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FAQs for FY 2009 HOPE VI Revitalization NOFA
Q1: Have there been technical corrections to the NOFA?
A1: Yes. Technical corrections were made to the FY 2009 HOPE VI Revitalization NOFA and were posted on Thursday, October 15, 2009. They are available on the HUD website at www.hud.gov/hopevi and on the http://www.grants.gov website. The CFDA number for the HOPE VI Revitalization program is 14.866. The deadline for HOPE VI Revitalization grant applications under this NOFA remains unchanged (November 17, 2009). Click on the link to go to the technical corrections document.
Q2: Where will Frequently Asked Questions be posted?
A2: Per the NOFA, Frequently Asked Questions will be posted at http://www.hud.gov/offices/pih/programs/ph/hope6/ and http://archives.hud.gov/funding/2009/grphopevirevi.cfm
Q3: I am a private citizen. Can I apply for a grant under the HOPE VI Revitalization program?
A3: No. The only eligible applicants for the HOPE VI Revitalization program are public housing authorities (PHAs). This is explained further in Section III.A (page 10) of the NOFA which states as follows:
"A. Eligible Applicants
1. Only PHAs that have severely distressed housing in their inventory and that are otherwise in conformance with the threshold requirements provided in Section III.C.2 of this NOFA are eligible to apply. This is considered a threshold requirement under Section III.C.2 of this NOFA.��
2. HCV Programs Only, Tribal Housing Agencies, and Others. PHAs that administer only HCV/Section 8 programs, tribal housing agencies and tribally designated housing entities, are not eligible to apply. Nonprofit organizations, for-profit organizations, and private citizens and entrepreneurs are not eligible to apply."
Q4: Page 112 of the NOFA notes that the HOPE VI funds must be obligated by HUD on or before September 30, 2009. Is this correct? When do grantees have to expend all the HOPE VI grant funds?
A4: Funds do not have to be obligated by HUD to grantees by September 30, 2009. Per the Omnibus Appropriations Act, 2009, the FY09 HOPE VI funds are available until September 30, 2010. Applications, as indicated in the NOFA, are due by Nov. 17, 2009. This was also clarified in the technical corrections to the NOFA that were posted on October 15, 2009. It clarified that the HOPE VI funds must be obligated by HUD by September 30, 2010. It was also clarified that grantees have until September 30, 2015 to expend the grant funds. The full technical corrections document is available on the HUD website at www.hud.gov/hopevi and http://archives.hud.gov/funding/2009/grphopevirevi.cfm, and on the Grants.gov website at www.grants.gov.
Q5: Can a PHA use the HOPE VI grant funds, if awarded, to reimburse themselves for the cost of preparing the application and any other costs that are currently being incurred related to the proposed project?
A5: No. Section IV.E.2.a of the NOFA states: �You may not use HOPE VI Revitalization grant funds to pay for any revitalization activities carried out on or before the date of the letter announcing the award of the HOPE VI Grant.�
Q6: Is there any prohibition against using Replacement Housing Factor (RHF) Funds in a HOPE VI project?
A6: The NOFA does not prohibit the use of RHF in HOPE VI projects. However, the NOFA does make reference to RHF funds in a couple places. See Section III.C.3.jj. "Program Requirements that Apply to Match and Leverage," specifically pages 75-76, which describe how Other Public Housing funds can be used for the application:
"(xvi) Other Public Housing Funds. Other Public Housing funding sources may be used in your proposal subject to the following criteria. Other Public Housing Funds include HOPE VI Demolition funds, HOPE VI Neighborhood Networks funds, HOPE VI Main Street funds, Capital Fund program funds, Replacement Housing Factor funds, reserves (legally available for use in the HOPE VI project), and proposals to use operating subsidy for debt service. For Match: Other Public Housing Funds may be counted for match EXCEPT FOR the HOPE VI program funds (HOPE VI Demolition, HOPE VI Neighborhood Networks, and HOPE VI Main Street), which may not be used for match. For Leverage: Other Public Housing Funds listed above, INCLUDING the HOPE VI program funds, will be considered under the Anticipatory leverage rating factor, in accordance with the criteria in the Anticipatory leverage rating factor. Other Public Housing Funds will NOT be counted for points under CSS, Development, and Collateral leverage."
If a grant is awarded to an applicant, then that grantee must follow the subsequent grant implementation guidance provided and required by HUD as the grantee implements the grant.
Q7: Could you please address how any funds awarded through CFRC would be treated since the NOFA is silent on this issue. Would they be considered Public Housing Capital Funds and have the same restrictions as "Public Housing Funds" or would they be treated more like CDBG, etc?
A7: CFRC funds are Public Housing Capital Funds so they are public housing funds.
Q8: Is there a requirement that HOPE VI or other public housing funds be used for off-site replacement units (both for the units to be counted as replacement units and for the housing authority to be eligible for the point for having an off-site component)?
A8: The NOFA does not contain requirements that say X-type of dollar can only be used for on-site or off-site property. The Off-Site Rating Factor (Section V.A.9.b, page 150-152) does not contain criteria about what type of funding is paying for the off-site units. Section III.C.3.r (page 60, in the Program Requirements section) does require as follows: "r. Non-Public Housing Funding for Non-Public Housing or Replacement Units. Public housing funds may only be used to develop Replacement Housing. You may not use public housing funds, which include HOPE VI funds, to develop retail or commercial space, economic development space, or housing units that are not Replacement Housing, as defined in this NOFA."
Q9: Section I.C.1 (page 6) provides the following definition: "Public Housing Project. A public housing project is a group of assisted housing units that has a single Project Number assigned by the Director of Public Housing of a HUD Field Office and has, or had (in the case of previously demolished units) housing units under an Annual Contributions Contract." If a PHA had two distinct projects, with different project numbers, under its original ACC, and those projects were combined into a single project number in PIC for the purposes of implementing HUD's project-based budgeting requirements using Asset Management Project (AMP) numbers, does HUD consider the "project" to be the one with the original project number or the combined project now in PIC?
A9: For purposes of the HOPE VI NOFA, HUD considers the project to be the one with the original project number. Applicants should be clear throughout their application as to the project they are targeting.
Q10: We plan to apply for a public housing site, for which most of the replacement units have already had financing obtained and/or identified, with some units already closed and under construction. The application will target the balance of the units on the site. Since HOPE VI funding will be requested only for the remaining units, do we have to demonstrate site control and land use approvals for that property?
A10: Yes. Section III.C.2.b(10) (page 29) establishes the site control threshold requirement. Section III.C.2.b(10) (d) states: "If one or more of your off-site parcels are a public housing property, you still must provide evidence of site control for those properties.� Section III.C.2.a(2) (page 19) states (incorporating the technical correction posted on October 15, 2009 and discussed below in the FAQ on the Land Use threshold): Land Use. Your application must include a certification from the appropriate local official (not the Executive Director) documenting that all required land use approvals for developed and undeveloped land, whether on the original site or off-site, have been secured for any housing and other proposed uses, or that the request for such approval(s) is on the agenda for the next meeting of the appropriate authority in charge of land use. In the case of the latter, the certification must include the date of the meeting. You must include this certification in your attachments."
Q11: For purposes of the Attachment 7 sources and uses budget and the Attachment 9 TDC analysis, do we need to identify the financing for the units for which most of the replacement units have already had financing obtained and/or identified?
A11: See the instructions on assembling the application in Section IV.B.8.e. For additional information regarding your question on what to include or not include, please refer to the definition of Revitalization Plan on page 6, Section I.C.3, which states as follow: "3. Revitalization Plan. Under this HOPE VI NOFA, your HOPE VI Revitalization Plan is the plan (e.g., programs, units, properties, financing, schedule, etc.) identified in your HOPE VI Revitalization grant application. The Revitalization Plan may only include activities that, as of the application deadline date, are proposed for the future or underway but not yet complete. Activities that were completed before the application deadline date will not be considered as part of the Revitalization Plan unless otherwise indicated in the NOFA. Thus you must present your Revitalization Plan clearly and consistently throughout the application (narratives and attachments), as it is the Revitalization Plan identified in the application that will be evaluated under the threshold requirements and rating factors, as applicable. If something is identified in the application as part of your Revitalization Plan, it will be subject to the threshold requirements and rating factors, as applicable." Please note this definition states: "Activities that were completed before the application deadline date will not be considered as part of the Revitalization Plan unless otherwise indicated in the NOFA." The "unless otherwise indicated in the NOFA" would refer for example to a rating factor such as section V.A.9.a(1)(b), Mixed Income Communities, Project-Based Affordable Housing: "If a housing authority has already developed and completed any project-based affordable units onsite, that number of units will be subtracted from the number of public housing units that the targeted project contains or contained."
Q12: Does Attachment 10, the Extraordinary Site Costs Certification, cover both the original public housing site and any off-site properties proposed in the revitalization plan?
A12: Yes. Extraordinary site costs are allowable, with justification (for the application, this is provided through Attachment 10), in connection to the Revitalization Plan, which includes the original site and any off-site properties. Section IV.B.8.e(16) (page 101) provides the following instruction on completing Attachment 10: "Attachment 10. Extraordinary Site Costs Certification. This attachment is applicable only if you request funds to pay for extraordinary site costs, outside the TDC limits. See section IV.E."
Q13: The 09 NOFA provides points for meeting recommended energy standards and best practices. Will the TDC limits be increased to reflect the additional cost requirements to meet these standards?
A13: No, the TDC limit requirements remain unchanged from that stated in the NOFA (Section IV.E.3, page 113 of the NOFA, which references 24 CFR 941.306, Notice PIH 2008-47 (HA), or successor Notice). However, the maximum grant amount was raised in the FY09 NOFA to $22 million (page 9, Section II.A.2).
Q14: The NOFA includes the following program requirement in section III.C.3.ll (page 81): Salary Limitation for Consultants. FY2009 funds may not be used to pay or to provide reimbursement for payment of the salary of a consultant, whether retained by the federal government or the grantee, at a rate more than the equivalent of General Schedule 15, Step 10 base pay rate for which the annual rate for FY 2009 is $127,604. The hourly rate is $61.14." How is �consultant� defined? Is use of that term supposed to cover any expert that might be hired to work on the grant and its implementation (e.g., consultants, developers, architects, program managers, etc.)? Or does it literally apply only to those professionals who have "consultant" in their title?
A14: For this requirement (which is standard for HUD programs), "consultant" refers to anyone who is not an employee or officer of the grantee organization. (2 CFR Part 230, Cost Principles for Non-Profit Organizations (OMB Circular A�122), puts consultants and professional services together).
Q15: Section III.C.2.a(2) contains a threshold requirement regarding land use. Does this apply to on-site and off-site land?�
A15: Yes, it applies to both on-site and off-site land. This clarification was included in the technical corrections to the NOFA that were posted on October 15, 2009. The correction clarified that the Land Use threshold requirement applies to on-site and off-site land.� The corrected language reads as follows: "Your application must include a certification from the appropriate local official (not the Executive Director) documenting that all required land use approvals for developed and undeveloped land, whether on the original site or off-site, have been secured for any housing and other proposed uses, or that the request for such approval(s) is on the agenda for the next meeting of the appropriate authority in charge of land use." The full technical corrections document is available on the HUD website at www.hud.gov/hopevi and http://archives.hud.gov/funding/2009/grphopevirevi.cfm, and on the www.grants.gov website.
Q16: Section III.C.2.b(10)(b) of the NOFA states in the site control threshold requirement the following: "If you demonstrate site control through an option to purchase, the option must extend for at least 180 days after the application deadline date." In the next paragraph Section III.C.2.b(10)(c) it discusses what types of other documents are acceptable including an option, a sales agreement, etc., as well as documents that are no acceptable. Does the 180-day requirement apply also to a sales agreement or sales contract as it relates to documentation for an off-site parcel?
A16: No. The 180-day requirement appears only in Section III.C.2.b(10)(b) which only references options to purchase.
SELECTION OF DEVELOPER (this also contains rating factor information)
Q17: Section III.C.2.a(3) (page 20) contains the following threshold requirement: "Selection of Developer. You must assure that: (a) By the application deadline date, you have initiated a request for qualifications (RFQ) for the competitive procurement of a developer for your first phase of construction, in accordance with 24 CFR 85.36 and 24 CFR 941.602(d) (as applicable), or you already have a Master Development Agreement in place. If you change developers after you are selected for funding, HUD reserves the right to rescind the grant; or (b) You will act as your own developer for the proposed project. If you change your plan and procure an outside developer after you are selected for funding, HUD reserves the right to rescind the grant. (c) You must demonstrate compliance with this threshold through completion and inclusion of the Assurances for HOPE VI Application document." Also, Section V.A.10.d(3)(page 158) contains the following rating factor under Project Readiness: "You will receive one point if a Master Development Agreement (MDA) has been developed and is ready to be executed. However, in cases where the PHA (not an affiliate/subsidiary/instrumentality) will act as its own developer for all components of the revitalization plan, an MDA is not needed and the one point will be awarded automatically."
Q17a: In order to qualify for the statements "its own developer" or "your own developer," is it correct that the development entity must be the Authority itself?
A17a: Yes, in order to qualify as "its own developer" or "your own developer," the PHA itself (not an affiliate/subsidiary/instrumentality) must be the developer.
Q17b: What is the process for selecting an affiliate/subsidiary/instrumentality (i.e. an entity connected in some way to the Housing Authority) as developer? Must this PHA affiliate/subsidiary/instrumentality be competitively procured through Part 85?
A17b: Only an instrumentality does not have to be competitively procured through Part 85.
Q17c: Does the developer agreement need to be executed only for the first phase of construction in order for the PHA to receive this point?
A17c: Please note that the rating factor language actually reads as follows: "You will receive one point if a Master Development Agreement (MDA) has been developed and is ready to be executed." That is, the MDA does not have to be executed yet to earn the point but has to be ready to be executed. However, the MDA for this rating factor does refer to the whole MDA, not just the first phase (this is under the Project Readiness rating factor which is about the overall project).
RESIDENT AND COMMUNITY INVOLVEMENT (this also contains rating factor information)
Q18: HUD Form 52787 (Attachment 31: Project readiness) indicates 5 meetings as the certification to readiness. The NOFA on pages 44-45 indicates 4 meetings. Can you please clarify whether 4 meetings is the required number of meetings and if that is correct how do we treat the certification which indicates 5 meetings?
A18:�The information you refer to on pages 44-45 is the program requirement language related to resident and community involvement (Section III.C.3.k. �Resident and Community Involvement�). This program requirement language is referred to in the threshold requirement on page 21 (Section III.C.2.a(5)) as follows:
"(5) Resident Involvement in the Revitalization Program Assurance. You must assure that you have involved affected public housing residents at the beginning and during the planning process for the revitalization program, prior to submission of your application. If you have not included affected residents in the planning process, your application will not be considered for funding. You MUST follow the resident involvement requirements listed in the Program Requirements section, section III.C.3. of this NOFA. You must demonstrate compliance with this threshold through completion and inclusion of the Assurances for HOPE VI Application document."
As noted in the threshold requirement language, "You MUST follow the resident involvement requirements listed in the Program Requirements section, section III.C.3. of this NOFA" which refers to pages 44-45, Section III.C.3.k. "Resident and Community Involvement." It also states that: "You must demonstrate compliance with this threshold through completion and inclusion of the Assurances for HOPE VI Application document." The Assurances form is posted on Grants.gov for applicants to use.
In contrast to the above threshold requirement, there is a rating factor (part of the overall "Project Readiness" rating factor), as you have seen, on page 158 in Section V.A.10.g(4) (highlighted below).
"d. Project Readiness - 6 Points. HUD places top priority on projects that will be able to commence immediately after grant award. You will receive the following points for each applicable subfactor certified in your application.
(4) You will receive one point if you have held five or more public planning sessions (resident trainings and public meetings)."
This is different than the threshold requirement and use of the Assurances form (i.e., the rating factor gives a point for going above and beyond the number of meetings required for meeting the threshold).
To respond to the threshold requirement, there is this instruction in section IV.B.8.e(18), page 102:
"Attachment 12. Assurances for a HOPE VI Application: for Developer, HOPE VI Revitalization Resident Training and Public Meeting Certification, and Relocation Plan (whether relocation is completed or is yet to be completed). Please complete this assurance document. Do not sign; a signature is not required."
To respond to the rating factor, there are these instructions:
Section IV.B.8.e(11)(d), page 100: "Project Readiness. Respond to Rating Factor V.A.10.d by completing the certification form provided and providing it in the attachments section."
Section IV.B.8.e(34), page 106: "Attachment 31. Form HUD-52787 (HOPE VI Revitalization Project Readiness Certification). This attachment is required in all applications. Complete Attachment 31 by indicating which of the items in Rating Factor V.A.10.d of the NOFA have been completed."
Q19: We are a university that may conduct the evaluation for a PHA that is applying for FY 2009 HOPE VI Revitalization grant funding. What does HUD specifically require of the evaluators? We have found on pages 23-24 of the NOFA a general passage about the evaluation, but we are unsure specifically what we must do.
A19: You mention pages 23-24. This is section III.C.2.a(10) and it is the only set of criteria in the NOFA that relates to the evaluation. This language is provided below. It is a threshold requirement which means that the applicant�s application must demonstrate that it meets this threshold requirement in order to be considered further. The "you" in the criteria is the applicant (public housing authority).
Pages 23-24 of the NOFA:
"(10) Evaluation. You must work with your local university(ies), other institutions of learning, foundations, or others to evaluate the performance and impact of your HOPE VI revitalization plan over the life of the grant. The proposed methodology must measure success against goals you set at the outset of your revitalization activities. Evaluators must establish baselines and provide ongoing interim reports that will allow you to make changes as necessary as your project proceeds. Where possible, you are encouraged to form partnerships with Minority-Serving Institutions (MSIs), Historically Black Colleges and Universities (HBCUs); Hispanic-Serving Institutions (HSIs); Community Outreach Partnership Centers (COPCs); the Alaskan Native/Native Hawaiian Institution Assisting Communities Program (as appropriate); and others in HUD's University Partnerships Program for the purpose of assisting HUD in a long-term look at the impacts of the HOPE VI program on residents and the community at large. In your application, you must include a letter(s) from an institution(s) of higher learning, foundations, or other organization that specializes in research and evaluation, that provides a commitment to work with you to evaluate your program and describes its proposed approach to carry out the evaluation if your application is selected for funding. The letter must provide the extent of the commitment and involvement, the extent to which you and the local institution of higher learning will cooperate, and the proposed approach, which builds upon information already being collected by HUD in reports submitted by the grantee. Please note that the evaluation must reflect the initiatives the applicant committed to in their application and undertook (e.g., Early Childhood Education program, Green Development and Energy Efficiency Strategies, etc.). The commitment letter must address all of the following areas for evaluation:
(a) The impact of your HOPE VI effort on the lives of the residents;
(b) The nature and extent of economic development generated in the community;
(c) The effect of the revitalization effort on the surrounding community, including spillover revitalization activities, property values, etc.; and
(d) Your success at integrating the physical and CSS aspects of your strategy."
Note though that the criteria include the statement: "Please note that the evaluation must reflect the initiatives the applicant committed to in their application and undertook (e.g., Early Childhood Education program, Green Development and Energy Efficiency Strategies, etc.)." The "Early Childhood Education program, Green Development and Energy Efficiency Strategies, etc" refers to Rating Factors later in the NOFA. The intent is that since the purpose of the evaluation is "to evaluate the performance and impact of your HOPE VI revitalization plan over the life of the grant," the applicant should be sure to incorporate the plans they committed to in their application in response to the threshold requirements and rating factors of the NOFA. The Rating Factors start on page 117.
Q20: Regarding the passage on page 23 "Evaluators must establish baselines and provide ongoing interim reports," could you tell us (a university) what the minimum required frequency of those reports is?
A20: There is not a minimum number of interim reports that HUD requires. This is something the applicant/grantee and the evaluator would work out amongst themselves. This is the application stage and the applications may or may not be funded.
Q21: Are there any guidelines for establishing baselines for the evaluation?
A21: HUD does not have required standardized guidance for the evaluation (as the needs and circumstances will vary locality to locality). However, again, for NOFA purposes (and grant implementation, if funded), the applicant must comply with the NOFA criteria in Section III.C.2.a(10).
Q22: Would we (a university) be required or allowed to make recommendations for action or improvement to the housing authority with respect to the provision of services by the community service providers, or are we simply supposed to evaluate the alignment and success of the delivered services with the objectives stated in the HOPE VI proposal?
A22: The minimum role of the evaluator is established in the NOFA criteria above. It is up to the applicant/grantee and the evaluator to work out how exactly they will interact, how often, and if more involvement of the evaluator is necessary/appropriate (e.g., to help more directly with case management). However, please note that an important use of the evaluation (and interim reports) is that it informs the grantee on the progress/impact of the grant as they implement it over the 4-5 year period, helping them in their decision-making.
FAIR HOUSING AND CIVIL RIGHTS
Q23: Is there a threshold requirement that applicants must meet related to Fair Housing and Civil Rights?
A23: Yes. There is a threshold requirement that all applicants have to meet in Section III.C.2.b(1) which states: "(12) Compliance with Fair Housing and Civil Rights Laws. This threshold is hereby incorporated from the General Section (Section III.C.2.c.)." Copied here is the text from the General Section (Section III.C.2.c.).:
"c. Compliance with Fair Housing and Civil Rights Laws
(1) With the exception of federally recognized Indian tribes and their instrumentalities, applicants must comply with all applicable fair housing and civil rights requirements in 24 CFR 5.105(a). If you are a federally recognized Indian tribe, you must comply with the nondiscrimination provisions enumerated at 24 CFR 1000.12, as applicable. In addition to these requirements, there may be program-specific threshold requirements identified in the individual program NOFAs.
(2) If you, the applicant:
(a) Have been charged with an ongoing systemic violation of the Fair Housing Act; or
(b) Are a defendant in a Fair Housing Act lawsuit filed by the Department of Justice alleging an ongoing pattern or practice of discrimination; or
(c) Have received a letter of findings identifying ongoing systemic noncompliance under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, or Section 109 of the Housing and Community Development Act of 1974, and the charge, lawsuit, or letter of findings referenced in subparagraphs (a), (b), or (c) above has not been resolved to HUD�s satisfaction before the application deadline, then you are ineligible and HUD will not rate and rank your application. HUD will determine if actions to resolve the charge, lawsuit, or letter of findings taken before the application deadline are sufficient to resolve the matter.
Examples of actions that would normally be considered sufficient to resolve the matter include, but are not limited to:
(i) A voluntary compliance agreement signed by all parties in response to a letter of findings;
(ii) A HUD-approved conciliation agreement signed by all parties;
(iii) A consent order or consent decree; or
(iv) An issuance of a final judicial ruling or a HUD Administrative Law Judge�s decision."
Applicants should review these criteria and determine how they think they comply with these criteria. HUD cannot now tell applicants how they would be evaluated (whether or not they pass) for this threshold requirement as it is based as of the application deadline date (Nov. 17, 2009) and it is part of the application review process.
SITES PREVIOUSLY FUNDED
Q24: Our PHA already has an existing HOPE VI Revitalization grant that is in process. Are there any threshold requirements in the NOFA that would prohibit us from applying for another severely distressed public housing project in our inventory?
A24: No, there is not a specific threshold requirement that would prohibit a PHA from applying for another severely distressed public housing project in our inventory just because it already has a HOPE VI Revitalization grant. However, in order to be considered for funding applications must meet all the threshold requirements identified in Section III.C.2 of the NOFA. On a related note, there is a threshold requirement pertaining to whether an applicant can apply for funds for a public housing project that has already been funded. It is in section III.C.2.b(7) (pages 28-29) and states as follows:
"(7) Sites Previously Funded.
(a) You may submit a Revitalization application that targets part of a project that is being, or has been, revitalized or replaced under a HOPE VI Revitalization grant awarded in previous years. You may not apply for new HOPE VI Revitalization funds for units in that project that were funded by the existing HOPE VI Revitalization grant, even if those funds are inadequate to pay the costs to revitalize or replace all of the targeted units. For example, if a project has 700 units and you were awarded a HOPE VI Revitalization grant or other HUD public housing funds to address 300 of those units, you may submit an FY 2009 HOPE VI Revitalization application to revitalize the remaining 400 units. You may not apply for funds to supplement work on the original 300 units. If you request funds to revitalize/replace the units not funded by the previous HOPE VI Revitalization grant, you must provide a listing of which units were funded by the previous grant and which units are being proposed for funding under the current grant application. You must discuss compliance with this threshold in your narrative. If you need to provide a listing of units as described above, this may be done in the attachments section (see Section IV.B). If you request funds to revitalize units or buildings that have been funded by an existing HOPE VI Revitalization grant, your application will not be considered for funding.
(b) You may not request HOPE VI Revitalization grant funds for units currently under
construction or already completed as of the application deadline, in accordance with the section IV(E), Funding Restrictions. You must demonstrate compliance with this threshold in your narrative."
Note also that Section V.A.1.c and Section V.A.1.d contain rating factors related to PHAs with existing HOPE VI Revitalization grants. These rating factors award points based grantees� progress in implementing their existing grants.
Q25: Section V.A.1.c (on page 119), "Capacity of Existing HOPE VI Revitalization Grantees � Expenditures," and Section V.A.1.d (on page 120), "Capacity of Existing HOPE VI Revitalization Grantees � Timeliness," both discuss "points deducted." These sections indicate that 3 points might be deducted at maximum from the available points based on expenditure levels, and 2 points for lack of timeliness. However, it appears there are no points indicated for these elements, and the total points available for the overall Capacity Section is 16, which indeed totals the points available from the other elements - development team, applicant, CSS program capacity and property management capacity. Will points deducted be taken from those 16 points, or are there in fact 5 points available which can be lost for existing Revitalization grantees, making the total points available for prior HOPE VI grantees 21?
A25: The rating factor, section V.A.1.c, "Capacity of Existing HOPE VI Revitalization Grantees - Expenditures," applies to applicants that have received HOPE VI Revitalization grants for FYs 1993 to 2006. The rating factor, section V.A.1.d, "Capacity of Existing HOPE VI Revitalization Grantees - Timeliness," applies to applicants that have received HOPE VI Revitalization grants for FYs 1993 to 2003). For both of these rating factors, the "highest" (i.e., best) score such an applicant can get is zero. The maximum amount of points available for the entire Capacity section is 16, not 21.
Q26: Here is the language from the HOPE VI NOFA regarding an open audit finding. Will we lose this point because of our open audit findings?
A26: The rating factor found at Section V.A.1.b(3) is as follows: "IG Audit Finding � 1 point. As of the application deadline date, if an applicant has an open IG audit finding that relates to your capacity to implement a HOPE VI Revitalization grant, they will earn zero points for this rating factor. If an applicant does not have such an IG audit finding, it will automatically earn the one point. You will also receive zero points if your application does not address this factor to an extent that makes HUD's rating of this factor possible." As it says, the open IG audit finding would have to relate to the PHA�s capacity to implement a HOPE VI Revitalization grant. The determination of this is made by HUD after the deadline (the IG finding must be as of the application deadline date).
Q27: The rating factor in Section V.A.1.d (pages 120-121) bases the award of points on the number of years it took an existing HOPE VI Revitalization grantee to complete a HOPE VI Revitalization grant starting from the execution date of its HOPE VI Revitalization Grant Agreement. Are there any exceptions made to this for extensions HUD may have approved for the grant(s) in question?
A27: No. The "execution date of its HOPE VI Revitalization Grant Agreement" means the date on which the Grant Agreement was executed between the PHA and HUD (which is the date HUD signed the document executing Grant Agreement). The Grant Agreement is not the Revitalization Plan. Please note that this rating factor applies only to applicants that have received HOPE VI Revitalization grants for FYs 1993 to 2003. Applicants with HOPE VI Revitalization grants only from FY 2004-2008, or no existing HOPE VI Revitalization grants are not subject to this rating factor.
Q28: Section V.A.1.b(1) (page 118) is the rating factor on Public Housing Assessment System (PHAS) and Section V.A.1.b(2) (page 118) is the rating factor on Section 8 Management Assessment Program (SEMAP). The both state that if the applicant has been rated as an Overall High Performer for the most recent PHAS/SEMAP review as of the application deadline date, the applicant will receive 2 points. It goes on to state that MTW PHA applicants will be scored in accordance with their MTW Agreement. We are an MTW agency and no longer report on PHAS/SEMAP. What do we need to provide for this requirement?
A28: As indicated in the NOFA, the PHA will be assessed based on what their MTW Agreement said at the time of the application deadline date (which is November 17, 2009) regarding PHAS/SEMAP (e.g., whether or not the PHA is scored, what its designation is, etc.). Applicants can also provide information on this in their narrative (Exhibit B) as indicated in section IV.B.8. e(3)(b) (page 97) which provides the following guidance: "(b) Capacity of Applicant. Respond to Rating Factor V.A.1.b."
Q29: The FY09 NOFA indicates 2 points for the SEMAP rating (page 118), which has to do with Section 8 voucher utilization, but not all housing authorities handle their own vouchers (e.g., the county may handle the voucher). There are also 3 points given for committing to certain criteria when doing relocation (page 143), but not all HOPE VI projects require relocation. Can you please explain what happens to these points if they don�t apply to a project?
A29: SEMAP rating factor:
If the applicant (the PHA) itself does not have/manage a Section 8 program, then it cannot earn the points. This is because of the following reasons. The "Section 8 Management Assessment Program (SEMAP)" rating factor is part of the overall "Capacity of Applicant" rating factor section (section V.A.1.b, page 118). The purpose of the overall "Capacity of Applicant" rating factor section is defined as follows: "This rating factor looks at the capacity of ONLY the applicant." That is, it is about the capacity of the PHA, not any other team member or area organization. This means for the SEMAP rating factor, that if the applicant does not have/manage Section 8, then it does not have that capacity and cannot earn points under the SEMAP rating factor. Specifically, the language of the rating factor focuses on the PHA: "If you [i.e., the PHA] have been rated as a High Performer for your [i.e., the PHA's] most recent SEMAP (or successor system) rating as of the application deadline date, you will receive...."
Relocation rating factor:
Section V.A.7 (page 142) is the Relocation rating factor and states in the opening paragraph: "For all applicants, whether you have completed, or have yet to complete, relocation of all residents of the targeted project, your HOPE VI Relocation Plan must include the three goals set out in section 24 of the 1937 Act, as described in sections a.(1), a.(2), and a.(3) below." Since the criteria states, "whether you have completed...," this means that the rating factor criteria in sections V.A.7.a.(1), a.(2), and a.(3) still apply in order to earn the full points. If relocation has already been done for the site, then the applicant should describe how the relocation plan used at the time of relocation met the criteria in sections V.A.7.a.(1), a.(2), and a.(3).
Q30: The NOFA, section V.A.2.d (page 126) specifies the following: "d. Need for Affordable Accessible Housing in the Community -- 3 Points. Your application must demonstrate the need for other housing available and affordable to families receiving tenant-based assistance under Section 8 (HCV), as described below and must be the most recent information available at the time of the application deadline...." What date should PHAs use for the measurement of the HCV and Public Housing utilization that is described?
A30: The NOFA language states, "...the most recent information available at the time of the application deadline...." This means most recent information available as of November 17, 2009.
Q31: The NOFA indicates that Collateral Resources can include past and planned projects. If a physical redevelopment activity that would qualify as a Collateral Resource was completed within the past 10 years, would this be accepted by HUD?
A31: The NOFA language for the Collateral Investment Leveraging rating factor appears in
Section V.A.3.e (page 132):
"e. Collateral Investment Leveraging -- 2 Points. Collateral investment includes physical redevelopment activities that have taken place in the past or will be completed within the term of the proposed HOPE VI Revitalization grant, and that will directly enhance your proposed HOPE VI Revitalization Plan. This relationship must be demonstrated in your application. These activities may be outside of your Revitalization Plan (as defined in the Definitions section of this NOFA). However, these activities will occur whether or not a Revitalization grant is awarded to you and the targeted public housing project is revitalized. This includes economic or other kinds of development activities that would have occurred with or without the anticipation of HOPE VI funds. These resources cannot duplicate any other type of resource and cannot be counted as match. Examples of collateral investments include local schools, libraries, subways, light rail stations, improved roads, day care facilities, and medical facilities. See section III.C.3, Program Requirements, and �Program Requirements that Apply to Match and Leverage� for resource and documentation requirements. These requirements MUST be followed as relevant in order to earn points under the leverage rating factor. "HOPE VI funds requested for physical development activities� is defined as your total requested amount of funds minus your requested CSS, administration amounts, and relocation. HUD will presume that your combined CSS, administration, and relocation amounts are the total of Budget Line Items 1408 (excluding non-CSS Management Improvements), 1410, and 1495 on the form HUD-52825-A, "HOPE VI Budget," that is included in your application.
(1) You will receive 2 points if the ratio of the amount of HOPE VI funds requested for physical development activities to the amount of your documented collateral resources is 1:1.0 or higher.
(2) You will receive zero points if the ratio of the amount of HOPE VI funds requested for physical development activities to the amount of your documented collateral resources is less than 1:1.0."
While the rating factor does not contain specific limitations on the age of a resource, it requires that the activities "will directly enhance your proposed HOPE VI Revitalization Plan. This relationship must be demonstrated in your application." Further, it must be that the activities will occur whether or not a Revitalization grant is awarded and the targeted public housing project is revitalized. Also be aware of the requirements under, Section III.C.3.jj, "Program Requirements that Apply to Match and Leverage" (starting on page 71): "(e) Dating. Match and leverage commitment letters must represent valid and accurate commitments. By including them in the application, the applicant is certifying that they are valid and accurate. Commitment letters must indicate that they are for the FY 2009 HOPE VI Revitalization application round or must be dated after the FY 2009 NOFA publication date."
COMMUNITY AND SUPPORTIVE SERVICES
Q32: Page 135, Section V.A.5.c is the Transition to Housing Self-Sufficiency rating factor. Is it necessary to limit the time families (except elderly/disabled) may remain in public housing units in order to be eligible for maximum points for housing self-sufficiency?
A32: No. The NOFA does not contain criteria requiring time limits.
EARLY CHILDHOOD EDUCATION
Q33: How any points are available for the Early Childhood Education Rating Factor in Section V.A.6?
A33: The Early Childhood Education Rating Factor is Section V.A.6 of the NOFA (beginning on page 137). The maximum amount of points available is 5 points. The first two points are available in Section V.A.6.d (page 139), "Existing Neighborhood Strengths - Early Childhood Education." The other three points are available in Section V.A.6.e (page 140), "Quality and Results Orientation � Early Childhood." The three points available under Section V.A.6.e, "Quality and Results Orientation � Early Childhood," are broken into two parts:� one point under Section V.A.6.e(3) "Pre-Revitalization/Relocation" and two points under Section V.A.6.e(4) "Post Revitalization." Please note that Section V.A.6.e(1) and Section V.A.6.e(2) are introductory criteria that apply to Section V.A.6.e (3) and (4).
Q34: For the rating factor in Section V.A.6.e.(4), "Quality and Results Orientation - Early Childhood Education, Post-revitalization" (starting on page 141) what is the percentage amount for the enrollment goal?
A34: Sixty-five percent. Section V.A.6.e.(4) was included in the technical corrections to the NOFA that were posted on October 15, 2009. The correction related to the "Quality and Results Orientation - Early Childhood Education, Post Revitalization" Rating Factor clarifies that the early childhood educational program should include intensive community outreach with a goal of enrolling at least 65 percent, not 75 percent, of the families with children ages zero to five that will occupy the revitalized site. �The full technical corrections document is available on the HUD website at www.hud.gov/hopevi and http://archives.hud.gov/funding/2009/grphopevirevi.cfm, and on the www.Grants.gov website.
Q35: I am looking for the definition of "Neighborhood Strengths Institution" and can't seem to find it. Do you happen to have the definition?
A35: The term "Neighborhood Strengths Institution" is used in the rating factor under section V.A.6.d (pages 139-140), as follows:
"d. Existing Neighborhood Strengths - Early Childhood Education (up to 2 points)
(1) This rating factor addresses the presence of a strong, anchor institution in your community that provides high-quality early childhood education to local children. You will receive two points if you describe in your narrative, and provide an executed memorandum of understanding (MOU) from, a Neighborhood Strengths Institution that provides a comprehensive, high-quality, results-oriented local early childhood education program such as described in paragraph b. of this rating factor. (While it is permissible for a PHA to have an MOU with more than one Neighborhood Strengths Institution, only one is required to earn points under this rating factor). (For more information on neighborhood strengths, see Section V.A.10.c, �Neighborhood Strengths, Impact and Sustainability of the Revitalization Plan.�) You are encouraged to consider accreditation by the National Association of Education of Young Children (NAEYC) as an indicator of quality. The program may be housed within or run by a local school. In order to receive full points, the identified program should include a parental involvement component, parental supports either on-site, through partners, or in the homes of participating families and other learning supports such as connections to health and nutrition programs to address the needs outlined in the needs assessment. Also, in order to receive full points, the narrative must demonstrate that the program is high-quality with a proven track record of positive outcomes, and the MOU must (a) commit to outreach to and enroll current and future CSS-eligible families and other non-public housing families in the revitalized neighborhood; and (b) commit to work with the Community Task Force as a lead neighborhood partner throughout the HOPE VI grant. This program/institution may be the same as that named below in the Quality Results and Orientation Post-Revitalization rating factor. ..."
This section, paragraph (1) states: �For more information on neighborhood strengths, see Section V.A.10.c, �Neighborhood Strengths, Impact and Sustainability of the Revitalization Plan.�� Accordingly applicants should refer to Section V.A.10.c (pages 156-157) which is titled, �Neighborhood Strengths, Impact and Sustainability of the Revitalization Plan.�). The information in Section V.A.10.c (1)(a) constitutes the definition of neighborhood strengths institution:
"c. Neighborhood Strengths, Impact and Sustainability of the Revitalization Plan - 4 Points
(1) You will receive up to 4 points if your application demonstrates your overall Revitalization Plan for the targeted public housing project will do the following (a)-(e). To earn the full 4 points, the application must demonstrate all the criteria showing a high level of neighborhood impact and sustainability of the Revitalization Plan. Points may be deducted for failure to do so and for lack of specificity.
(a) Result in a revitalized site(s) that will enhance the surrounding neighborhood in which the project is located by building on the strengths of the surrounding neighborhood. Applicants must describe these existing neighborhood strengths in their application and how they will contribute to a revitalized site(s) that will enhance the surrounding neighborhood. For purposes of this NOFA, neighborhood strengths are considered any existing asset that will help transform the neighborhood into a functioning, sustainable, mixed income community. In general neighborhood strengths consist of institutions, organizations and businesses which serve as anchors in the community, providing jobs, services and economic benefits. They also can consist of neighborhood amenities, such as good schools, community centers and recreation centers; easy access to public transportation, parks and playgrounds, hospitals, health clinics, supermarkets and other retail uses; ..."
GREEN DEVELOPMENT AND ENERGY EFFICIENT STRATEGIES
Q36: Rating factor V.A.10.g, Green Development and Energy Efficient Strategies, says that if applicants pursue a green rating program that requires a third-party certification, the applicant must provide evidence of such certification in the application. Since the third-party certifications are not completed until after construction is complete, what documentation will HUD accept in Attachment 35 of the grant application to document green development strategies and earn the 6 points for green development?
A36: Applicants do not have to provide a third-party certification regarding the completed units at the time of application. This issue was also addressed in the technical corrections to the NOFA that were posted on October 15, 2009. The full technical corrections document is available on the HUD website at www.hud.gov/hopevi and http://archives.hud.gov/funding/2009/grphopevirevi.cfm, and on the www.grants.gov website. Regarding this question, it corrected section V.A.10.g to read as follows:
"g. Green Development and Energy Efficiency Strategies � 6 points. HUD is encouraging development that increases resource efficiency, reduces green house gas emissions and promotes healthy living environments for residents. Applicants may earn points under one of the following paragraphs, (1), (2), or (3), for a maximum of 6 points. Applicants must respond to the respective rating factor below in their narrative. Attachment 35 is available if applicants need space in addition to their narrative to respond to this rating factor.
(1) Green Development (6 or 0 points). Applicants that certify and demonstrate that they will implement green development in their HOPE VI program, if funded, are eligible to receive 6 points for undertaking green development strategies. These points are available to applicants that certify that and describe how they will fulfill the requirements of one of several recognized green rating programs, including: Enterprise Green Communities Criteria; the National Association of Home Builders (NAHB) Green Building Guidelines; Leadership in Energy and Environmental Design (LEED) for Homes (for single family) or LEED New Construction (for multifamily); or Earthcraft in the design and construction of their project. For green programs that require third-party certification, the applicant, if funded, must provide evidence of such certification after construction of the units. For green programs that require self-certification, the applicant, if funded, must provide evidence of self-certification, such as the Enterprise Green Communities Checklist. In order to earn the 6 points, applicants must describe and certify to their plan to implement green development in their HOPE VI program, if funded, in the narrative of their application. You will receive zero points if your application does not demonstrate these criteria, or if your application does not include sufficient information to be able to evaluate this factor."
Q37: Project Based Vouchers. We understand that information on any Project-Based Affordable Housing (section V.A.9.a), including project-based voucher assistance, needs to be discussed in the application�s narrative, and that project-based voucher assistance alone cannot earn the one point available under section V.A.9.b, "Off-Site Housing" (page 152: "This point cannot be earned if the only off-site activity you propose is project-based voucher assistance, second mortgage assistance or Section 32"). We also understand that the project-based vouchers are not required to have documented site control (section III.C.2.b(10), page 29: Site Control. If you propose to develop units (the threshold does not apply to the usage of project-based vouchers, second mortgage assistance, and Section 32) off-site...."). What level of documentation, if any, is required for the HOPE VI Application for the inclusion of a property/project using project-based vouchers as a part of the overall HOPE VI Revitalization Plan for the Project-Based Affordable Housing 1 Point and the Off-Site Housing 1 Point?
A37: The rating factors, Project-Based Affordable Housing and Off-Site Housing, must be addressed in the narrative as indicated on in section IV.B.8.e(10) (page 99, excerpt copied below). There is not additional documentation required by the NOFA related to project-based vouchers.
"(10) Exhibit I. Mixed-Income Communities. Verify that you have included information relating to the following:
(a) Public Housing Replacement Requirement. Respond to the threshold requirement in Sections III.C.2.b(21).
(b) Project-Based Affordable Housing. Respond to Rating Factor V.A.9.a;
(c) Off-Site Housing. Respond to Rating Factor V.A.9.b;
(d) Low-Income Housing Tax Credit Units. Respond to Rating Factor V.A.9.c.
(e) Market Rate Housing Units. Respond to Rating Factor V.A.9.d."
Q38: The NOFA, section V.A.9.a(1)(a) �states the following: Project-based affordable housing units� are defined as on-site and off-site housing units where there are affordable-housing use restrictions on the unit, e.g., public housing, project-based HCV (Section 8) units, LIHTC units, HOME units, affordable homeownership units, etc. �Units already completed, as of the application deadline, may not be counted.� What does the phrase, �Units already completed� mean?
A38: The criterion is as stated, that the units are already completed. That is, the units are physically completed. It does not relate to financing and that units have converted from construction financing to permanent financing.
Q39: On page 152, Section V.A.9.c(1): "For purpose of this rating factor, LIHTC units do not include public housing or project-based assistance (the only subsidy is the tax credits), thus creating affordable rental units at 60%AMI." To qualify for points in this Rating Factor, is it required that the LIHTC units be restricted at 60% AMI or can they be restricted at a lower AMI?
A39: The LIHTC units can be restricted at a lower AMI. �The sentence, "For purposes of this rating factor, LIHTC units do not include public housing or project-based assistance (the only subsidy is the tax credits), thus creating affordable rental units at 60% AMI" does not mean that the tax credit units are restricted at only 60% AMI. They can they be restricted at a lower AMI. The intent of the rating factor is to incentivize having LIHTCs units that do not include public housing or project-based assistance in the revitalization plan (as part of creating mixed income communities).
Q40: Can I submit my application in paper form?
A40: No. All applications must be submitted electronically through Grants.gov. See Section IV of the NOFA, "Application, Submission and Timely Receipt Information," for more information on the submission process and Grants.gov.
Q41: Are the page limit requirements different for the FY2009 HOPE VI Revitalization NOFA?
A41: Yes. The FY 2009 NOFA indicates in section IV.B.8.b that each HOPE VI Revitalization application must contain no more than 115 pages of narrative exhibits and no more than 135 pages of attachments. Note there are some exceptions to the page limits as stated in section IV.B.8.b(3).
Q42: Is there a way I can check if I am doing the calculation correctly for the threshold requirement in Section III.C.2.b(21), " Public Housing Replacement Requirement"?
A42: HUD is providing an optional tool (MS-Excel) which applicants can use to check their calculation. This optional tool is provided for potential applicants to use if they wish as they develop their response to the Public Housing Replacement Requirement threshold in Section III.C.2.b(21) of the FY 2009 HOPE VI Revitalization NOFA. Use of this tool is optional and is not required. This optional tool is not to be submitted as part of the application.
Q43: Where do I respond to the threshold requirements in Sections III.C.2.b(11), (12), (13), (14), (15), (16), (17), (18), and (19).
A43: Applicants must respond to these threshold requirements (e.g., Compliance with Fair Housing and Civil Rights Laws, Delinquent Federal Debts, etc.) in their narrative exhibits. These thresholds are incorporated from the FY 2009 General Section. As stated in the instructions in section IV.B.8.b(12) on page 100, "(12) Exhibit K. General Section Threshold Requirements Narratives. Respond to the threshold requirements in Sections III.C.2.b(11), (12), (13), (14), (15), (16), (17), (18), and (19)."
Last modified: November 4, 2009