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I. Waiver and Alternative Requirement for HUD Review of Action Plans for Disaster Recovery and Action Plan Amendments Related to Funding Appropriated by Public Laws 115–123 and 115–56.
Public Law 115–123 1 appropriated $28 billion of Community Development Block Grant disaster recovery (CDBG–DR) funding for two purposes: (1) To address unmet needs arising from certain major declared disasters that occurred in 2017; and (2) To fund mitigation activities for all CDBG–DR grantees that received CDBG–DR funding in response to unmet needs arising from major disasters declared in 2015, 2016, and 2017. These funds were in addition to $7.4 billion appropriated by Public Law 115–56 2 for unmet needs arising from major declared disasters in 2017. HUD allocated virtually all funding for unmet needs 3 and established administrative requirements via two Federal Register Notices published on February 9, 2018 (83 FR 5844–5869) and August 14, 2018 (83 FR 40314–40325).
In general, the funds are to be used for activities authorized under Title I of the Housing and Community Development Act of 1974 (42 U.S.C. 5301 et seq.) (HCD Act) related to disaster relief, long-term recovery, restoration of infrastructure and housing and economic revitalization in the "most impacted and distressed" areas defined by HUD. By providing the supplemental disaster recovery funding under Title I of the HCD Act, Congress implicates the general statutory and regulatory requirements of the Community Development Block Grant (CDBG) program.
Both Public Law 115–123 and 115–56 include the following proviso with respect to CDBG–DR funding:
Provided further, That prior to the obligation of funds a grantee shall submit a plan to the Secretary for approval detailing the proposed use of all funds, . . . :
HUD's Federal Register Notice of February 9, 2018, establishes the requirements and criteria that inform these plans and substantial amendments thereto (see section VI., A.2., Action Plan for Disaster Recovery waiver and alternative requirement (83 FR 5849)). Section VI., A.2.(e) is entitled Review and Approval of Action Plan and states that "HUD will review each action plan within 45 days from the date or receipt." The above referenced requirements are also generally applicable to CDBG–DR funds allocated by the August 14, 2018, Notice, via Section II., "Use of Funds."
For CDBG–DR funds appropriated by Public Laws 115–123 and 115–56, HUD currently has three Action Plan Amendments (State of Florida, the Commonwealth of Puerto Rico and the United States Virgin Islands (USVI)) pending review and approval involving an aggregate of $9.3 billion. In addition, there are Action Plans from the states of California, Georgia and Missouri pending review and approval for an aggregate of $221 million.
Public Laws 115–123 and 115–56 also include the following proviso:
Provided further, That in administering the funds under this heading, the Secretary of Housing and Urban Development may waive, or specify alternative requirements for, any provision of any statute or regulation that the Secretary administers in connection with the obligation by the Secretary or the use by the recipient of these funds (except for requirements related to fair housing, nondiscrimination, labor standards, and the environment), if the Secretary finds that good cause exists for the waiver or alternative requirement and such waiver or alternative requirement would not be inconsistent with the overall purpose of title I of the Housing and Community Development Act of 1974:
This proviso enables HUD to waive various statutory requirements applicable to CDBG and to establish alternative requirements to those provisions. In this Notice, HUD is applying this authority to extend the period available for HUD review of pending Action Plan Amendments and Action Plans involving CDBG–DR funding under Public Laws 115–123 and 115–56.
Due to the lapse of FY 2019 appropriations for HUD as of December 21, 2018, HUD has already issued a regulatory waiver extending the HUD review period for the Action Plan Amendments submitted by Florida, Puerto Rico and the USVI from 45 days to 60 days, which is the period set forth under the applicable statutory provision (42 U.S.C. 12705(c)(1)) for consideration of housing strategy, which is analogous to an action plan or action plan amendment. HUD has not yet addressed the status of the pending Action Plans for California, Georgia and Missouri as the 45-day review period for these submissions occurs in late January, 2019. However, HUD cannot be assured of completing the reviews of these pending submissions and issuing affirmative approvals as required by Public Laws 115–123 and 115–56 given the impact upon HUD's operations during the appropriations lapse period. Therefore, the Secretary finds that there is good cause to waive the statutory sixty (60) day review deadline established by 42 U.S.C. 12705(c)(1) and is issuing an alternative requirement for review of pending Action Plan Amendments and Action Plans involving funding under Public Laws 115–123 and 115–56. HUD will review the pending Action Plan Amendments and Action Plans and provide affected grantees with a decision within a time period which will be announced by HUD after enactment of funding for the Department's normal operations.
Failure to extend the review period could lead to deemed approvals upon expiration of the customary 60-day review period, an outcome that would be inconsistent with both HUD's oversight responsibilities and the purposes of the CDBG–DR funding or, alternatively, disapproval. Grantees with pending submissions are advised that the extension of HUD's review period and resulting delays should not be considered a commentary on the submissions but is a recognition of the current circumstances.
Date: 4-20-2019 Updated: 4-20-2019 Subject:
From: Erin Monroe Wesley
Sent: Monday, September 19, 2016 9:58 AM
To: email@example.com Don Pierson firstname.lastname@example.org email@example.com firstname.lastname@example.org
email@example.com Johnny Bradberry firstname.lastname@example.org email@example.com
firstname.lastname@example.org email@example.com firstname.lastname@example.org email@example.com
firstname.lastname@example.org email@example.com firstname.lastname@example.org
email@example.com firstname.lastname@example.org email@example.com firstname.lastname@example.org
email@example.com Jacqui Vines firstname.lastname@example.org
Cc: Pat Forbes Rowdy Gaudet Lori Dupont Erin Monroe WesleySubject: Restore Louisiana Task Force
Good Morning -
Thank you for agreeing to serve on the Governor's Restore Louisiana Task Force, which is charged with establishing short and long-term priorities in developing plans for recovery and redevelopment throughout the state of Louisiana as a result of the March and August flooding events. Our first meeting of the task force will be held on Wednesday, September 28, 2016, 9:30 a.m. - 11:30 a.m., in House Committee Room 5 at the Louisiana State Capitol. Please let us know if you are able to attend by responding to Lori Dupont, copied here, at Lori.Dupont@la.gov. I have attached the following documents for your review and records in preparation for our first meeting:
We would like to engage the members of the task force as early as this week in our meetings with HUD, FEMA, and GOHSEP this Friday, September 23rd . Please let us know if you would like to join us for these meetings this week.
Restore Louisiana Task Force Membership
Restore Louisiana Task Force Staff Support
Additional staffers to be identified.
We look forward to working with each of you in our state's recovery efforts.
Erin Monroe Wesley
Special Counsel (Policy Director/Legislative Affairs)
Date: 7-13-2019 Updated: 7-13-2019 Subject: State Directors
For Disaster Related and Preparation visit your OHSEP website linked here:
Date: 7-9-2019 Updated: 7-9-2019 Subject: OHSEP
You are receiving this notification because you have not closed on your grant award offered by Restore Louisiana.
Please note that you MUST execute your grant agreement by Wednesday, July 31, 2019 or the grant offered will be rescinded and you will no longer be able to participate in the Restore Louisiana Homeowner Assistance Program.
Please reach out to your assigned Case Manager as soon as possible to schedule your closing:
Case Manager Name: [SNIP]
Case Manager Email: [SNIP]
Case Manager Phone: [SNIP]
The Restore Louisiana Homeowner Assistance Program
Editors note: Case Workers appear to be titled Case Managers which would match the states policy that any manager can find a homeowner not cooperative and rescind their grant award and drop them from the program. This information was publish in Feb. 2019 and offered by the lead legal adviser for the state of Louisiana OCD-DRU.
Date: 7-9-2019 Updated: 7-9-2019 Subject: State Contractors
Documents from Housing and Urban Development Department
Housing and Urban Development Department
Applicability of Updates to Duplication of Benefits Requirements under the Stafford Act for Community Development Block Grant Disaster Recovery Grantees
Abstract: Elsewhere in the Federal Register, the Department published the notice ' Updates to Duplication of Benefits Requirements Under the Stafford Act for Community Development Block Grant (CDBG) Disaster Recovery Grantees,' which reflects the requirements of recent CDBG disaster recovery (CDBG-DR) supplemental appropriations acts and amendments to the Robert T. Stafford Disaster Relief and Emergency Assistance Act. This notice makes conforming amendments to notices governing CDBG-DR grants...
Updates to Duplication of Benefits Requirements Under the Stafford Act for Community Development Block Grant Disaster Recovery Grantees
Abstract: This notice describes the requirements to prevent duplication of benefits applicable to Community Development Block Grant disaster recovery (CDBG-DR) grants received in response to a disaster declared between 2015 and 2021. It updates existing duplication of benefits requirements to reflect recent CDBG-DR supplemental appropriations acts and amendments to the Robert T. Stafford Disaster Relief and Emergency Assistance Act impacting certain grantees. The notice also includes minor...
Date: 6-20-2019 Updated: 6-20-2019 Subject: CDBG-DR
State of Louisiana HUD CDBG-DR AMI (%) Percentage.
Need more information? Here's your jump board.
If your AMI changed from below 80% to over 80% and under 120% you can appeal that your increase has not be for two consecutive years. Over 120% AMI you can argue the on the same grounds if your increase has not been for 2 consecutive years. (Based on light Sunday reading)
Those of you that are over HUD's income limits (120%) and would like to understand more about how HUD determines over income limits this link is for you.
Resource link: FR-2018-07-26
Very Low Income * 2.4 = 120% AMI.
Very Low Income is 50% AMI.
Example: State wide VLI family of 2 = $24,850
$24,850 * 2.4 = $59,640 120% or HUD Income Limit.
So be sure the state doesn't use the math I just showed you. Some areas are much higher while others are lower. The state really likes to put everyone in one box, so look out for a spreadsheet with the above calculations in VLI for your areas.
Example: Louisiana State Wide 120% AMI.
Date: 6-16-2019 Updated: 6-16-2019 Subject: AMI
34. Rental assistance to displaced homeowners. The requirement of 42 U.S.C. 5305(a)(8) are modified to authorize grantees to extend rental assistance payments on behalf of qualified homeowners for up to 24 months. After a disaster, many homeowners encounter unanticipated delays and scarcity of available construction and/or elevation contractors in their area. While undergoing rehabilitation of their homes, most of these homeowners are forced to pay not only a mortgage, but a rental payment as well since their homes are not inhabitable. In other cases, homeowners who have paid off their mortgages must accommodate this additional rental expense into their budgets. In order to provide temporary financial assistance to these families, many of whom are low- or moderateincome households, HUD is modifying the requirements at 42 U.S.C. 5305(a)(8) to the extent necessary to allow grantees to provide up to 24 months of homeowner rental assistance to eligible applicants within the grantee's singlefamily rehabilitation/reconstruction programs. In the case of rehabilitation programs in which the homeowner is responsible for construction oversight, the grantee must establish performance milestones for the rehabilitation that are to be met by the homeowner in order to receive such payments. A grantee using this alternative requirement must document, in its policies and procedures, how it will determine the amount of assistance to be provided is necessary and reasonable. Homeowners receiving interim mortgage assistance are not eligible for rental assistance.
Date: 6-15-2019 Updated: 6-15-2019 Subject: Allocations
33. Limitation on emergency grant payments - interim mortgage assistance. 42 U.S.C. 5305(a)(8) is modified to extend interim mortgage assistance to qualified individuals from 3 months to up to 20 months. Interim mortgage assistance is typically used in conjunction with a buyout program, or the rehabilitation or reconstruction of single-family housing, during which mortgage payments may be due but the home is uninhabitable. The time required for a household to complete the rebuilding process may often extend beyond 3 months, during which mortgage payments may be due but the home is inhabitable. Thus, this interim assistance will be critical for many households facing financial hardship during this period. Grantees may use interim housing rehabilitation payments to expedite recovery assistance to homeowners, but must establish performance milestones for the rehabilitation that are to be met by the homeowner in order to receive such payments. A grantee using this alternative requirement must document, in its policies and procedures, how it will determine the amount of assistance to be provided is necessary and reasonable.
Date: 6-15-2019 Updated: 6-15-2019 Subject: Allocations
You are receiving this notification because you have not closed on your grant award offered by Restore Louisiana.
Please note that you MUST execute your grant agreement by Wednesday, July 31, 2019 or the grant offered will be rescinded and you will no longer be able to participate in the Restore Louisiana Homeowner Assistance Program. "
According to reports filed for April and May the state of Louisiana Office of Community Development Disaster Recovery Unit working under the name of Restore Louisiana Homeowners Program has increased it's speed of processing grant awards by increasing the number of rescinded grants offered to homeowners.
April of 2019, 30 homeowners have had their HUD CDBG-DR grant awards rescinded by the state for state created policy reasons.
May of 2019 278 homeowners have had their HUD CDBG-DR grant awards rescinded by the state for state created policy reasons.
The state of Louisiana's timing will match the 3rd year since the flood and fall on or close to the anniversary date of the August 12th 2016 floods.
It appears the state has not formally offered homeowners with alternatives to their recovery. With over 2,000 homeowners at risk of losing everything from the flood to include all additional grant funds for unmet needs the state will face additional homelessness and blight as a result of meeting goals and deadline.
HUD officially allows the state to run the distribution of funds up and to the Sept. 2022. The state of Louisiana OCD-DRU has announced several times the closing dates of programs in 2018 and continues by rewording the closing of programs to the rescinding of grant awards.
"Elsewhere, this notice describes the extension of the expenditure deadline that the Department is authorized to provide to all CDBG-NDR (NDR = National Disaster Resilience) grantees, allowing them to expend funds until September 30, 2022. "
Grantee Name: Louisiana
Grant Number: B-16-DL-22_0001
Grant Award: $1,708,407,000
Average of March, April, May Spending: $23,334,110
Grantee Spending Status: On Pace
NOTE: On Pace = Spending greater than the monthly pace required to fully use the grant by target closeout date.
Public Laws 114-223, 114-254 and 115-31.
Public Laws 114-223 (Approved September 29, 2016)
Public Laws 114-254 (Approved December 10, 2016)
Public Laws 115-31 (Approved May 5, 2017):
Waivers and Alternative Requirements for CDBG-DR Funds Appropriated by Public Law 114-223, 114-254 and 115-31 (Applicable only to the State of Louisiana)
Pursuant to the Prior Notice, each grantee is required to expend 100 percent of its allocation of CDBG-DR funds on eligible activities within 6 years of HUD's execution of the grant agreement.
Date: 6-13-2019 Updated: 6-13-2019 Subject: State Contractors
Do you have copies of the discussions and first drafts?
"WHEREAS, Louisiana has invested and is continuing to invest significant resources toward creating organizations such as The Water Institute of the Gulf and university centers that build the state's strength as a unique, global leader in water management; and
Have you participated with the collection of data related to Mississippi River Basin Wide Modeling in the past decade with a group called "The Water Institute of the Gulf?"
Several Not For Profits, For Profits, and University Science Research groups may have been purposely excluded from grant awards published in Public Law 115-123.
Editors Note: Has the state of Louisiana and it's capital region taken economic development over collaborated scientific research between Not for Profits, Universities and For Profit organizations?
Modeling software developed by one university may share the same data as another and provides slightly different results. Modeling software such as Hurricane Tracking software often produces different results. They may be similar but no two data calculating applications seem to produce the same results. Many factors are included but are not important for this report. What is important is knowing that non technical, non science community individuals have lobbied for specific modeling software provided by a group that is located in a part of the state of Louisiana that is only interested in economic growth from the grant awards related to Public Law 115-123.
Date: 6-13-2019 Updated: 6-13-2019 Subject: Watershed
Let's first start off with some resources to bring you up to speed.
Then, in a article we'll share what one homeowner is doing in the southern state of Louisiana to fight against rusty ducts, dirt, moisture in the air and just plan cool sticky inside the home. Enough, we're not from the stone age, let's work the science of building.
Resources to read:
Date: 6-9-2019 Updated: 6-9-2019 Subject: Construction
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Deconstruction, is taking the house apart without damaging the components of the house. Only the slab foundation will...