighborhood or jurisdiction could be detrimental.Eligible Applicants: Homeowners will be eligible for the program if they meet the following criteria:>> Owner occupant at time of disaster event>> Damaged address was the applicant's primary residence at the time of disaster event>> Located in one of 51 disaster declared parishes80>> Suffered major or severe damages (1+ feet of flooding or $8,000 FEMA Verified Loss) as a resultof the 2016 Severe Storms and Flooding events>> Eligible structure as determined by program, including but not exclusive to, one or two familyhome structures, mobile/manufactured, and modular homesDue to limits in the funding available in the first two allocations, the state prioritized a first phase of theprogram impacted homeowners meeting the criteria outlined below. With additional funding madeavailable in the second allocation, the state will expand program eligibility criteria to assist additionalhomeowners described above as Eligible Applicants with remaining unmet needs. This includeshouseholds of all income levels with primary residences located inside or outside of the floodplain thatcan exhibit a remaining need for funding to repair or rebuild their homes in keeping with the guidelinesof the program. Due to the number of impacted homeowners eligible for the program, the state intendsto fund eligible homeowners in phases. As the state collects additional data and information from FEMA,SBA, NFIP, other funding sources and real and potential homeowner applicants, the state may expand thecriteria listed in the phases below to include homeowners who had a structural flood insurance policy atthe time of the flood and have an eligible remaining unmet need.Phase I: The equally-weighted criteria for Phase One of the program include all of the requirementsbelow:>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or havedamage which meets the major/severe damage standard, as defined by the program;>> The applicant household meets federal Low- to Moderate-Income (LMI) requirements;>> The applicant or co-applicant is elderly (age 62 on the date of the disaster event) OR is a personwith disabilities or has a person with disabilities in the household;>> The home is located outside the Special Flood Hazard Area (floodplain);>> The homeowner has completed all work or has remaining prospective work to complete at thetime of application; and>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.Phase II: The equally-weighted criteria for Phase Two of the program include all of the requirementsbelow:>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or havedamage which meets the major/severe damage standard, as defined by the program;>> The applicant household meets federal Low- to Moderate-Income (LMI) requirements;>> The applicant or co-applicant is elderly (age 62 on the date of the disaster event) OR is a personwith disabilities or has a person with disabilities in the household;>> The home is located inside the Special Flood Hazard Area (floodplain);>> The homeowner has completed all work or has remaining prospective work to complete at thetime of application; and>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.Phase III: The equally-weighted criteria for Phase Three of the program include all of the requirementsbelow:81>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or havedamage which meets the major/severe damage standard, as defined by HUD;>> The impacted home is located within one of the ten most impacted and distressed (MID)parishes;>> The home is located outside the Special Flood Hazard Area (floodplain);>> The homeowner has remaining prospective work to complete at the time of application; and>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.Homeowners who qualify under Phase III may be eligible for assistance for prospective work andreimbursement for work incurred prior to application, or within HUD approved guidelines.Phase IV: The equally-weighted criteria for Phase Four of the program include all of the requirementsbelow:>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or havedamage which meets the major/severe damage standard, as defined by HUD;>> The impacted home is located within one of the ten most impacted and distressed (MID)parishes;>> The home is located inside the Special Flood Hazard Area (floodplain);>> The homeowner has remaining prospective work to complete at the time of application; and>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.>> Homeowners who qualify under Phase IV may be eligible for assistance for prospective workand reimbursement for work incurred prior to application, or within HUD approved guidelines.Phase V: The equally-weighted criteria for Phase Five of the program include all of the requirementsbelow:>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or havedamage which meets the major/severe damage standard, as defined by HUD;>> The impacted home is located within one of the 51 Presidentially declared parishes;>> The homeowner has remaining prospective work to complete at the time of application; and>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.>> Homeowners who qualify under Phase V may be eligible for assistance for prospective work andreimbursement for work incurred prior to application, or within HUD approved guidelines.Phase VI: The equally-weighted criteria for Phase Six of the program include all of the requirements below:>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or havedamage which meets the major/severe damage standard, as defined by HUD;>> The impacted home is located within one of the 51 Presidentially declared parishes;>> The homeowner has completed rehabilitation or reconstruction of their home at the time ofapplication; and>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.Criteria for Selection: The prioritization criteria outlined above are weighted equally; therefore, theprogram will not give preference to any individual homeowner over another so long as all criteria havebeen met. In designing the eligibility and prioritization criteria, OCD-DRU has aimed to provide assistanceas soon as possible to those determined to be most in need of such assistance. For a homeowner toreceive assistance in Phase One of the program, all eligibility and prioritization criteria (as they are defined 82above) must be met. Applications from applicants that meet all the criteria above will be processed asthey enter the program. It is anticipated the state will be able to serve all homeowners who meet theeligibility and prioritization criteria listed herein. Criteria for selection will be further determined withinthe program policies and procedures based on availability of funds and number of applications.Maximum Award: The maximum award will be determined by the scope of work based on a consistenteconomy grade of building materials as calculated by the program using national building standardestimating software, less any duplication of benefits (e.g. NFIP, FEMA or SBA). Duplication of Benefits isdefined further in the program policies and procedures. The state will include details of the programstandards in its policies and procedures.Due to limited funding, the state will implement the program using two dual-tiered award approaches fora) prospective work (Solutions 1 and 2) and b) reimbursement (Solution 3). Below are the details of thetwo dual-tiered award approaches:a) Prospective Work (Solutions 1 and 2)>> At the time of application, homeowners still have repairs or reconstruction work to completeon their homes>> Program completes an inspection and generates a scope of work based on economy gradematerials>> Program completes a duplication of benefits check>> Program deducts the duplication of benefits from the scope of work>> Program determines an eligible prospective award amount>> Program applies the dual-tiered award approach:a. Homeowners with household incomes of 0-120% Area Median Income are eligible for100% of the eligible award amount for prospective workb. Homeowners with household incomes of 120%+ Area Median Income are eligible for 50%of the eligible award amount for prospective workb) Reimbursement (Solution 3)>> At the time of application, homeowners may have completed all or partial repairs orreconstruction of their homes>> Program completes an inspection and generates a scope of repaired work based on economygrade materials>> Program completes a duplication of benefits check>> Program deducts the duplication of benefits from the scope of work>> Program determines an eligible reimbursement award amount>> Program applies the dual-tiered award approach: 83a. Low to moderate income households with either an owner/co-owner who is elderly (62+)or has a person with disabilities living in the home are eligible to receive 100% of theireligible reimbursement award amountb. All other households are eligible for 25% of their eligible reimbursement award amountBased on FEMA and SBA data, the current eligibility limitations described in the phased approach, thedual-tiered award structure and economy grade materials approach, the program currently anticipatesserving around 36,510 homeowners through the program as currently budgeted. Using best availabledata, the state anticipates serving the following number (see table below) of homeowners in each of thephases. These numbers do not reflect a participant cap for each of the phases; the actual numbers servedin each of the phases will be determined once the program is underway.Projected Number of Homeowners Served perPhaseTOTAL 36,510Phase I 3,798Phase II 4,504Phase III 11,009Phase IV 8,586Phase V 2,972Phase VI 5,642Homeowners may provide personal funding to expand the program-approved scope of work or pay forhigher quality materials. Further details will be outlined in the program policies and procedures.Program Managed and Homeowner Contracted Programs – The sample award calculations below arebased on if a homeowner is eligible for 100% of the eligible award amount. These award amounts aresubject to the dual-tiered award approaches described above:Example 1Scope of Work $120,000Duplication of BenefitsFEMA Assistance for StructuralRepairs to Home $12,000SBA Loan for Structural Repairs toHome $25,000Total duplication of benefits $37,000Maximum Eligible Award $83,000Example 2Scope of Work $100,000Duplication of Benefits 84FEMA Assistance for StructuralRepairs to Home $12,000SBA Loan for Structural Repairsto Home $20,000Grant from a local non-profit topurchase sheetrock $5,000Total duplication of benefits $37,000Maximum Eligible Award $68,000Program Timeline: The State of Louisiana anticipates the launch of the Homeowner Program in the secondquarter of 2017. Homeowners will initially complete a survey and then will be invited to apply to therespective phase of the program under which they claim to meet the respective criteria. As additionalphases open for application review and processing, homeowners who qualified under previous phasesmay be able to apply to the program even as later phases are open. The state may add, expand or amendthe program phases following updated assessments of unmet homeowner needs. The state willcommunicate which program phases are open for application through direct communication withhomeowners who completed the survey and through the approaches in the state's outreach plan that willbe undertaken by the state's program manager. The program will end when all funds are expended, or sixyears after the execution of the grant agreement with HUD.Restore Louisiana Rental Housing ProgramsSummary: The State of Louisiana will establish a portfolio of rental programs to address the immediateand long-term housing needs of low-to-moderate income families in the flood impacted areas. Due to theshortage of affordable housing stock, and to meet the unmet needs of renters in the community, it isimperative to provide solutions that address the immediate housing needs of displaced and vulnerablerenters, but the state has designed programs and plans to provide the majority of funding allocated forrental programs on long-term recovery solutions that replace and create affordable housing stock. Eachprogram will address rental availability, affordability and quality standards.As stated in the 2014 Housing Needs Assessment conducted by LSU, Louisiana residents across the stateare rent burdened. The floods of 2016 made the situation in many areas of Louisiana much worse. Thevacancy rates dropped to about 1 percent and monthly rents increased. Currently, 720 low-incomefamilies are receiving FEMA Temporary Shelter Assistance (TSA), which is currently set to end in February2017. New construction, substantially damaged, or substantial improvement of structures in the 1 percentannual (or 100 year) floodplain must be elevated to meet the higher standard of either federalrequirements or local ordinance requirements.Due to the limited amount of funding available, the state will underwrite applicants for feasibility, costefficiencies and ability to meet the goals of the programs. Applicants will be prioritized based on meetingprogram eligibility requirements.Geographic Eligibility: Disaster-declared parishes impacted by the 2016 Severe Storms and FloodingAllocation for Activities: 85Program Area FirstAppropriationSecondAppropriationTotal % ofTotalRental Repair and In-fill,Multifamily Gap, Piggyback,Rapid Rehousing and PSHSupport Services$19,000,000 $111,000,000 $130,000,000 6%Administrating Entity: State of LouisianaProposed Use of Funds: Programs may include: repair, rehabilitation of flood-damaged units; newconstruction to increase available rental units; assistance to pay for a defined period of rental assistanceor support services; and assistance to pay for a defined period of flood insurance premiums for eligibleprogram applicants.Initially, the state will address the affordable rental housing needs through the activities defined below:>> Repairing Rental Units (Repair and Infill Program and Multi-family Gap Program): The state hascreated options within the rental program that will enable some rental units to be restoredwithin a few months. Property owners will be able to receive funds as a loan to repair units andin exchange the state will require affordable rents for qualified families.>> Creating New Rental Units (Repair and Infill Program, Multi-Family Gap Program andPiggyback): Creating new rental units is another viable approach to provide needed relief forrenters located in the damaged parishes. This program will utilize lots already owned andcontrolled by local nonprofits and units of local government. In partnership with local housingagencies such as redevelopment authorities and community housing development organizationsas well as financial institutions, the state can assist the development of new and rehabilitatedrental units within nine months to a year. The state will require affordable rents for qualifiedfamilies.>> Housing Assistance to Displaced Renters (Rapid Rehousing): Providing tenant-based assistanceto families displaced by the floods who are also at risk of homelessness or experiencinghomelessness.>> Public Support Services (Rapid Rehousing and PSH Support Services): Providing wrap-aroundsupport services to families displaced by the floods who are also at risk of homelessness and/orare in need of permanent supportive housing solutionsDuplication of Benefits: All rental programs will include a duplication of benefits review as part of theapplication review and award calculation process.Eligible Applicants: Landlords with vacant units and/or units occupied by low-to moderate incomefamilies that were displaced by the flood, community development nonprofits, Public Housing Authorities(PHAs), Development Authorities, and Community Housing Development Organizations (CHDOs) and/orprivate entities.Criteria for Selection: Applicants will be prioritized based on meeting program eligibility requirements.More specific prioritization criteria will be outlined in program policies and procedures. At this time, thereare no specific prioritization criteria given more weight or value than others. 86Program Timelines: The State of Louisiana anticipates launching the Restore Louisiana Rental HousingPrograms in the second quarter of 2017. The program will end the earlier of when all funds are expendedor six years after the execution of the grant agreement with HUD.In-fill and Rehabilitation Rental ProgramSummary: This program seeks to rehabilitate or create new affordable housing units through the creationof a fully or partially forgivable loan program.Eligible Activity Rehabilitation, new construction, loan financing (HCDA Sections 105(a)(4)); 105(a)(8-9); 105(a)(15)).National Objective Benefit to low to moderate income personsProgram Budget $45,000,000Proposed Use of Funds: Awards provided to landlords under the program for the repair or creation ofaffordable housing for low income families may be issued as a fully or partially forgivable or fully repayableloan for eligible rehabilitation, reconstruction or new construction costs, as defined in the programpolicies and procedures. Reimbursement of eligible expenses may also be eligible and will be detailed inthe program policies and procedures.Eligible Applicants: Community Housing Development Organizations; 501(c)3 and 501(c)4 Not-for-ProfitOrganizations; Public Housing Authorities (PHAs); development agencies of units of local government(public or quasi-public); for-profit entities registered under the State of Louisiana; or private landlordsMethod of Distribution: The award will be issued as a loan or a grant to eligible applicants. The state willopen an application process for all eligible property owners for a defined period of time, following a seriesof workshops in which program staff will provide technical assistance to potential applicants so theyunderstand the requirements of the program. During the workshops, program staff will provide additionalinformation on the application timeline, process and eligibility criteria. Landlords will be able to askquestions and understand the full requirements of the program. Potential applicants are not required toparticipate in the workshops in order to apply to the program; the program staff will conduct a series ofoutreach efforts in order to encourage impacted and eligible landlords to apply to the program. Eachproperty will be underwritten to ensure project viability for completion and sustainability for the durationof the affordability period. The sequence in which the program will provide assistance to applicants isbased on those who are able to first demonstrate how they meet the program criteria, complete theirapplications in a timely manner, provide all requisite support documentation, secure all funding necessaryto complete and sustain the project in the short and long-term and have a reasonable timeline to beginconstruction.Criteria for Selection: In order to be eligible for the program, applicants will be reviewed based on thefollowing basic equally weighted criteria. Priority will be given to applicants able to meet the goals andrequirements of the program in a timely and/or cost-efficient manner. If additional criteria are includedin the program application review process, they will be described in detail in the public-facing programpolicies and procedures:>> Owners of flood-damaged properties with 1-7 units in a single structure>> Private landlords are eligible to apply to the program for the properties they owned prior to theflood events87>> Non-profit or public entities may be eligible if they have flood-damaged properties and/or vacantlots available for new construction>> All applicants must secure a construction loan or other interim financing to complete thenecessary repairs or construction; CDBG-DR funds will be funded upon satisfactory completion,as will be defined in the public-facing program policies and procedures;>> Ability to provide and sustain affordable housing units for low income families for the requisitetime period and terms established by the program; and>> Cost reasonablenessMaximum Award: The maximum award will be the lesser of the cost of construction or limits set by theprogram below. Each project will be reviewed for duplication of benefits, financial feasibility and costreasonableness. An applicant landlord may be eligible to receive multiple awards for multiple eligibleproperties. Awards per property will not exceed the following amounts for the following structure types:Building Size MaximumAwardSingle Family Unit $150,000Double Unit $250,000Triple Unit $315,000Four Unit $375,000Five to Seven Units $500,000Affordability Requirements:Definition of Affordable Rents: Housing is considered “affordable” if the rent (including utilities) is no morethan 30 percent of a household's pre-tax income.Number of Units: In order to be eligible for the program, at a minimum, the recipients must agree to meetthe occupancy rule requirements established by HUD (see below). However, as will be detailed in theprogram guidelines, the state may require recipients to provide affordable housing to low-to-moderateincome housing through additional units within assisted structures:>> All assisted single unit structures must be occupied by L/M income households,>> An assisted two-unit structure (duplex) must have at least one unit occupied by a L/M incomehousehold, and>> An assisted structure containing more than two units must have at least 51 percent of the unitsoccupied by L/M income households.Duration of Affordability: The provision of affordable rents to qualified tenants will be required at aminimum for the initial lease-up, but longer affordability terms may be required. The duration ofaffordability may be tied to the amount of funding provided to the landlord. This will be further definedin the final program policies and procedures.Multifamily Rental Gap ProgramSummary: As noted in the unmet needs assessment, many properties outside the floodplain were notrequired to hold insurance and thus have no means to offset the cost of repair. For those property ownersthat had insurance, the cost of repair may not be fully met. Given these circumstances, each group of 88property owners may face significant gaps to repair units. In addition, insurance rates may increase giventhe extensive nature of the disaster. It is anticipated that owners of large developments may have afinancial burden in operation and cash flow, which will impact their ability to recover and offer long-termaffordable housing to qualified rentersEligible Activity Rehabilitation, loan financing (HCDA Sec. 105 (a)(4); 105(a)(9);105(a)(14-15))National Objective Benefit to low to moderate income personsProgram Budget $45,000,000Proposed Use of Funds: Funding will be provided in the form of a loan to the property owners of floodimpactedproperties with 20 or more units to cover eligible unmet needs. Owners will be required to signa completion guaranty, at a minimum. This program will provide assistance for eligible unmet needsrelated to the hard and soft costs of repair or reconstruction of eligible properties, subject to programpolicies and procedures. Eligible flood insurance premiums may also be covered through program funds,subject to program limits. Reimbursement of eligible expenses may also be eligible and will be detailed inthe program policies and procedures. New construction is not eligible under this program.Eligible Applicants: For-profit and non-profit public and private property owners and developers of floodimpactedproperties; Public Housing Authorities. Both property owners of existing affordable housingproperties and owners of market-rate properties are eligible to apply to the program. In return forprogram assistance, owners of market-rate properties must agree to convert at least 51% of their units toaffordable units for eligible low income tenants for a defined period of time that is commensurate withthe amount of assistance provided through the program.Method of Distribution: Funding will be provided in the form of a loan or grant to the public and privateproperty owners, developers or Public Housing Authority. The program will be implemented on acompetitive basis. The program will be open for application for a defined period of time, as will bedescribed in the Notice of Funding Availability to request applications from developers. Priority may begiven to properties with existing affordability requirements; the details of the prioritization andapplication review process will be detailed in program solicitations issued by the state and/or the programpolicies and procedures.Criteria for Selection: The program will address multi-unit developments in two categories:>> Flood-damaged properties with 20 units or more; and>> Properties in a Special Flood Hazard Area (floodplain) with the required flood insurance; or>> Properties not located in a Special Flood Hazard Area (floodplain).While priority may be given to properties with existing affordability requirements, the state may alsoinvest in market-rate properties which have experienced flood-related damages but do not have sufficientfunds to repair and restore the units, and whose property owners would commit to certain affordabilityrequirements in return for repair funds. Priority will be given to those applicants who demonstrate thereadiness, feasibility, sustainability and cost reasonableness of their projects.Maximum Award: The maximum award will be set after determination of damage during programimplementation. Each project will be reviewed for financial feasibility and cost reasonableness.No payment will exceed a total amount of $65,000 per unit.89Affordability Requirements:Definition of Affordable Rents: Housing is considered “affordable” if the rent (including utilities) is no morethan 30 percent of a household's pre-tax income.Number of Units: In order to be eligible for the program, at a minimum, the recipients must agree to meetthe occupancy rule requirements established by HUD (see below). However, as will be detailed in theprogram guidelines, the state may require recipients to provide affordable rental housing to low-tomoderateincome housing through additional units within assisted structures:>> An assisted structure containing more than two units must have at least 51 percent of the unitsoccupied by L/M income households.Duration of Affordability: The provision of affordable rents to qualified tenants will be required at aminimum for the initial lease-up, but longer affordability terms may be required. This will be furtherdefined in the final program policies and procedures.Program Timeline:Piggyback ProgramSummary: The state will develop a ‘piggyback' program that will seek to leverage CDBG-DR with lowincome housing tax credits (LIHTCs) or other sources to address the longer-term housing recovery needsin the impacted communities.Eligible Activity Acquisition, clearance, rehabilitation, reconstruction, and newconstruction, elevation, loan financing HCDA Sections 105 (a)(1),(4) and(14)National Objective Benefit to low to moderate income personsProgram Budget $19,000,000Proposed Use of Funds: Assistance will be provided in the form of loans for gap financing for mixedincome,additional affordability, and PSH developments.Eligible Applicants: For-profit and non-profit public and private property owners; Public HousingAuthorities.Method of Distribution: The Piggyback Program funds will be awarded to specific developments inaccordance with a competitive funding process. The state will issue a competitive Notice of FundingAvailability for a defined period of time, inviting eligible developers to apply to the program. The timingof the application period will coincide with the state's availability of Low Income Housing Tax Credits. Theprogram will review and underwrite each project for eligibility, feasibility, leverage and costreasonableness. Priority will be given to the most cost-effective projects.Criteria for Selection:Within the approved developments, the program will provide assistance to medium and large-scaleaffordable and mixed income rental housing developments, specifically:90>> Workforce Housing Units. The program will facilitate the creation of mixed-income projectsincluding market-rate units and units affordable to (and restricted to occupants by) householdswith incomes below both 80% and 60% of area median income (AMI).>> Additional Affordability Units. The state will facilitate development of units affordable to (andrestricted to occupancy by) households with incomes at or below 20% of AMI, 30% of AMI, and40% of AMI.>> Permanent Supportive Housing (PSH). The state will also facilitate the development ofpermanent supportive housing for a variety of households including extremely low incomepeople (20% AMI and below) with serious long term disabilities, and/or who are homelessand/or who are most at-risk of homelessness.o The primary strategy is a PSH Set-Aside Program, under which all properties thatreceive CDBG-DR funds will be required to make at least 5% of total units available toPSH clients, who will be supported by appropriate services. Additional incentives in theform of bonus points in the project selection scoring system may be awarded toprojects that elect to assist greater than 10% of their units.o An additional strategy is development of PSH properties in which at least 15%, but notmore than 50% of the units are set-aside for PSH. PSH clients will be supported byappropriate services.Maximum Award: The maximum award for which a project is eligible will be determined on a case-bycasebasis after a project is thoroughly underwritten. Each project will be reviewed for affordablehousing outcomes, financial feasibility and cost reasonableness. No payment will exceed a total amountof $65,000 per unit.Rapid Rehousing ProgramSummary: The state has established a model of Rapid Rehousing for households following disasters. TheRapid Rehousing Program (RRH) is based on an effective solution to address the needs of persons eitherexperiencing homelessness or at risk of becoming homeless by providing a combined solution ofassistance for affordable housing and support services that help households to be self-sufficient. Thisincludes preventing homelessness whenever possible by rapidly rehousing people when homelessness isimminent and providing ‘wrap around' services that stabilize the cost of housing and supports selfsufficiencyfor the household.Eligible Activity HCDA Sec. 105 (a)(4), 105(a)(8)National Objective Benefit to low to moderate income personsProgram Budget $16,000,000Proposed Use of Funds and Maximum Award: Funds may be used for up to 24 months of the actual costsfor rental assistance, security and utility deposits, rental and utility arrearages, application andbackground check fees charged when applying for housing. Total monthly rental assistance for eligibleprogram participants will be determined based on an evaluation of rent comparables and will be limitedto a maximum of 24 months of monthly rental assistance. In addition, funds will be provided to theprogram subrecipients to provide wrap-around services to those families receiving rental assistance. Thewrap-around services are critical to helping families become independent from the rental assistance.Eligible Applicants: Displaced households at 30% AMI and below91Criteria for Selection:This program will provide rental assistance and support services to renters displaced by the floods whoare experiencing homelessness or are at risk of becoming homeless. Populations deemed at risk ofbecoming homeless include very low and extremely low income families receiving Temporary ShelterAssistance (TSA) from FEMA and very low and extremely income families temporarily living with friendsand family.The program is limited to those individuals and families who experience a demonstrable hardship. Thestate has defined a family or an individual to be experiencing demonstrable hardship for this program ifthey were displaced by the flood and lack the resources to obtain housing on their own, are experiencingliteral homelessness, are persons whose primary source of income was impacted by the flood, areexperiencing health issues that were exacerbated by the flood and/or are persons with disablingconditions prior to the flood that are exacerbated by the flood.Method of Distribution: The state will open the application period for 90 days, using the Disaster CaseManagement (DCM) team, a team implemented and administered by the Louisiana Department of Healthand a network of non-profit organizations, in the selection process for eligible applicants. The DCM willperform applicant intake and will complete the review and eligibility determination. The state will makepayments for eligible expenses directly to the landlords of eligible program participants.Permanent Supportive Housing Services ProgramSummary: Supportive housing has proven to be a very successful answer to preventing homelessnessbecause it is a cost effective, community-friendly alternative to shelters that enables individuals to remainhoused and achieve increasing levels of self-sufficiency. Supportive housing is permanent affordablehousing linked to tenancy support services (health, mental health, employment) required to helpindividuals rebuild their lives after homelessness, institutional care or other disruptions. Tenancy supportservices include any service necessary to help a program participant maintain their rental unit, such asemployment search support, physical and mental health support services, referral services to otherprograms and support networks, life skills training, reminders to pay bills on a regular basis, financialmanagement and budgeting, etc. The support services provided through this program will assistindividuals in transitioning to Permanent Supportive Housing and maintaining successful, long-termtenancies.Eligible Activity HCDA. Sec.105(a)(8), 105(a)(11)National Objective Benefit to low to moderate income personsProgram Budget $5,000,000Use of Funds and Maximum award: Pre- and post-tenancy support services, up to $5,000 per year perperson receiving servicesEligible Applicants: A household is considered to be in need of permanent supportive housing if all fourof the following conditions are met:1. A household member has a substantial, long-term disability including but not limited to seriousmental illness, addictive disorder with a co-occurring disorder, developmental disability, physical,cognitive, or sensory disability, or a disabling chronic health condition, which substantially 92impedes that person's ability to live independently without supports; and is of such nature thatthe ability to live independently could be improved by more suitable housing conditions; and2. The household member with the condition in (1) above is receiving Medicaid-funded or otherfunded supports and services operated or managed by the Department of Health and Hospitalsprogram offices for Behavioral Health, Developmental Disabilities, Public Health or Aging andAdult Services, the U.S. Department of Veterans Affairs or local Continuum of Care; and3. The supports or services in (2) above expressly include assisting the qualified member to get andkeep housing; and4. Have household incomes at or below 50% AMI.Criteria for Selection: Households that are homeless, at risk of becoming homeless, living in an institution,or at risk of living in an institution will be prioritized.Method of Distribution:The program will use the existing state PSH program that serves as a model for the rest of the country.The state will work with Louisiana Department of Health and their existing subrecipient service providersto expand their program to target individuals displaced by the 2016 Severe Storms and Flooding. Theapplication period will be open to all eligible participants until all funds necessary for the services areexpended by program subrecipients.2. Economic RevitalizationRestore Louisiana Economic Revitalization ProgramsSummary: The state has allocated $62,000,000 to support economic revitalization in impacted areasthrough a suite of programs described below. The state understands that residential communities cannotfully recover and thrive without businesses returning to the community, as they provide essential servicesand employment to local residents. It is imperative that the state invest in those businesses that supportrecovering neighborhoods, provide local employment opportunities and produce the foods consumeddirectly or indirectly by local residents. In order to ensure these businesses remain viable and resilient inthe face of future disasters, it is critical the state provide technical assistance to the impacted businesses.The state has prioritized businesses that experienced physical or financial losses as a result of the 2016Severe Storms and Flooding and remain in need of immediate financial assistance to reopen or remainviable in the impacted communities.The economic revitalization portfolio included herein aims to support the state's long-term housingrecovery in the following ways:>> Provide assistance to small businesses that provide income-producing jobs to residents of thedisaster-impacted communities.>> Provide assistance to small businesses that provide services, goods and amenities to residents ofthe disaster-impacted communities.>> Provide assistance to farmers that produce the crops necessary to directly or indirectly feed theresidents of the disaster-impacted communities and/or contribute to the economic stability oftheir communities.93>> Adding to the local governments' and state's tax base through the generation of sales taxes,which in turn will allow these governments to continue to provide essential public services tothe disaster-impacted communities.>> Ensure the financial assistance invested in these programs is sound and secure through theprovision of technical assistance to eligible businesses.Geographic Eligibility: Disaster-declared parishes impacted by the 2016 Severe Storms and FloodingAllocation for Activities:Program Area FirstAppropriationSecondAppropriationTotal % ofTotalSmall Business Loan andGrant Program, SmallBusiness Technical AssistanceProgram and Louisiana FarmRecovery Grant Program$11,400,000 $50,600,000 $62,000,000 4%Administering Entity: State of Louisiana and subrecipientsProposed Use of Funds: Funds will be in the form of loans and/or grants to businesses, farmers as well asgrants to entities that provide technical assistance services to businesses. Funds may be used for operatingexpenses (rent/mortgage, insurance, utilities, non-owner employee wages); replacement of movableequipment or inventory necessary for a business's recovery; and future crop needs. Funds may also beused to provide technical assistance services to businesses.Duplication of Benefits: All economic revitalization programs will include a duplication of benefits reviewas part of the application review and award calculation process.Ineligible Activities: Forced mortgage payoffs; SBA home/business loan payoffs; funding for secondhomes; assistance for those who previously received Federal flood disaster assistance and did notmaintain flood insurance; and compensation payments.SBA Declined Loans: Business owners approved for SBA loans who declined their loans will be reviewedfor eligible award amounts and duplication of benefits, per the state's program policies and procedures.Small Business Loan and Grant ProgramSummary: The state will administer a lending program for disaster-impacted small businesses for nonconstructionrelated expenses. The state will enter into subrecipient agreements with implementingpartners including local community development organizations (non-profit organizations, communitydevelopment financial institutions, local credit unions, and other eligible organizations) who qualify underSection 105(a)15 of the HCDA. In the event the state is unable to identify local community developmentorganizations that can serve the entire impacted area, the state may issue awards directly to smallbusinesses that meet the program criteria.Eligible Activity HCDA Section 105(a)8, 105(a) 14-15, 105(a) 17 and 105(a)21-22National Objective LMI Job Creation and/or Retention, LMI Area Wide Benefit, LMI LimitedClientele, Urgent Need94Program Budget $51,200,000Proposed Use of Funds: Funds will be used for a package of partially forgivable loans or grants up to 20percent with fully repayable loans up to 80 percent. Loan rates will be zero- to low-interest, amortizedand repaid over a term outlined in the program policies and procedures. Reimbursement of eligibleexpenses may also be eligible and will be detailed in the program policies and procedures.Eligible Applicants: For-profit businesses and private non-profit organizations located in parishesimpacted by the 2016 federally-declared severe storms and flooding events.Criteria for Selection: In order to be eligible for the program, businesses must meet the following equallyweightedcriteria. If additional criteria are included in the program application review process, they willbe described in detail in the program policies and procedures:>> Are located in one of the 51 federally declared disaster impacted parishes;>> Were operating prior to the respective flood events (March or August);>> Employ 1 to 50 full time equivalent employees;>> Generate a minimum of $25,000 annual gross revenue; and>> Were directly impacted by the floods, as a documented physical or financial lossWhile the state will continue to prioritize businesses that provide essential goods or services, with theaddition of the second allocation, the state has expanded the pool of businesses to all Eligible Applicantsdefined above.Note: Essential goods or services are considered to be those goods or services necessary for theimmediate and long term housing and community recovery, which will be detailed in the programpolicies and procedures. Such goods and services may include grocery stores, pharmacies, healthcareproviders, gas stations, residential construction-related companies, child care providers and locallyownedrestaurants or residential service providers.Assistance type: The state will decide whether the program awards will be issued to eligible businessesand non-profits in one of the following award structures:a) 80 % loan and 20% grant; orb) 80% fully repayable loan and 20% forgivable loanMaximum Award: The program will provide standard awards of a maximum of $50,000, with exceptionsallowing for up to a maximum award of $150,000. The state will include its exceptions policy in theprogram policies and procedures.Loan interest rate and loan term: Zero to low interest rate loan, amortized and repaid over terms outlinedin the policies and procedures.Method of Distribution:The state will issue a Notice of Funding Availability to secure subrecipient lenders who will implement theprogram on behalf of the state. Grants will be made to subrecipients who qualify under Section 105(a) 15of the HCDA and who meet the requirements outlined in the NOFA, which include the lending applicants'demonstrated capacity to implement the flood recovery program in eligible parishes. 95The state will conduct extensive outreach to the business community and will open the application periodfor one month in the second quarter of calendar year 2017. The first phase of the program is limited tothose businesses considered to provide an essential good or service. Applicant businesses and non-profitswill apply to subrecipient lenders, who will underwrite the businesses for program eligibility, eligibleexpenses and financial viability. If additional funds are available after the first phase of the program, thestate may open another phase of the program to include additional small businesses.Program Timeline:The state anticipates launching the program in the second quarter of calendar year 2017. The first phaseof the program application will be open for one month. The state may implement additional phases if allfunds are not expended in the first phase.Small Business Technical Assistance ProgramSummary: Business owners recovering from disasters are often in need of specific technical assistance torespond to losses to their businesses, whether it be a loss of employees or customers or a need for a newproduct that may present a growth opportunity for a business. Technical assistance providers supportbusinesses to develop new business plans and continuity plans, reestablish lost financial records and datasystems and create a disaster resilience plan to help prepare for future disasters.Eligible Activity Section 105(a)8, 105(a) 15, 105(a) 17, and 105(a) 21-22National Objective LMI, Urgent NeedProgram Budget $800,000The state will develop a program to provide technical assistance services to businesses to bolster the grantand loan resources and strengthen the business community.Proposed Use of Funds: Grants will be awarded to subrecipients who will provide technical assistanceservices to small businesses and non-profit organizations. Technical assistance activities may include butare not limited to: development of business continuity plans; financial management guidance; and longtermrecovery and sustainability plans for businesses impacted by the flooding events.Eligible Applicants: For-profit small businesses and private non-profit organizations may be referred orrequest technical assistance either through the Small Business Loan and Grant program or else mayrequest technical assistance directly from the subrecipients implementing the Technical Assistanceprogram.Method of Distribution:The state will engage the Small Business Development Centers (SBDC) as subrecipients to the program.The SBDCs will provide the technical assistance services directly to businesses. SBDCs have a proven trackrecord working within their business community and have a unique understanding of the challenges facingbusinesses in and outside their portfolio. SBDCs may provide technical assistance services to businesseswithin their portfolio as well as to those businesses referred to the SBDCs by the subrecipientsimplementing the Small Business Loan and Grant program.Program Timeline:The state anticipates launching the program in the second quarter of calendar year 2017, in conjunctionwith the Small Business Loan and Grant Program.96Small Business Bridge Loan ProgramSummary: The Louisiana Flood Bridge Loan Program provides banks a guarantee against losses for shorttermbridge loans to assist businesses with immediate capital while they seek flood insurance, SBAassistance or other longer-term recovery assistance. The program will be designed to provide immediate,rapid financial assistance using existing banks as the conduit for businesses to gain access to the resources,and immediately useful in the short term of the first 12-18 months after the disaster.Due to a change in allocation and funding priorities, the state will not administer this program at thistime.Louisiana Farm Recovery Grant ProgramSummary: To assist the agricultural sector recovery from the 2016 floods, the Louisiana Department ofAgriculture and Forestry (LDAF) designed the Louisiana Farm Recovery Grant Program (LFRGP) to assistindividual farm enterprises impacted by the Great Floods of 2016.Traditionally, the United States Department of Agriculture (USDA), via the Farm Bill and its crop lossprograms, has addressed storm related losses. However, in 2008, substantial new changes wereincorporated into the Farm Bill. Many of Louisiana's farmers would not qualify for recovery funds fromthis new USDA program; therefore, additional assistance is needed to fund the unmet needs faced byLouisiana producers.According to LSU Ag Center, the combined $367 million in flood-related damages resulted in a totalestimated economic impact of nearly 6 percent of typical farm value for the Louisiana agriculturalindustry. Moreover, most family farms face huge hurdles. Today just 19 cents of the retail food dollar goesto the farmer. This share represents a drop of more than 50 percent from what farmers received in 1950,leaving razor-thin profit margins, if any, for their families, and less money to spend in their localeconomies. Louisiana farmers are faced with the potential to lose money before the crop is even planted.They will not have the necessary income to cover farm expenses, and certainly will not be able to coverfamily living expenses including housing. This potential negative income not only affects the farmer, butalso employees and local communities that rely on her/his business.In Louisiana, farming supports not only the jobs generated by the farming operation, but also a numberof agribusiness sectors ranging from farm machinery equipment to food processing plants. Sustaining theproducers directly allows the agricultural industry to yield jobs and generates wealth for Louisiana's ruralcommunities. Communities that lose family farms lose a base of committed employers and consumers,causing more businesses to shut their doors, shrinking the local tax base and ultimately leading topopulation loss. This pattern drains local businesses and can decimate the social fabric of ruralcommunities, increasing unemployment rates and placing a higher demand on access to affordable rentalhousing. If farmers are faced with a lack of access to adequate recovery resources, when compoundedwith an aging farming population and an exodus of rural youth to urban areas, previously vibrant farmingcommunities will experience a sharp decline. The jobs and the salaries that come with the farm andagricultural industry allow people in agriculture to remain in their homes.Furthermore, historically, producers commonly utilize their houses for collateral and in many instancesthe farm business operates out of their home. If the farm ceases to exist, the producer can no longerafford his/her home. The home will have to be sold if it was used as collateral for production loans. If theproducers lose their homes there is limited housing stock available for relocation. If producers do not have 97access to resources necessary to recover from the impacts of the 2016 floods, they may not be able tostay in their homes. This would force outmigration and make it difficult for communities to experiencelong-term housing and economic recovery. While these homes are not aggregated in densely populatedneighborhoods, rural communities thrive on the network of residents living in the area. Closure of farmsand the departure of residents unable to recover from the impacts of the floods would result in theunraveling of the social, community and residential fabric of Louisiana's flood-impacted ruralcommunities.The LFRGP will provide $10 million to eligible impacted farms in all of Louisiana's disaster declaredparishes. The program targets farms that are deemed viable – having a chance to survive and able tocontribute to the economy while maintaining and creating rural jobs. Funds will be available via a directgrant to the farm. Farms assisted via the program are expected to plant a crop in 2017. Farms must beable to provide a plan detailing an acceptable use of funds including showing how they would use thegrant, specifically what they intend to plant, anticipated acreage and proposed timeline for their goal.The Louisiana Agricultural Finance Authority (LAFA, also referred to as “the Authority”) is a public agencyorganized pursuant to Louisiana Revised Statues 3§264 et al. and regulations promulgated. Through LAFA,with administrative assistance provided by LDAF, the state will implement, manage, and monitor LFRGP.Use of the expertise of LAFA will provide greater efficiencies in program delivery and ensure thataccountability and transparency are achieved, as LAFA and the farming industry have an establishedworking relationship with other federal disaster recovery programs.Eligible Activity 105(a)(17)National Objective Urgent need or benefit to low to moderate income personsProgram Budget $10,000,000Proposed Use of Funds: Farmers may use the proceeds from the grant program to pay off existing cropproduction loans that were originated to initiate production damaged or destroyed by the 2016 floods.Pre-existing loans that were used for production of crops damaged by the 2016 floods may only beserviced from the proceeds of this grant program following a commitment from a lending institution tofurnish sufficient funding for preparation, planting, management and harvesting of the 2017 crop. Fundsmay not be used for construction-related expenses. Reimbursement of eligible expenses may also beeligible and will be detailed in the program policies and procedures.Eligible Applicants: To be eligible for funding, producers must meet the following equally-weightedcriteria:>> Must have been in operation during the 2016 growing season;>> Must have received farm revenue in 2014, 2015 or 2016 of at least $25,000; and>> Must have suffered at least $10,000 in losses, damages, displacement or substantial farmingoperation interruption as a direct result of either or both floods.Method of Distribution: Applicants will apply to the Authority for funding during a defined applicationperiod. Requests for funds are expected to exceed the program's funding capacity. If the total request foreligible funds for all farms exceeds the total allocation, the Authority may pro-rata allocate funds to ensurethat all eligible entities have access to some funds. The Authority may also use professional judgment toensure that farms have access to capital.98Maximum Award: The maximum grant amount is $100,000.Program Timeline: The State of Louisiana anticipates the launch of the program in the second quarter of2017. The program will end when all funds are expended, or six years after the execution of the grantagreement with HUD.3. InfrastructureSummary: The flooding events of 2016 exposed vulnerabilities in the state's infrastructure system. TheState of Louisiana identified over $207 million in infrastructure needs, including over $105 million in nonfederalshare match for FEMA PA Projects throughout the state. Investments in infrastructure repair andrebuilding are necessary to secure the state's investment in housing repairs throughout impactedcommunities. These investments will bolster confidence in communities continuing to rebuild, as well asleverage the federal investment made in housing repair. Without assistance to meet the local matchrequirements, the public services, infrastructure and resources typically provided by state and localgovernments will be severely at-risk, as local governments will be required to either a) forgo assistancefrom FEMA PA or b) divert funding needed for other community needs toward meeting the matchrequirements. Communities need access to these critical public services and infrastructure improvementsin order to realize long-term recovery and restoration of housing. The state will dedicate $105,000,000 tooffset the burden of the non-federal share match requirements faced by state entities and local entitiesand jurisdictions.Program Area FirstAppropriationSecondAppropriationTotal % ofTotalInfrastructure: FEMA PublicAssistance Nonfederal ShareMatch$0 $105,000,000 $105,000,000 6%FEMA Public Assistance Nonfederal Share MatchMany federal agencies, including FEMA, require jurisdictions to pay a percentage of the costs of disastercleanup and recovery efforts. In the aftermath of catastrophic events, such as the Great Floods of 2016,the cost of this “non-federal share” of recovery can equal a significant portion of a jurisdiction's operatingbudget. Requiring a jurisdiction to pay this share can result in a burden on a locality's ability to continuenormal operations in addition to meeting recovery needs. Recognizing that this requirement places asignificant burden on localities, Congress has designated non-federal share as an eligible activity underCDBG-DR regulations, making it one of the few federal funding sources that can be used to offset ajurisdiction's non-federal match requirements.Eligible Activity Non-federal share 105(a)(9)National Objective Urgent need, benefit to low to moderate income persons,elimination of slums and blightActivity Amount $105,000,000FEMA provides funds to eligible applicants who must document disaster-related damages. As a costsharing program, FEMA requires that the state certify that local applicants that receive FEMA funds havemet the “local match” requirement. The federal/local cost-share ratio is normally 75% in federal funds 99and 25% in state or local funds. Due to the catastrophic nature of the August 2016 Floods, the local costsharewas decreased to 10%, thus, following the Great Floods of 2016, Louisiana's communities face twodifferent non-federal cost share requirements:DisasterFEMA PublicAssistanceNonfederalShare MatchRequirementDR-4263 (March 2016 Floods) 25%DR-4277 (August 2016 Floods) 10%Proposed Use of Funds: Funds will be provided as payment to state agencies, eligible organizations,local governments or other local entities for eligible activities within approved Project Worksheets(PWs). The state anticipates being able to fund the match requirements for all FEMA PA eligible projects.Duplication of Benefits: The FEMA PA Match program will include a duplication of benefits review as partof the application review and award calculation process.Eligible Applicants: All entities eligible for FEMA PA, under DR-4263 and DR-4277. Eligible applicantsfor FEMA PA include, but are not limited to, the following entities:>> Parish and municipal governments>> State agencies and authorities>> Schools (K-12) and Universities>> First responders>> Critical infrastructure facilities as defined by FEMA (wastewater and drinking facilities)>> Public Housing Authorities>> Other parish and local program applicants eligible to receive federal recovery funds, includingeligible private non-profit organizationsMaximum Award: The maximum award will be the lesser of the cost-share requirement or a pro-ratashare based on available funding.Program Timeline: The State of Louisiana anticipates the launch of the Restore Louisiana FEMA PublicAssistance Non-federal Share Match Program in the second quarter of 2017. The program will end whenall funds are expended, or six years after the execution of the grant agreement with HUD.4. Vulnerable PopulationsOCD-DRU, in coordination with the LHA, has designed a suite of programs that account for the specificneeds of the state's most vulnerable populations, understanding that the funding allocated is notsufficient to serve all households in need of assistance. As is identified in the program descriptions above,the state is prioritizing the provision of funding to those most in need of assistance with its owneroccupiedand rental housing programs.Specifically, the homeowner program will prioritize low-to-moderate income individuals and families,elderly persons, and persons with disabilities. The design of the proposed portfolio of rental programs 100creates affordable units as quickly as possible to provide immediate housing options to individuals andfamilies that are currently homeless or at-risk of homelessness.In addition to the programs proposed in this Action Plan, the state continues to work with its federalpartners to continue to support vulnerable populations who remain displaced from the March and Augustfloods through TSA and Disaster Case Management (DCM). Currently, FEMA has nearly 1,100 displacedhouseholds (comprising over 3,600 individuals) who are receiving TSA. This program, while temporary, isproviding a much needed recovery function for vulnerable populations. The state, in coordination withFEMA, seeks to ensure that all households have a permanent housing plan prior to the exit from TSA. Theprograms proposed in this Action Plan will play a key role the transition.Through DCM, the state works with five on-the-ground partners,such as Catholic Charities of the Diocesesof Baton Rouge, who provide direct case management for over 1,700 households. This crucial casemanagement service for vulnerable populations ensures that they have access to critical resources tofurther their recovery needs. The state understands the gravity of the needs of the most vulnerablepopulations, and continues to work with state, local, and federal partners to provide recovery solutionsand a safety net to this population.Furthermore, the state has requested $92,000,000 in Social Services Block Grant funds to meet the needsof vulnerable populations through Health Delivery System to rebuild the health care needs of itspopulations through child care centers, child abuse prevention, mental health services for children,developmental disability services and mental health services for adults, child welfare services, child careservices, and a call center/hotline designated to connecting residents with appropriate housing resources.B. Leveraging Funds1. HousingTo maximize the impact of the CDBG-DR funding provided to the state, and as part of a continuous effortto prevent duplication of benefits, there will be an ongoing commitment to identify and leverage otherfederal and non-federal funding sources. Further, the state will utilize existing relationships and strive tocreate new partnerships with other federal and state agencies, corporations, foundations, nonprofits andother stakeholders as a means of utilizing all viable sources of funding.CDBG-DR funds will be used to address critical unmet needs that remain following the infusion of fundingfrom other federal sources, including FEMA, NFIP and the SBA. Existing state resources and other fundsfrom the disaster appropriation will also be examined in an effort to ensure that all available funding isutilized where it is most needed.Specifically, the state is working directly with FEMA and GOSHEP to implement the Shelter at HomeProgram, which provides emergency damage remediation for families so they can return home whilerebuilding. To date the program has assisted over 9,400 households. While the Shelter at Home programallows for emergency repairs that are different from the long-term repairs funded through the CDBG-DRprograms, further assistance through CDBG-DR funding will continue to leverage this initial federalinvestment from FEMA. Additionally, the state has committed existing Tenant Based Rental Assistance(TBRA) dollars to meet the immediate needs of renters in the impacted parishes. Existing state resourcesand other funds from the disaster appropriation will also be examined in an effort to ensure that allavailable funding is utilized where it is most needed.Furthermore, the state has designed all of the housing programs in this action plan to cover the gapfunding needed by leveraging insurance, private funds, and other assistance to complete the repairs from 101the 2016 Floods. Understanding the limited funding for recovery, the state will encourage all applicantsto seek out all other funding sources to meet their full recovery needs.2. Economic DevelopmentThe state will combine funding to address economic development unmet needs from other federalfunding sources such as SBA loans, NFIP, non-disaster CDBG funding, the U.S. Department of Agriculture(USDA), and the U.S. Department of Commerce. Non-federal resources such as local and state economicdevelopment public funds, as well as private financing and equity investments, will provide additionalleverage to disaster recovery funds.3. InfrastructureThe state will combine funding to address infrastructure unmet needs from other federal funding sourcessuch as non-disaster CDBG funding, USDA, and FEMA PA. Additional non-federal resources such as localand state public funds will provide additional leverage to these disaster recovery funds.4. MitigationThe state is committed to a multi-pronged approach to addressing mitigation needs community wide. Thestate will leverage FEMA HMGP funds to implement large scale mitigation projects, which providemitigation measures at the parcel level, yet impact a community as a whole. Leveraging mitigation dollarswill allow for the state to invest in resilient infrastructure to rebuild impacted areas to standards that willreduce impacts from future flooding events. For example, the State may consider combining CDBG-DRfunds to leverage HMGP funds used for strategic buyouts in a floodplain. Further details on mitigationprojects will be outlined in future action plans.5. Other Sources of FundsAs part of the state's ongoing recovery efforts, OCD-DRU leverages CDBG-DR funds with the followingsources of funds which may include but is not limited to:>> Low-Income Housing Tax Credit Programs;>> HOME Program;>> Medicaid Funded Provision of Medical Services;>> FEMA PA;>> New Market Tax Credit Programs;>> Historic Tax Credit Programs;>> Live Performance Tax Credits Programs;>> HUD 242 Loan Program;>> Private Resources (Developers/Non-Profit Organizations/Homeowners/Landlords);>> Other federal programs and resources; and>> State Capital Outlay Program.C. Contractor Standards and Appeals ProcessRecovery programs implemented by the State of Louisiana will incorporate uniform best practices ofconstruction standards for all construction contractors performing work in all relevant jurisdictions.Construction contractors will be required to carry required licenses, insurance coverage(s) for all workperformed, and state-contracted contractors will be required to provide a warranty period for all workperformed. Contractor standards will be enumerated for each program (e.g. homeowners and rentalproperty owners) in respective policies and procedures documents, and will pertain to the scale and typeof work being performed. The state will implement an appeals process for homeowners, rental propertyowners and small business owners related to program eligibility and program application process. In 102addition, the state will implement an appeals process for the Restore Louisiana state managedhomeowner program to allow for appeals of rehabilitation contractor work that is not in keeping withestablished contractor standards and workmanship detailed in relevant policies and procedures manualsgoverning the respective program. In the state managed homeowner program, the homeowners willmake an appeal to the state or its designated vendor to contest the work completed by the statecontractedhomebuilding contractor. Details of the point of contact and procedure for submitting theappeal will be detailed in the program policies and procedures. In the homeowner managed program, thehomeowner will resolve conflicts with the homebuilding contractor directly, as the state is not a party tothe contract between the homeowner and the homebuilding contractor.The State of Louisiana intends to promote high quality, durable and energy efficient construction methodsin affected parishes. All newly constructed buildings must meet all locally adopted building codes,standards and ordinances. In the absence of locally adopted and enforced building codes that are morerestrictive than the state building code the requirements of the State Building Code will apply. Futureproperty damage will be minimized by incorporating resilience standards through requiring that anyrebuilding be done according to the best available science for that area with respect to base floodelevations.D. Planning and CoordinationThe State of Louisiana has historically experienced flooding, coastal land loss, subsidence and wetlanddegradation with a significant portion of the southern half of the state below sea level, and the constantthreat of tropical storms and hurricanes. Since the flooding and damage associated with hurricanesKatrina and Rita in 2005, followed by hurricanes Gustav and Ike in 2008 and Hurricane Isaac in 2012, thestate has been proactive in undertaking measures that address resiliency and sustainability, as well aseducating the public so that future risk for communities and individuals is minimized. Louisiana articulatedits vision for a recovery that is “Safer, Stronger and Smarter” translated into the following actions:>> Oversight for ensuring impacted parishes developed Long Term Recovery Plans as required underFEMA's ESF-14 in 2006;>> State adoption of the National Building Code Standards in 2006;>> Proactively ensuring parish adoption of the Advisory Base Flood Elevations (ABFEs) withconcurrent adjustments in permits issued for new construction and height or elevationrequirements issued after the respective adoptions;>> Funding of “Louisiana Speaks” – a major regional initiative for all of south Louisiana reflectingvisions and strategies for resiliency and sustainable growth practices (May 2007). More than27,000 citizens, a historical first in the United States, participated in developing the plan. The 94-page document in hardcopy and disc and two subsequent publications: “Louisiana Speaks:Planning Toolkit” and “Louisiana Speaks: Pattern Book” were widely distributed to planners,government entities, local nonprofits and associations and citizens; and>> The Coastal Protection Restoration Authority (CPRA) funded by the Louisiana Legislature todevelop a 2017 Coastal Master Plan (CMP) with specific projects within each parish designed forprotection of the coast and communities. CPRA collaborates extensively with a wide range ofother federal, state and local agencies, has developed an interdisciplinary planning process thatengages diverse groups of coastal stakeholders, focus groups, and national and international 103experts in order to capture the wide range of perspectives and expertise necessary in developinga holistic coastal planning effort for the 2017 CMP. Under the CPRA effort, numerous supportingteams have been formed, which include:o Framework Development Team (FDT) which serves as the primary cross-disciplinarycollaborative group, consists of representatives from federal, state and localgovernments; NGOs; business and industry; academia; and coastal communities.o Science and Engineering Board (SEB) which includes scientists and engineers with nationalor international experience who cover the range of disciplines, including socio-economics,coastal modeling, water and natural resources, urban planning, wetlands, fisheries,coastal geoscience, economic policy, and risk reductiono Resiliency Technical Advisory Committee (TAC) is a small cross-disciplinary advisory groupthat offers working-level guidance and recommendations on the programmatic and policymeasures needed to implement a comprehensive flood risk and resilience program. TheTAC comprises experts in the areas of climate adaptation planning, community planning,socio-economics, social vulnerability, hazard mitigation, disaster planning, andenvironmental policy.Because OCD-DRU has administered CDBG-DR disaster recovery funds since 2006, mechanisms are inplace to serve as guidelines for not only CDBG compliance, but also comprehensive planning andprioritization of projects for the short-term and long-term recovery of communities. These mechanismsinclude:>> The state's template for the development of a disaster recovery proposal to use CDBG-DR fundsat the parish level is being adapted to incorporate assurances that projects will reflect “unmetneeds” as established in the state's Action Plan, as well as take into consideration and reflect:o The Flood Recovery Strategy emanating from the NDRF;o Local ABFEs and Flood Insurance Rate Maps (FIRMs);o The parish Hazard Mitigation Plan required by GOSHEP;o The parish's Long Term Recovery Plan (ESF-14);o An assessment of local land use plans, zoning and floodplain management ordinancespermit requirements;o The Master Plan of the CPRA (where applicable); ando Regional coordination with the respective regional planning commission.This action will enable the leveraging of CDBG-DR funds with other funding sources and alreadyidentified priorities for sustainability and resiliency;>> The state has guidelines on elevation and costs for specific types of housing and encouragescoordination of CDBG-DR funding with FEMA's HMGP; and>> The Pilot Comprehensive Resiliency Program, implemented in 2010 under funding fromhurricanes Gustav and Ike, is a proactive program to develop and facilitate local planning thatincorporates sustainability and resiliency into land use plans, zoning and floodplain management.The program funds were made available to local governments and non-profit entities in parishesimpacted by hurricanes Gustav and Ike through a competitive application process. Twenty-ninecommunities were awarded grants through the competitive program. These projects include 104water management, floodplain ordinances, comprehensive plans, zoning codes and a plan forwetland carbon. In addition, 17 building code inspectors are funded for a two-year period in 10communities to assist with enforcement and adaptation of permit policies and fees to allow forthose communities to ultimately sustain the effort to manage growth, compliance and blight.The education component of the Resiliency Program, through a joint venture with the LSU CoastalSustainable Studio, has established a permanent online library, reflecting the plans developed throughthe Resiliency Program, criteria for determining sustainability and resiliency at the local level andeducational tools. The OCD-DRU and LSU initiative includes a series of statewide webinars and workshopsthat provide national perspectives through recognized experts and local tools and strategies forimplementation. Topics to date have included: “Gaining Economic Advantage through Environmental andHazard Mitigation”, “Social Resilience: Bridging Planning and Communication through Technology” and“Retrofitting for Resiliency”. The Forum, “NFIP: Preparing for Changes to Flood Insurance” that was heldJune 17, 2013 was designed to help parishes and municipalities develop community-scale strategies thatreduce flood risk and increase their scores on the Community Rating System. All webinars and workshopsare available on the Louisiana Resiliency Assistance Program website at http://resiliency.lsu.edu/.Outreach for these sessions are statewide to elected officials, disaster recovery subrecipients, floodplainmanagers, planners, etc. Distribution is both by LSU, OCD-DRU and through partners such as the LouisianaMunicipal Association, the Louisiana Chapter of the American Planning Association, the FloodplainManagement Association and others. Therefore, in preparation of this Action Plan, the state has ensuredthat this document does not conflict with any existing regional recovery plans. The state will continue tocoordinate with regional and local governments to ensure that all recovery efforts are aligned.6. Citizen ParticipationA. Citizen Participation PlanThe State of Louisiana developed a specific Citizen Participation Plan for disaster recovery from the 2016Severe Storms and Flooding in compliance with CDBG regulations and all applicable waivers. The planincludes citizen participation requirements both for the state and also the parishes or other entities thatwill implement activities under this grant. The State's full Citizen Participation Plan is Appendix B of thisdocument.Citizens and other stakeholders will be given an opportunity for reasonable and timely access toinformation and a period for submitting comments relating to this Disaster Recovery Action Plan and anyensuing substantial amendments. Publication of the Action Plan, public comment, and substantialamendment criteria is located on the OCD-DRU website.The state is committed to providing access to the Action Plan and programs detailed within to all itscitizens. These efforts include special consideration for those with limited English proficiency (LEP) andpersons with disabilities. The Action Plan and substantial amendments will be translated into Spanish andVietnamese to reach the LEP population in the impacted areas. Citizens with disabilities or those whoneed technical assistance can contact the OCD-DRU office for assistance, either via:>> Telephone, voice 225-219-9600 or LA Relay Service 711;>> Email at firstname.lastname@example.org; or>> Mail to the Office of Community Development, Disaster Recovery Unit,Post Office Box 94095, Baton Rouge, LA, 70804-9095. 105The OCD-DRU website (http://www.doa.la.gov/Pages/ocd-dru/Index.aspx) will contain direct links to theAction Plan, amendments, reports and recovery programs and will be updated to provide additionalinformation.1. Citizen InputThe state has been in ongoing communications with its residents, local government leaders, statelegislators and other stakeholders in communities impacted from both the March and August floodingevents. This continuous outreach has helped identify the needs and priorities of the impactedcommunities and informs the programs set forth in this Action Plan.OCD-DRU personnel have provided ongoing support within the parishes since the flooding events. Stateofficials have held frequent calls and meetings with these and other impacted communities to discuss,among other things, the storms' effects on the local housing stock, infrastructure and businesscommunities. These meetings have included seven public meetings held across the state as part of itsCitizen Participation outreach associated with the first allocation of funds, as well as six public meetingsof the Recover Louisiana Task Force.2. Louisiana Disaster Housing Task ForceFEMA's NDRF is a guide that enables effective recovery support to disaster-impacted states, tribes,territorial and local jurisdictions. It provides a flexible structure that enables disaster recovery managersto operate in a unified and collaborative manner. It also focuses on how best to restore, redevelop andrevitalize the health, social, economic, natural and environmental fabric of the community and build amore resilient Nation. As part of Louisiana's framework, the Disaster Housing Task force was created andimplemented following Hurricane Isaac. Immediately following the March floods, the Louisiana DisasterHousing Task Force (Task Force) was activated and remained in effect throughout the August floodingevent. The Task Force includes: state personnel from OCD-DRU, GOHSEP, the LHC and the stateDepartment of Children and Family Services (DCFS); representatives from HUD and FEMA; and membersfrom the local Voluntary Organizations Active in Disaster (VOAD).The Task Force has played an essential role in maintaining contact with the leaders of the impactedparishes, assessing needs on the local level and providing data as needed. The state's outreach efforts willcontinue throughout the duration of the program planning and recovery process, in accordance with theCitizen Participation Plan.3. Restore Louisiana Task ForceIn response to the flooding events in March and August, Governor John Bel Edwards enacted the RestoreLouisiana Task Force (RLTF), charged with overseeing the state's recovery efforts from flooding events in2016. The RLTF comprises key stakeholders from the public and private sectors who represent the entirestate, including impacted parishes. Their roles as elected officials or advisory roles in the communityposition them to provide strategic direction to create policy and advise the governor and OCD-DRU staffin the aftermath of the 2016 Severe Storms and Flooding.Furthermore, the RTLF establishes and recommends to state and local agencies both short and long-termpriorities in developing plans for recovery and redevelopment. These priorities and plans focus on thefollowing areas: housing rehabilitation and redevelopment; economic and workforce development;education, infrastructure and transportation; healthcare; fiscal stability; family services; and agriculture. 106Additionally, the RLTF coordinates with GOSHEP, OCD-DRU, and the affected parishes and municipalitiesto assist in collecting and analyzing data about the ongoing residential, business and public infrastructureneeds for recovery, identifying additional sources of federal funding, and sets priorities and offersdirection to OCD-DRU and GOHSEP related to the use of funds made available through the Robert T.Stafford Disaster Relief and Emergency Assistance Act and any additional available federal funds.The state's template for the development of a disaster recovery proposal to utilize CDBG-DR funds hasbeen adapted to incorporate the NDRF process. As a function of the Restore Louisiana Task Force, TaskForce members engage in smaller working group sessions to deliberate and recommend programstrategies related to particular recovery areas. These working groups have been structured to mirror theRecovery Support Functions (RSF) outlined in the NDRF: Community Planning and Capacity Building;Economic Recovery; Health and Social Services; Housing; Infrastructure Systems; and Natural and CulturalResources. Each working group has been assigned an OCD-DRU staff member responsible for ensuringthat local, state and federal members of the RSFs are invited and encouraged to participate in each of theRLTF working group sessions. By combining these functions, the state has been able to draw upon andincorporate the expertise, strategies and perspectives from local, state and federal stakeholders in theinitial and ongoing programs design process.The RLTF also establishes a federal and state legislative agenda for the recovery and redevelopment effortand for coordinating between levels and branches of government to implement that agenda. The RLTFcomprises 21 voting members representing the impacted parishes and communities of Louisiana.4. Consultation with Units of Local Government, Tribes and StakeholdersWith 56 parishes impacted by the 2016 Severe Storms and Flooding, the state has continued ongoingdialogue and consultation with all Units of Local Governments (UGLGs), stakeholders and tribes duringand after the direct impacts of the disasters. OCD-DRU's outreach team provides daily support to many ofthe impacted parishes and has conducted technical assistance and assessment meetings with impactedparishes. Additionally, OCD-DRU staff has consulted with representatives from local chambers ofcommerce, financial institutions, non-profit organizations and community development financialinstitutions to seek input on the experiences of residents and businesses following the storms. Input fromthese stakeholders hasinformed the initial program design and ongoing consultation will incorporate bestpractices and local knowledge into the development of program policies and procedures.For specific consultation on Action Plan development, the state worked with both the Louisiana MunicipalAssociation (LMA) and the Louisiana Police Jury Association to conduct webinars to provide a platform forUGLGs, non-entitlement, entitlement communities to provide input and consultation. Additionally,through the RSF 1 – Community and Capacity Building (RSF 1) of the Task Force, OCD-DRU staff incoordination with FEMA and GOHSEP have conducted numerous meetings with UGLGs to advise andassess ongoing recovery needs.In conjunction with the NDRF, the state hosted the Louisiana Symposium on Recovery and Resilience onDecember 8, 2016, which provided impacted parishes and municipalities with an opportunity to learnabout and share best practices. The one-day event included 184 participants representing 18 floodimpactedparishes. The Symposium provided the following to attendees:>> The opportunity to hear from and dialogue with peers and subject matter experts with experiencein addressing recovery issues and resilience in Louisiana and other parts of the nation.>> Information about regional and state watershed management within Louisiana with anopportunity for a targeted discussion on implementation going forward. 107>> Specifics on how the State of Louisiana's approach to responding to the needs created by thefloods.The symposium included seven breakout sessions, including panels and feedback on risk reduction,resilient implementation, and long term community planning and recovery. The event will be followedup by other statewide training opportunities and targeted workshops in individual communities asneeded.The RSF 1 Planning and Capacity Committee is developing a Community Long-Term Planning Processspecifically for Louisiana, building off of the state's Stronger Communities Together process, which hasbeen successful in 32 communities across the state. All six RSF's are participating in the development ofthe template and will participate in the implementation to be provided to the ten most impactedcommunities. GOHSEP, FEMA, and OCD-DRU will collaborate to provide oversight of the project. Theprocess is being modified to include: (1) guidance on how to set up a local planning advisory groupconsisting of a diverse set of key stakeholders who will champion and follow-up on implementation; (2)guidance on the public process of getting residents educated and involved in all aspects of thedevelopment of the plan so that they are knowledgeable and supportive of decisions going forward; (3)redesigning the elements to be addressed to reflect the six RSF's as the core – planning/capacity,infrastructure, housing, economic development, health and social resources, natural and culturalresources, and a resilience and hazard mitigation component; and (4) guidance on resilience and hazardmitigation criteria for any projects identified and prioritized so that they are designed to reduce risk. Thecriteria mirror what has been developed for the LA SAFE initiative to ensure coordinated efforts andcommon messaging within local communities and across the state as a whole.Timeline for a statewide training kickoff is April 2017 with a goal for all communities impacted by 4277and 4263 to have a resiliency/recovery strategy within six months. Targeted follow-up and support willbe provided to the ten most impacted communities throughout the process to ensure this effort isexpedited and done as models for other communities within the state and as a template for the NDRFnationally. Support includes on the ground staff support, review of existing hazardmitigation/comprehensive land use plans, education on mitigation/resiliency strategies and bestpractices, tracking community input, etc.Combined outreach efforts between GOSHEP, FEMA and OCD-DRU have already been conducted toconduct preliminary capacity assessments and get buy-in from local leadership and stakeholders for theCommunity Long Term Planning Process.Through the Governor's Office of Indian Affairs, the state conducted outreach to the ten state recognizedtribes after both the March and August flooding events. Two of the ten tribes are located within theimpacted parishes, and the state is committed to working with these tribes to ensure that the recoveryneeds are being addressed.Additionally, the Governor's Office of Indian Affairs has completed outreach to the four federallyrecognized tribes and continues to assess impacts and needs of the tribes to ensure recovery needs arebeing addressed at the state and federal level.Because of the widespread impact of the flooding events, the state is committed to ongoing consultationthrough regional public meetings, the RLTF, meetings with UGLGs and tribes in impacted parishes andwith the public to ensure the continuation of robust consultation efforts with these key groups throughoutthe recovery process. 108B. Citizen ComplaintsThe state and its subrecipients have established procedures for responding to citizens' complaintsregarding activities carried out utilizing these CDBG-DR funds. The Citizen Participation Plan provides fulldetails. Citizens will be provided with an appropriate address, telephone number and times during whichthey may submit such complaints. The state and subrecipients will provide a written response to eachcomplaint within 15 days of receiving a complaint, as practicable.C. Receipt of CommentsThis Action Plan was posted for public comment on February 1, 2017. The plan was posted online inEnglish, Spanish, and Vietnamese. Public notices were published in eight newspapers, including TheAdvocate, the state's journal of record, and a press release was also distributed.D. Amendments to the Disaster Recovery Action Plan1. Substantial AmendmentsPer 81 FR 83254,substantial amendments are defined by a change in program benefit or eligibility criteria;the addition or deletion of an activity; or the allocation or reallocation of a monetary threshold specifiedby the grantee. For purposes of this allocation of funding, the state will define the threshold for asubstantial amendment as the greater of a re-allocation of more than $5 million dollars or a reallocationwhich constitutes a change of 15 percent or greater of a program budget.Only those amendments that meet the definition of a substantial amendment are subject to the citizenparticipation process.2. Submittal of AmendmentsA substantial amendment to the Action Plan will follow the same procedures for publication as the originalAction Plan in accordance with the Citizen Participation Plan. All amendments, both substantial and nonsubstantial,will be posted on the OCD-DRU website in sequential order after HUD has given final approval.Action Plan Amendments will also be incorporated into the Original Action Plan.