HUD Archives: FY 1998 SuperNOFA 1: Comprehensive Improvement Assistance Program (CIAP)

FY 1998 SuperNOFA 1

Comprehensive Improvement Assistance Program (CIAP)

PROGRAM DESCRIPTION: Approximately $304,000,000 is available in funding for the Comprehensive Improvement Assistance Program (CIAP). The CIAP provides modernization funds to housing authorities (HAs) that own or operate less than 250 units of public housing, to enable them to improve the physical condition and upgrade the management and operations of existing public housing developments to assure their continued availability for low-income families.

APPLICATION DUE DATE: The CIAP Application is due on or before 6:00 p.m., local time on June 29, 1998. An original CIAP Application and two copies must be received at the HUD Field Office with jurisdiction over the HA, Attention: Director, Office of Public Housing (OPH). See theGeneral Section of this SuperNOFA for specific procedures governing the form of application submission (e.g., mailed applications, express mail, overnight delivery, or hand carried).

Emergency Modernization Applications. The HA may submit a CIAP Application for Emergency Modernization whenever needed. See Sections III(A)(3)(a) and III(A)(9) of this CIAP section of the SuperNOFA.

ADDRESS FOR SUBMITTING APPLICATIONS: CIAP applications must be delivered by the application due date to the HUD Field Office with jurisdiction over the HA, Attention: Director, Office of Public Housing (OPH).

FOR APPLICATION KITS, FURTHER INFORMATION, AND TECHNICAL ASSISTANCE:

For Application Kits. A CIAP Application Kit will automatically be transmitted under separate cover to every eligible HA to supplement the policies and procedures set forth in this CIAP section of the SuperNOFA. The application kit will include copies of forms needed for application submission. Application kits and any supplementary information also may be obtained by contacting the SuperNOFA Information Center at 1-800-HUD-8929. Persons with hearing or speech impairments may call the Center's TTY number at 1-800-483-2209. The application kit also will be available on the Internet through the HUD web site at http://www.HUD.gov. When requesting an application kit, please refer to CIAP and provide your name, address (including zip code), and telephone number (including area code).

For Further Information and Technical Assistance. William J. Flood, Director, Office of Capital Improvements, Department of Housing and Urban Development, 451 Seventh Street, SW, Room 4134, Washington, D.C. 20410. Telephone (202) 708-1640. (This is not a toll free number.) Applicants also may contact the SuperNOFA Information Center at the telephone listed, above.

ADDITIONAL INFORMATION:

I. Authority; Purpose; Amount Allocated; and Eligibility.

(A) Authority. Section 14, U. S. Housing Act of 1937 (42 U.S.C. 14371); and the CIAP regulations in 24 CFR part 968, subparts A and B.

(B) Purpose. The CIAP provides modernization funds to HAs that own or operate less than 250 units of public housing, to enable them to improve the physical condition and upgrade the management and operations of existing public housing developments to assure their continued availability for low-income families.

(1) In FY 1998, a total of $2.5 billion is available for the Modernization Program (CIAP and CGP), of which approximately $304 million will be available to HAs with fewer than 250 housing units.

(2) Modernization funds are allocated between CIAP and CGP agencies based on the relative shares of backlog needs (weighted at 50%) and accrual needs (weighted at 50%), as determined by the field inspections conducted for the HUD-funded Abt Associates study of modernization needs. This allocation results in CIAP agencies receiving approximately 11% and CGP agencies receiving approximately 89% of the total funds available.

(a) Backlog needs are needed repairs and replacements of existing physical systems, items that must be added to meet the HUD modernization and energy conservation standards and State or local codes, and items that are necessary for the long-term viability of a specific housing development.

(b) Accrual needs are needs that arise over time and include needed repairs and replacements of existing physical systems and items that must be added to meet the HUD modernization and energy conservation standards and State or local codes.

(3) Assignment of Funds to Field Offices of Public Housing (OPH). In past years, the distribution of Public Housing CIAP funds for each Field OPH has been based solely on the relative shares of backlog and accrual needs for CIAP PHAs. In order to obtain a more equitable distribution of available funds relative to historical demand within each Field Office (FO) jurisdiction, Headquarters has determined that the FY 1998 distribution of Public Housing CIAP funds for each Field Office of Public Housing (Field OPH) will be based on the relative shares of backlog and accrual needs for CIAP PHAs (weighted at 50%) and the relative demand for CIAP funds, as evidenced by the CIAP funds requested in FY 1997 (weighted at 50%). However, to ensure that the relative demand side of the allocation formula does not give undue weight to FOs that were able to fund a higher percentage of funds requested in prior years, each Field OPH was capped by Headquarters in FFY 1997 to an allocation amount that would fund no more than 30% of funds requested by PHAs in that FOs jurisdiction in FFY 96. Those same percentages are being used in FFY 98.

(a) The Field OPH Director shall have authority to make Joint Review selections and CIAP funding decisions.

(b) If additional funds for Public Housing CIAP become available, Headquarters will allocate the funds to each Field OPH based on the table below.

(c) If a Field OPH does not receive sufficient fundable applications to use its allocation, Headquarters will reallocate the remaining funds to one or more Field OPHs that have the highest unfunded demand, as evidenced by approvable applications.

The following table shows the percentage distribution of CIAP funds for PHAs assigned by Headquarters to each Field OPH. The percentage distributions for the Texas State and Houston Area Offices have been further broken down to indicate what percentage of their distribution will be allocated to HAs involved in the East Texas civil rights case (i.e., Young v. Cuomo) to meet the requirements of the settlement agreement, which is subject to judicial oversight, along with other modernization needs.

OFFICE OF PUBLIC HOUSING (OPH)	PERCENT OF THE CIAP ALLOCATION
NEW ENGLAND
Massachusetts State Office	2.4560
Connecticut State Office	.8107
New Hampshire State Office	1.5676
Rhode Island State Office	.4361
NEW YORK/NEW JERSEY
Buffalo Area Office	2.0783
New Jersey State Office	2.3160
New York State Office	1.4892
MID-ATLANTIC
Maryland State Office	.4214
West Virginia State Office	1.3081
Pennsylvania State Office	.6837
Pittsburgh Area Office	.9155
Virginia State Office	.4234
District of Columbia Office	.1672
SOUTHEAST
Georgia State Office	8.2709
Alabama State Office	5.0915
South Carolina State Office	1.2749
North Carolina State Office	2.9244
Mississippi State Office	1.6542
Jacksonville Area Office	2.5183
Knoxville Area Office	1.0628
Kentucky State Office	4.7477
Tennessee State Office	2.7438
Florida State Office	1.0793
MIDWEST
Illinois State Office	3.9655
Cincinnati Area Office	.4645
Cleveland Area Office	.5422
Ohio State Office	1.1608
Michigan State Office	1.8521
Grand Rapids Area Office	2.6617
Indiana State Office	1.1643
Wisconsin State Office	2.5429
Minnesota State Office	3.7183
SOUTHWEST
New Mexico State Office	1.3046
Texas State Office East Texas HAs Non-East Texas HAs	7.2209 (0.361045 or 5% of 7.2209) (6.859855 or 95% of 7.2209)
Houston Area Office East Texas HAs Non-East Texas HAs	1.7024 (0.817152 or 48% of 1.7024) (0.885248 or 52% of 1.7024)
Arkansas State Office	2.1839
Louisiana State Office	3.9607
Oklahoma State Office	2.3203
San Antonio Area Office	3.1643

GREAT PLAINS
Iowa State Office	.5858
Kansas/Missouri State Office	2.7413
Nebraska State Office	1.0943
St. Louis Area Office	1.0715
ROCKY MOUNTAIN
Colorado State Office	3.1227
PACIFIC/HAWAII
Los Angeles Area Office	.2670
Arizona State Office	.9903
Sacramento Area Office	.0808
California State Office	1.7445
NORTHWEST/ALASKA
Oregon State Office	.6706
Washington State Office	1.2608
TOTAL	100.0000

(D) Eligible Applicants. Public Housing Agencies (HAs) that own or operate fewer than 250 public housing units are eligible to apply and compete for CIAP funds. HAs with 250 or more public housing units are entitled to receive a formula grant under the Comprehensive Grant Program (CGP) and are not eligible to apply for CIAP funds. Entities other than HAs are not eligible to apply for CIAP funds. Indian Housing Authorities are not eligible to apply for these funds.

(E) Eligible Activities.

(1) An HA may use financial assistance received under this CIAP section of the SuperNOFA for activities including, but not limited to:

(a) Physical improvements, e.g., alterations, betterments, additions, and accessibility features;

(b) Demolition and conversion costs;

(d) Economic development costs;

(e) Resident management costs;

(f) Drug elimination costs;

(g) Lead-based paint abatement costs;

(h) Administrative costs;

(i) Salaries and employee benefit contributions; and

(j) Architectural/engineering and consultant fees.

(2) Repeal of the Expansion of Eligible Activities. The FY 1998 Appropriations Act did not continue the expanded eligible activities that could be funded, with prior HUD approval, as provided in section 14(q) of the U.S. Housing Act of 1937, as amended in section 201 of the HUD FY 1996 Appropriations Act. These activities include: new construction or acquisition of additional public housing units, including replacement units; modernization activities related to the public housing portion of housing developments held in partnership or cooperation with non-public housing entities; other activities related to public housing, including activities eligible under the Urban Revitalization Demonstration (HOPE VI), such as community services; and operating subsidy purposes (not to exceed 10 percent of the grant amount). Therefore, funds approved under this CIAP section of the SuperNOFA, i.e., Fiscal Year (FY) 98 funds, may not be used for the above purposes. However, HAs may still use previously apposed grant funds (FFY 97 and prior years)that are unobligated or the above activities with prior HUD approval, where applicable. Relief from this prohibition is pending in Congress.

II. Program Requirements.

In addition to the program requirements listed in the General Section of this SuperNOFA, applicants are subject to the following requirements:

(A) Forms, Certifications and Assurances. In addition to the forms, certifications and assurances listed in the General Section of this SuperNOFA, applicants are required to submit signed copies of Form HUD-50071, Certification for Contracts, Grants, Loans and Cooperative Agreements.

(B) Departmental Priority. The transformation of public housing is one of the Department's major priorities. To facilitate the modernization of public housing so that it is integrated in the broader community, the Department encourages HAs to consider the following:

(1) Design. When identifying physical improvement needs to meet the modernization standards, HAs are encouraged to consider a design which supports the integration of public housing into the broader community. Although high priority needs, such as those related to health and safety, vacant, substandard units, structural or system integrity, and compliance with statutory, regulatory or court-ordered deadlines, will receive funding priority, HAs should plan their modernization in a way which promotes good design, but maintains the modest nature of public housing. The HA should pay particular attention to design, which is sensitive to traditional cultural values, and be receptive to creative, but cost-effective approaches suggested by architects, residents, HA staff, and other local entities. Such approaches may complement the planning for basic rehabilitation needs. It should be noted that there will be no increase in operating subsidy as a result of any modernization activities.

(2) Physical Accessibility and Visitability. In addition to the design considerations set forth in Section II(C)(1) of this CIAP section of the SuperNOFA, HAs must comply with accessibility requirements and are encouraged to provide units that are "visitable" by persons with mobility impairments. Visitability gets the person into the home, but does not require that all features be made accessible throughout the home.

(a) Accessibility. An accessible home means that the home is located on an accessible route (36" clear passage) and, when designed, constructed, altered or adapted, can be approached, entered, and used by an individual with physical disabilities.

(b) Visitability. Visitability restricts itself to two areas of a home; i.e., at least one entrance is at grade (no-step); and all doors inside provide a 32" clear passage. A visitable home serves not only persons with disabilities, but also persons without disabilities. (For example, a mother pushing a stroller; person delivering large appliances, etc.). One difference between "visitability" and "accessibility" is that accessibility requires that all features of a dwelling unit be made accessible for mobility impaired persons. A visitable home provides less accessibility than an accessible home. Examples of actions that HAs may take to support visitability include:

(i) When conducting a "needs assessment," the HA may identify some single family scattered site homes and make those units visitable.

(ii) When undertaking substantial alterations as defined in 24 CFR 8.23(a), the HA may identify some units in an elderly development not subject to the new construction requirements of 24 CFR 8.22 and make those units visitable.

(iii) The HA may target the first floor of an existing 3-story family apartment complex and make those units visitable.

(3) Provision of Community Space for Welfare-to-Work Initiatives. HAs are encouraged to provide community space for Welfare-to-Work initiatives, which include, but are not limited to, services coordination/case management, training, child care, health care, transportation, and economic development. Where community space is not otherwise available, CIAP funds may be used to convert existing dwelling space, renovate existing nondwelling space, or construct or acquire nondwelling space for this purpose. Where CIAP funds will be used to provide community space, HAs are required to submit written evidence from a qualified local agency or provider that the agency or provider agrees to furnish, equip, operate and maintain the community space, as well as provide insurance coverage. Where HAs themselves intend to operate the community space, they must submit written evidence of the continuing funding sources to furnish, equip, operate, maintain and insure the community space.

(4) Elimination of Vacant Units. HAs are encouraged to apply for CIAP funds to address vacant units where the work does not merely involve routine maintenance, but will result in reoccupancy.

(C) Accessibility Requirements. In carrying out modernization work, HAs are required to comply with the requirements of 24 CFR 8.23(a) regarding substantial alterations and 24 CFR 8.23(b) regarding other alterations, as well as with Title II of the Americans with Disabilities Act and 28 CFR part 35. Title II is applicable to HAs established under State law. Also, the HA shall comply with the requirements of 24 CFR 8.22 and 24 CFR 100.205 (the Fair Housing Act) regarding new construction.

(D) Expediting the Program. HAs must obligate approved funds within two years and expend within three years of program approval (Annual Contributions Contract (ACC) Amendment execution) unless a longer implementation schedule (Part III of the CIAP Budget) is approved by the Field Office due to the size or complexity of the program. However, HUD strongly encourages the minimum amount of time feasible for program completion and contends that an 18 month timeframe for fund obligation is generally reasonable. Failure to obligate funds in a timely manner may result in the termination of the program and recapture of the funds.

(E) Planning. In preparing its CIAP Application, the HA is encouraged to assess all its physical and management improvement needs. Physical improvement needs should be reviewed against the modernization standards as set forth in HUD Handbook 7485.2, as revised, physical accessibility requirements as set forth in 24 CFR part 8, and 28 CFR part 35, and any cost-effective energy conservation measures identified in updated energy audits. The modernization standards include development specific work to ensure the long-term viability of the developments, such as amenities and design changes to promote the integration of low-income housing into the broader community. In addition, the HA is strongly encouraged to contact the Field Office to discuss its modernization needs and obtain information.

(F) Resident Involvement and Local Official Consultation Requirements.

(1) Residents/Homebuyers. The CIAP regulations at 24 CFR 968.215 require the HA to establish a Partnership Process to ensure full resident participation in the planning, implementation and monitoring of the modernization program, as follows:

(a) Before submission of the CIAP Application, consultation with the residents, resident organization, and resident management corporation (herein referred to as residents) of the development(s) being proposed for modernization regarding its intent to submit an application and to solicit resident comments;

(b) Reasonable opportunity for residents to present their views on the proposed modernization and alternatives to it, and full and serious consideration of resident recommendations;

(c) Written response to residents indicating acceptance or rejection of resident recommendations, consistent with HUD requirements and the HA's own determination of efficiency, economy and need, with a copy to the Field Office at Joint Review. If the Joint Review is conducted off-site, a copy shall be mailed to the Field Office;

(d) After HUD funding decisions, notification to residents of the approval or disapproval and, where requested, provision to residents of a copy of the HUD-approved CIAP Budget; and

(e) During implementation, periodic notification to residents of work status and progress and maximum feasible employment of residents in the modernization effort.

(2) Local Officials. Before submission of the CIAP Application, consultation with appropriate local/tribal officials regarding how the proposed modernization may be coordinated with any local plans for neighborhood revitalization, economic development, drug elimination and expenditure of local funds, such as Community Development Block Grant funds.

(G) Environmental Requirements. Under 24 CFR part 58, the responsible entity, as defined in 24 CFR 58.2(a)(7), must assume the environmental responsibilities for projects being funded under the CIAP. If the HA objects to the responsible entity conducting the environmental review, on the basis of performance, timing or compatibility of objectives, the Field OPH Director will review the facts to determine who will perform the environmental review. At any time, the Field OPH Director may reject the use of a responsible entity to conduct the environmental review in a particular case on the basis of performance, timing or compatibility of objectives, or in accordance with 24 CFR 58.77(d)(1). If a responsible entity objects to performing an environmental review, or if the Field OPH Director determines that the responsible entity should not perform the environmental review, the Field OPH Director may designate another responsible entity to conduct the review or may itself conduct the environmental review in accordance with the provisions of 24 CFR part 50. After selection by the Field Office for Joint Review, the HA shall provide any documentation to the responsible entity (or Field Office, where applicable) that is needed to perform the environmental review.

(1) Where the environmental review is completed before Field Office approval of the CIAP budget and the HA has submitted its request for release of funds (RROF), the budget approval letter shall state any conditions, modifications, prohibitions, etc. as a result of the environmental review.

(2) Where the environmental review is not completed and/or the HA has not submitted the RROF before Field Office approval of the CIAP budget, the budget approval letter shall instruct the HA to refrain from undertaking, or obligating or expending funds on, physical activities or other choice-limiting actions, until the Field PH Director approves the HA's RROF and the related certification of the responsible entity (or the Field Office has completed the environmental review). The budget approval letter also shall advise the HA that the approved budget may be modified on the basis of the results of the environmental review.

(H) Declaration of Trust. Where the Field Office determines that a Declaration of Trust is not in place or is not current, the HA shall execute and file for the record a Declaration of Trust, as provided under the ACC, to protect the rights and interests of HUD throughout the 20-year period during which the HA is obligated to operate its developments in accordance with the ACC, the Act, and HUD regulations and requirements.

(I) HA Submission of Additional Documents. After the Field Office Public Housing Director's funding decisions, the HA shall submit the following documents within the time frame prescribed by the Field Office:

(a) Form HUD-52825, CIAP Budget/Progress Report, which includes the implementation schedule(s), in an original and two copies.

(b) Form HUD-52820, HA Board Resolution Approving CIAP Budget, in an original only.

(J) ACC Amendment. After HUD approval of the CIAP Budget, the Field Office and the HA shall enter into an ACC amendment in order for the HA to draw down modernization funds. The ACC amendment shall require low-income use of the housing for not less than 20 years from the date of the ACC amendment (subject to sale of homeownership units in accordance with the terms of the ACC). The HA Executive Director, where authorized by the Board of Commissioners and permitted by State law, may sign the ACC amendment on behalf of the HA. HUD has the authority to condition an ACC amendment (e.g., to require an HA to hire a modernization coordinator or contract administrator to administer its modernization program).

(K) Use of Dwelling Units for Economic Self-Sufficiency Services and/or Drug Elimination Activities. CIAP funds may be used to convert dwelling units for purposes related to economic self-sufficiency services and/or drug elimination activities. Regarding the eligibility for funding under the Performance Funding System of dwelling units used for these purposes, refer to 24 CFR 990.108(b)(2).

(L) Duplication of Funding. The HA shall not receive duplicate funding for the same work item or activity under any circumstance and shall establish controls to assure that an activity, program, or project that is funded under any other HUD program shall not be funded by CIAP.

(M) Conflict of Interest. In addition to the conflict of interest requirements in 24 CFR part 85, no person who is an employee, agent, consultant, officer, or elected or appointed official and who exercises or has exercised any functions or responsibilities with respect to activities assisted under this grant, or who is in a position to participate in a decision making process or gain inside information with regard to such activities, may obtain a financial interest or benefit from the activity, or have an interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has family or business ties, during his or her tenure or for one year thereafter.

(N) Wage Rates. The wage rate requirements at 24 CFR 968.110(e) and (f) apply to assistance under this program.

III. Application Selection Process.

(A) Rating and Ranking

(1) General. The rating and ranking of applications, the grouping of applications, the technical review process and funding decisions will be in accordance with HUD's regulations in 24 CFR 968.210.

(2) Eligibility Review. After the HA's CIAP application is determined to be complete and accepted for review, the Field Office eligibility review shall determine if the application is eligible for full processing or processing on a reduced scope, and shall assess the applicant's management and modernization capability.

(a) Full Eligibility. To be eligible for full processing, the applicant must be in compliance with the program requirements listed in Section II of the CIAP section of the SuperNOFA, and additionally must be in compliance with the following:

(i) Each eligible development for which work is proposed has reached the Date of Full Availability (DOFA) and is under ACC at the time of CIAP application submission; and

(ii) Where funded under Major Reconstruction of Obsolete Projects (MROP) after FY 1988, the development/building has reached DOFA or, where funded during FYs 1986-1988, all MROP funds for the development/building have been expended.

(b) Reduced Eligibility. When the following conditions exist, the HA's application will be reviewed on a reduced scope in accordance with HUD's regulations in 24 CFR 968.210.

(i) An HA that has been Not designated as Troubled under 24 CFR part 901, Public Housing Management Assessment Program (PHMAP), or

(ii) Designated as Troubled, but has a reasonable prospect of acquiring management capability through CIAP-funded management improvements and administrative support. A Troubled PHA is eligible for Emergency Modernization only, unless it is making reasonable progress toward meeting the performance targets established in its memorandum of agreement or equivalent under 24 CFR 901.140 or has obtained alternative oversight of its management functions.

(iiI) An HA that has been designated as Modernization Troubled under 24 CFR part 901, PHMAP is eligible for Emergency Modernization only, unless it is making reasonable progress toward meeting the performance targets established in its memorandum of agreement or equivalent under 24 CFR 901.140 or has obtained alternative oversight of its modernization functions. Where an HA does not have a funded modernization program in progress, the Field Office shall determine whether the HA has a reasonable prospect of acquiring modernization capability through hiring staff or contracting for assistance.

(3) Long-Term Viability and Reasonable Cost. On Form HUD-52822, CIAP application, the HA certifies whether the developments proposed for modernization have long-term physical and social viability, including prospects for full occupancy. During Joint Review, the Field Office will review with the HA the determination of reasonable cost for the proposed modernization to ensure that unfunded hard costs do not exceed 90 percent of the computed total development cost (TDC) for a new development with the same structure type and number and size of units in the market area. The Field Office shall make a final viability determination. Where the estimated per unit unfunded hard cost is equal to or less than the per unit TDC for the smallest bedroom size at the development, no further computation of the TDC limit is required.

(a) If the Field Office determines that completion of the improvements and replacements will not reasonably ensure the long-term physical and social viability of the development at a reasonable cost, the Field Office shall only approve Emergency Modernization or non-emergency funding for essential non-routine maintenance needed to keep the property habitable until the demolition or disposition application is approved and residents are relocated.

(b) Where the Field Office wishes to fund a development with hard costs exceeding 90 percent of computed TDC, the Field Office shall submit written justification to Headquarters for final decision. Such justification shall include:

(i) Any special or unusual conditions have been adequately explained, all work has been justified as necessary to meet the modernization and energy conservation standards, including development specific work necessary to provide a modest, non-luxury development; and

(ii) Reasonable cost estimates have been provided, and every effort has been made to reduce costs; and

(c) Rehabilitation of the existing development is more cost-effective in the long-term than construction or acquisition of replacement housing; or

(d) There are no practical alternatives for replacement housing.

(4) "Fast Tracking" Emergency Applications. Emergency applications do not have to be processed within the normal processing time allowed for other applications. Where an immediate hazard must be addressed, HA emergency applications may be submitted and processed at any time during the year when funds are available. The Field Office shall "fast track" the processing of these emergency applications so that fund reservation may occur as soon as possible. An emergency application is comprised of the forms, certifications and assurances listed in the General Section of the SuperNOFA, and also the following documents:

(a) Form HUD-52825, CIAP Budget/Progress Report, which includes the implementation schedule(s), in an original and two copies.

(b) Form HUD-52820, HA Board Resolution Approving CIAP Budget, in an original only.

(B) Factors For Award Used To Evaluate and Rate Applications.

The factors for rating and ranking applicants, and maximum points for each factor, are provided below. The maximum number of points to be awarded is 102. This includes two EZ/EC bonus points, as described in the General Section of the SuperNOFA.

Rating Factor 1: Capacity of the Applicant and Relevant Organizational Experience (20 Points)

This factor addresses the extent to which the applicant has the organizational resources necessary to successfully implement the proposed activities in a timely manner. The rating of the "applicant" or the "applicant's organization and staff" for technical merit or threshold compliance, unless otherwise specified, will include any sub-contractors, consultants, sub-recipients, and members of consortia which are firmly committed to the project. In rating this factor HUD will consider the extent to which the proposal demonstrates:

(1) The knowledge and experience of the overall proposed project director and staff, including the day-to-day program manager, consultants and contractors in planning and managing programs for which funding is being requested. Experience will be judged in terms of recent, relevant and successful experience of the applicant's staff to undertake eligible program activities.

(2) The applicant has sufficient personnel or will be able to quickly access qualified experts or professionals, to deliver the proposed activities in each proposed service area in a timely and effective fashion, including the readiness and ability of the applicant to immediately begin the proposed work program. The adequacy of the personnel for an HA will be determined on the basis of the amount of funding and the complexity of the proposed activities.

(3) The applicant has demonstrated experience in managing programs, and carrying out grant management responsibilities for programs, similar in scope or nature directly relevant to the work activities proposed. If the applicant has managed large, complex, interdisciplinary programs, the applicant should include that information in the response.

(4) If the applicant received funding in previous years in the program area for which they are currently seeking funding, the applicant's past experience will be evaluated in terms of their ability to attain demonstrated measurable progress in the implementation of their most recent grant award as measured by obligation and expenditures and measurable progress in achieving the purpose for which funds are provided.

(5) The Field Office shall evaluate the HA's management capability. Particular attention shall be given to the adequacy of the HA's maintenance in determining the HA's management capability. This assessment shall be based on the compliance aspects of on-site monitoring, such as audits, reviews or surveys which are currently available within the Field Office, and on performance reviews. The HA has management capability if it is:

(a) Not designated as Troubled under 24 CFR part 901, Public Housing Management Assessment Program (PHMAP), or

(b) Designated as Troubled, but has a reasonable prospect of acquiring management capability through CIAP-funded management improvements and administrative support.

(6) The Field Office shall evaluate the HA's modernization capability, including the progress of previously approved modernization and the status of any outstanding findings from CIAP monitoring visits. The HA has modernization capability if it is:

(a) Not designated as Modernization Troubled under 24 CFR part 901, PHMAP, or

(b) Designated as Modernization Troubled, but has a reasonable prospect of acquiring modernization capability through CIAP-funded management improvements and administrative support, such as hiring staff or contracting for assistance.

Rating Factor 2: Need/Extent of the Problem (20 Points)

This factor addresses the extent to which there is a need for funding the proposed program activities and an indication of the urgency of meeting the need in the target area. In responding to this factor, applicants will be evaluated on:

(1) The extent to which they document the level of need for the proposed activity and the urgency in meeting the need using statistics and analyses contained in a data source(s) that:

(a) Is sound and reliable. To the extent that the applicant's community's Consolidated Plan and Analysis of Impediments to Fair Housing Choice (AI) identifies the level of the problem and the urgency in meeting the need, references to these documents should be included in the response. HUD will review more favorably those applicants who used these documents to identify need, when applicable.

If the proposed activity is not covered under the scope of the Consolidated Plan and Analysis of Impediments to Fair Housing Choice (AI), applicants should indicate such, and use other sound data sources to identify the level of need and the urgency in meeting the need. Types of other sources include, but are not limited to, law enforcement agency crime reports, an HA's assessment of its physical and management needs, HUD review reports, and other sound and reliable sources appropriate for the specific SuperNOFA program and activities for which an applicant is applying. For technical assistance programs, input from HUD State and Area Office(s) and assessments are included among the data sources that may be used to identify need.

(b) Is specific to the development where the proposed activity will be carried out or where applicable, documents the need for an HA-wide activity(s). Specific attention must be paid to documenting need which has a direct impact on the surrounding community, e.g., where a design change facilitates the integration of public housing into the surrounding community. (2) The extent of vacancies based on the HA-wide vacancy rate, where the vacancies are not due to insufficient demand.

Rating Factor 3: Soundness of Approach (40 Points)

This factor addresses the quality and cost effectiveness of the applicant's proposed work plan. There must be a clear relationship between the proposed activities, community needs and the purpose of the program funding for an applicant to receive points for this factor. In evaluating this factor, HUD will consider the following:

(1) (5 Points) The quality of the cost estimates for the proposed work.

(2) (25 Points) The extent to which the proposed physical improvement needs meet the modernization standards, and support the integration of public housing into the broader community. Although high priority needs, such as those related to health and safety, vacant, substandard units, structural or system integrity, and compliance with statutory, regulatory or court-ordered deadlines, will receive funding priority, to the extent possible, HAs should plan their modernization in a way which promotes good design, but maintains the modest nature of public housing.

(3) (5 Points) Decree to which the PHA Affirmatively Furthers Fair Housing. Actions that assist the jurisdiction in overcoming impediments to fair housing choice identified in the jurisdictions's Analysis of Impediments (AI) to Fair Housing Choice, which is a component of the jurisdiction's Consolidated Plan, or any other planning document that addresses fair housing issues. Examples of actions that can be taken may include, but are not limited to: neighborhood revitalization efforts that encourage fair housing choice (such as schools, grocery stores, transportation and the quality of services); implementing site selection policies which give priority to sites located outside of minority and low-income areas; participating in mobility counseling programs and clearing houses which offer housing opportunities both within and outside of high-poverty areas; increasing the supply of accessible housing available to low-income persons with disabilities; and ensuring accessibility and visitability for persons with disabilities to aspects of the program. Additional examples may be obtained from Chapter 5 of the "Fair Housing Planning Guide, Vol. 1" which may be ordered from HUD's Fair Housing Clearinghouse by calling (800-343-3442).

(5 Points for Subfactors (4) through (8))

(4) The degree of resident involvement in HA operations as described in the Narrative Statement and supported by FO file evidence.

(5) The degree of HA activity in coordinating/providing resident services related to Welfare-to-Work initiatives in community facilities at or near HA developments based on FO file evidence. Such services include, but are not limited to services coordination/case management, training, child care, health care, transportation, and economic development.

(6) The degree of HA activity in resident initiatives, including resident management, economic development, homeownership, and drug elimination efforts or other resident initiatives for non-elderly as described in the Narrative Statement and supported by FO file evidence.

(7) The degree of non-elderly resident employment through direct hiring or contracting/subcontracting or job training initiatives as described in the Narrative Statement and supported by FO file evidence.

(8) Further and support the policy priorities of HUD including:

(a) Promoting healthy homes;

(b) Providing opportunities for self-sufficiency, particularly for persons enrolled in welfare to work programs;

(c) Enhancing on-going efforts to eliminate drugs and crime from neighborhoods through program policy efforts such as "One Strike and You're Out" or the "Officer Next Door" initiative;

(d) Providing educational and job training opportunities through such initiatives as Neighborhood Networks, Campus of Learners and linking to AmeriCorps activities.

Rating Factor 4: Leveraging Resources (10 Points)

This factor addresses the ability of the applicant to secure community resources (note: financing is a community resource) which can be combined with HUD's program resources to achieve program purposes. In evaluating this factor HUD will consider:

(1) To the extent possible, the applicant has taken the initiative to partner with other entities to secure additional resources to increase the effectiveness of the proposed program activities, e.g., CDBG funds may be committed for infrastructures. Resources may include funding or in-kind contributions, such as services or equipment, allocated to the purpose(s) of the award the applicant is seeking, e.g., an educational institution may provide training in conjunction with a management improvement activity. Resources may be provided by governmental entities, public or private nonprofit organizations, for-profit private organizations, or other entities willing to partner with the applicant. Applicants may also partner with other program funding recipients to coordinate the use of resources in the area of the public housing development.

(2) Where applicable, applicants should provide evidence of other resources by including in the application letters of firm commitment, memoranda of understanding, or agreements to participate from those entities identified as partners in the application. Each letter of commitment, memorandum of understanding, or agreement to participate should include the organization's name, proposed level of commitment and responsibilities as they relate to the proposed program. The commitment must also be signed by an official of the organization legally able to make commitments on behalf of the organization.

(3) The local government support for proposed modernization, through either funding or in-kind contributions, over and above what is required under the Cooperation Agreement for municipal services, such as police and fire protection and refuse collection, within the last 12 months, that will directly benefit the public housing or the neighborhood surrounding the public housing.

Rating Factor 5: Comprehensiveness and Coordination (10 Points)

This factor addresses the extent to which the applicant coordinated its activities with other known organizations, participates or promotes participation in a community's Consolidated Planning process, and is working towards addressing a need in a holistic and comprehensive manner through linkages with other activities in the community.

In evaluating this factor, HUD will consider the extent to which the applicant demonstrates that it has:

(1) Coordinated its proposed activities with those of other groups or organizations prior to submission in order to best complement, support and coordinate all known activities and if funded, the specific steps it will take to share information on solutions and outcomes with others. Any written agreements, memoranda of understanding in place, or that will be in place after award should be described.

(2) Taken or will take specific steps to become active in the community's Consolidated Planning process (including the Analysis of Impediments to Fair Housing Choice) established to identify and address a need/problem that is related to the activities the applicant proposes.

(3) Taken or will take specific steps to develop linkages to coordinate comprehensive solutions through meetings, information networks, planning processes or other mechanisms with:

(a) Other HUD-funded projects/activities outside the scope of those covered by the Consolidated Plan; and

(b) Other Federal, State or locally funded activities, including those proposed or on-going in the community.

IV. Application Submission Requirements.

The HA shall submit the CIAP Application to the Field Office, with a copy to appropriate local officials, e.g., the mayor, City Manager. The HA may obtain the necessary forms from the Field Office. The CIAP Application is comprised of the following documents:

(A) Form HUD-52822, CIAP Application, in an original and two copies, which includes:

(1) A general description of HA development(s), in priority order, (including the current physical condition, for each development for which the HA is requesting funds, or for all developments in the HA's inventory) and physical and management improvement needs to meet the Secretary's standards in 24 CFR 968.115; description of work items required to correct identified deficiencies, including accessibility work; and the estimated cost. Where the HA has not included some of its developments in the CIAP Application, the Field Office may not consider funding any non-emergency work at excluded developments or subsequently approve use of leftover funds at excluded developments. Therefore, to provide maximum flexibility, the HA may wish to include all of its developments in the CIAP Application, even though there are no known current needs. Following is an example of the general description:

Development 1-1: 50 units of low-rent; 25 years old; physical needs are: new roofs; storm windows and doors; and electrical upgrading at estimated cost of $150,000.

Development 1-2: 40 units of low-rent; 20 years old; physical needs are: physical accessibility for kitchens, bathrooms and doors in 2 units and common laundry room; visitability in 4 ground floor units; kitchen floors; shower/bathtub surrounds; fencing; and exterior lighting at estimated cost of $130,000.

Development 1-3: 35 units of Turnkey III; 15 years old; physical needs are: physical accessibility in 3 units; and roof insulation at estimated cost of $50,000.

Development 1-4: 20 units of low-rent; 5 years old; no physical needs; no funding requested.

(2) Where funding is being requested for management improvements, an identification of the deficiency, a description of the work required for correction, and estimated cost. Examples of management improvements include, but are not limited to, the following areas:

(a) The management, financial, and accounting control systems of the HA;

(b) The adequacy and qualifications of personnel employed by the HA in the management and operation of its developments by category of employment; and

(c) The adequacy and efficacy of resident programs and services, resident and development security, resident selection and eviction, occupancy and vacant unit turnaround, rent collection, routine and preventive maintenance, equal opportunity, and other HA policies and procedures.

(3) A certification that the HA has met the requirements for consultation with local officials and residents/homebuyers and that all developments included in the application have long-term physical and social viability, including prospects for full occupancy. If the HA cannot make this certification with respect to long-term viability, the HA shall attach a narrative, explaining its viability concerns.

(B) A Narrative Statement, in an original and two copies, addressing each of the rating factors in Section III(B) of this CIAP section of the SuperNOFA. In addressing the affirmatively furthering fair housing technical review factor, actions that the HA has taken, or plans to take, to accomplish this objective may include, but are not limited to the following:

(1) Actions that contribute toward the reduction of concentration of low-income-persons who are protected under the Fair Housing Act and Title VI of the Civil Rights Act. Such actions may include housing programs/activities that provide information regarding housing opportunities outside of minority concentrated areas within the HA's jurisdictional boundaries, or efforts that encourage landlords/owners to make available housing opportunities outside of minority concentrated areas. For example, the HA may refer applicants to other available housing as part of an established housing counseling service or assist applicants in getting on other waiting lists.

(2) Actions that overcome the consequences of prior discriminatory practices or usage which may have tended to exclude persons of a particular race, color or national origin; or that overcome the effects of past discrimination against persons with disabilities. Such actions may include those actions taken without any kind of legally binding order, but which have changed previous discriminatory management, tenant selection and assignment or maintenance practices.

(3) Actions that assist the jurisdiction in overcoming impediments to fair housing choice identified in the jurisdiction's AI (Analysis of Impediments to Fair Housing Choice), which is a component of the jurisdiction's Consolidated Plan, or any other planning document that addresses fair housing issues. Examples of actions that can be taken may include, but are not limited to: neighborhood revitalization efforts that encourage fair housing choice (such as schools, grocery stores, transportation, and the quality of services); implementing site selection policies which give priority to sites located outside of minority and low-income areas; participating in mobility counseling programs and clearinghouses which offer housing opportunities both within and outside of high-poverty areas; increasing the supply of accessible housing available to low-income persons with disabilities; and ensuring accessibility and visitability for persons with disabilities to aspects of the program. Additional examples may be obtained from Chapter 5 of the Fair Housing Planning Guide, Vol 1" which may be ordered from HUD's Fair Housing Clearinghouse by calling (800) 343-3442.

(C) Form HUD-50071, Certification for Contracts, Grants, Loans and Cooperative Agreements, in an original only, required of HAs established under State law, applying for grants exceeding $100,000.

(D) Evidence of Physical Condition of the Developments. At the option of the HA, photographs or video cassettes showing the physical condition of the developments.

V. Corrections to Deficient Applications.

The General Section of the SuperNOFA provides the procedures for corrections to deficient applications.

Return to the 1998 Funds Available

Content Archived: July 23, 2012