Questions and Answers
41. Section XII(B)(4)(b) says that applicants can earn two points if the targeted severely distressed public housing site is cleared. Can we earn the two points if we are only doing rehabilitation and not demolishing any units?
Yes. Applicants whose Revitalization Plan only includes rehabilitation and no demolition of public housing units will be able to earn these two points. Please see the technical correction to the NOFA addressing this matter, as published in the Federal Register on December 9, 2004.
FAQs #42-43 posted on December 12, 2003
42. Are there estimated dates (e.g., grant award, grant agreement execution) we must use in making our program schedule in accordance with IV(B)(1)(b)(i)(C)?
No, you are not required to use specific dates for purposes of the schedule required for the threshold at Section IV(B)(1)(b)(i)(C). Rather, it is essential that applicants ensure their program schedule follows the revitalization grant implementation requirements of Section XVI(C). Applicants should clearly indicate on their program schedule the estimated dates they are using. However, HUD suggests the use of the following dates for the sake of consistency.
Grant award - March 30
Grant Agreement execution - May 30
HUD's written request for Supplemental Submissions - June 30
HUD's approval of Supplemental Submissions - September 30
43. If the housing authority forms a development entity with the City, is the housing authority still considered to be a self-development entity for purposes of the NOFA Section IV?
No, the housing authority would not be considered to be a self-development entity. It would need to enter into an intergovernmental agreement or partnership agreement to establish the development entity.
FAQs #44-66 posted on January 7, 2004
44. Do we have to submit a DUNS number with our application?
Yes. In accordance with the technical corrections published in the Federal Register on December 9, 2003, all applicants for FY 2003 HOPE VI Revitalization funding must submit a DUNS number with their application. It may be included in the application on a separate sheet of paper and will not be counted toward the page count. You may find the technical corrections at the FY 2003 Funding Information webpage below.
http://www.hud.gov/offices/pih/programs/ph/hope6/grants/fy03/index.cfm
45. Is the Acquisition Proposal referred to in the NOFA under Section I(G)(4) due with the application or post-award?
An acquisition proposal is not required as part of the application. Section I(G)(4) means that before a PHA undertakes acquisition activities they must submit the proposal to HUD in accordance with 24 CFR 941.303. However, site control of off-site properties for housing developed is required in accordance with Section XI(B)(4).
46. Do we have to submit a certification related to the Code of Conduct with our application?
Yes. In accordance with Section (II)(B)(27), each applicant must include a certification that, if awarded funds under the FY 2003 HOPE VI Revitalization NOFA, they as the grantee will submit a copy of their Code of Conduct prior to entering into an agreement with HUD. This certification may be in the form of a letter and may be placed in the application behind the HOPE VI Revitalization Applicant Certifications form at Attachment 37.
47. The threshold requirement at Section III(D)(6) says that, "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 or other HUD funds…." Does "other HUD funds" apply to modernization work and capital improvements done at the development using CGP or Capital Funds (such as upgrades to kitchens and baths, roof work, replacement of sewers/laterals).
No. The threshold at Section III(D)(6) does not refer to modernization funding or Capital Fund Program funding (i.e., CGP, etc.). Rather, as explained in FAQ #24, you may not apply for funds for units where you have received HOPE VI Revitalization funding, MROP funding and other funds under the Development Program, as those funds were intended to achieve significant revitalization of units, as opposed to regular upkeep.
48. Is it necessary to include in the application a certification that the revitalization plan is consistent with the consolidated plan?
No. A certification that the revitalization plan is consistent with the consolidated plan is not required as part of the application. However, applicants must address whether the proposed revitalization plan has been incorporated into their most recent PHA Plan in accordance with the rating factor at Section IV((B)(5).
49. Can the Overall Match be comprised of both match for CSS
& Development resources?
Yes, but you still must be able to demonstrate the CSS match on its own in accordance with Section VI(A)(2) and (7).
50. Can the match be counted as part of the leverage for both CSS and Development?
Yes. HUD reviews the match threshold separately from the leverage rating factor. Assuming that the application demonstrates that the match threshold requirement of Section VI(A)(7) has been met, and it passes all other threshold requirements, HUD then evaluates the resource documentation for scoring purposes under Section VI(H). Assuming that resources you have documented for leverage meet the necessary requirements for leverage (Sections VI(B)-(H), as relevant), then they may also be counted for purposes of the leverage rating factor, in addition to having been used in relation to verifying the match threshold. CSS leverage may only be used for CSS leverage and Development resources may only be used for Development leverage.
51. In the NOFA Section VI(D)(1)(c), it says, "If you have obtained a construction loan but not a permanent loan, the value of the acceptably documented construction loan will be counted as leverage." Does that mean if we use HOPE VI as security on a construction loan that gets paid back at the end of the construction period, we will be able to count the entire amount of the construction loan as a development resource in our development leverage calculation?
If the construction loan is paid back with HOPE VI funds then no, the construction loan would not be counted as leverage. This would be because you would not actually be leveraging new funds, i.e., bringing more money (non-HOPE VI) to the deal. Rather you would be postponing the use of your HOPE VI funds. If the construction loan is paid back with a non-public housing source of funds, then the construction loan would be included as leverage.
52. Section VI((D)(5) states that downpayments from homebuyers
may not be counted as a type of development resource. If downpayment
assistance is provided by an organization, not a homebuyer, can
the amount of downpayment assistance provided be counted as a type
of development resource?
Yes, downpayment assistance may be counted as a physical development resource if it is provided by an organization (not a homebuyer). This resource commitment must be properly documented in accordance with Section VI(C).
53. Under Section VI(D)(12) , will we be disqualified if we
propose the use of tax credits and do not yet have these tax credits
reserved?
No. Leveraging is evaluated in the NOFA as a rating factor not a threshold requirement. If an applicant does not have documentation from their state or local housing finance agency demonstrating that low-income housing tax credits proposed in their revitalization plan have been reserved, the application will not be disqualified. However, those proposed equity amounts , regardless of phase, would not be considered in the point calculations under rating factor Section VI(H)(1) (Development Leveraging).
54. Can the Anticipatory Leverage and Collateral Leverage be
comprised of both CSS and Development resources?
No. As Section VI(H)(3) and (4) state, these resources (anticipatory and collateral) cannot duplicate any other type of resource (i.e., CSS or Development) and cannot be counted as match.
55. The County began work in 2000 on some municipal projects,
such as roads and bridges, in anticipation of a HOPE VI Revitalization
grant award in 2000 and again in 2001. Though the applicant was
not awarded a grant in those years, the work continued on one of
these projects until completion. Would the completion of this count
as a collateral investment?
In order to receive the points for collateral resources under Section VI(H)(4), an applicant must be able to show that the physical redevelopment activities are underway or projected to be completed before October 2008 and that they will enhance the HOPE VI community. However, in order to be counted as collateral investments, these activities must occur whether or not the public housing project is revitalized. Applicants should also note that the resources they cite as collateral investment cannot duplicate any other type of resource. In the above example, if the work meets the definition of collateral investment, and has already been completed, it may be counted as collateral investment.
56. Are there any submission requirements due at the time of
application related to appraisal or title review of properties proposed
to be acquired for the purposes of development pursuant to the Revitalization
Plan?
No, documentation on appraisals and titles are not required as part of the application. However, applicants must provide proper evidence of site control to meet the threshold at Section XI(B)(4). Examples of acceptable site control evidence are described in that section.
57. The City will be providing land to the housing authority
for off-site housing but does not provide options on their property.
However, we will have an ordinance approved by the City council
that approves the sale of the land to the housing authority for
the HOPE VI program. Is this an acceptable form of site control
to meet the threshold under Section XI(B)(4)?
Yes. An ordinance is acceptable as evidence of site control if it approves the sale of the land and is only contingent on the factors in the NOFA under Section XI(B)(4).
58. If we proposed a community center on site where the management
office will be located, and specific CSS programming will occur,
do we need the market assessment letter to discuss the demand for
this facility and associated pricing structure?
The market assessment letter required under Section XI(C) only needs to address a community facility if that facility is market driven, e.g., a YMCA. A community facility that is primarily intended to facilitate the delivery of community and supportive services for residents of the targeted severely distressed public housing project and of off-site replacement housing does not need to be addressed in the market assessment letter.
59. We think that a small retail structure should be built on
one part of the site. However, we are not putting a budget in for
the construction/development of this structure. Instead, the land
itself will be put in a land bank for the potential future construction
of a retail facility funded maybe through the proceeds generated
from the development itself or some other source of funds. In this
situation, do we need to get a preliminary market assessment letter
that assesses the demand for this facility and associated pricing
structure even though we are not really including it as part of
our program?
If you include it as part of your proposal in the application, then it should be addressed in some manner in the market assessment letter required under Section XI(C).
60. If we use tables in our narrative exhibits, can they be
single-spaced?
Anything in the narrative section must be double-spaced, whether in paragraphs or in tables. Any page that equate to single spacing will be counted as two pages in accordance with the NOFA Section XIII(B)(1).
61. Can you explain the "n/a" requirement at Section
XIII(B)(6)?
Section XIII(B)(6) states that, "If a Section is not applicable, omit it; do not insert a page marked n/a." This means that if a particular NOFA criteria does not apply to an applicant, it is not necessary to insert a separate page indicating, "n/a," or "not applicable." Applicants will not be penalized (i.e., it is not a threshold requirement or a rating factor) for including an "n/a" page for an attachment or writing "n/a" for relevant parts of the narrative exhibits, except in regard to the page count. That is, the applicant must still meet the page limit requirements defined under Sections XIII(A)(1)(b) and XIII(A)(2)(b). Individual pages labeled with "n/a" will be counted toward the page limits, unless the page is included for a section otherwise omitted from the page limits, in accordance with Section XIII(A)(3).
62. Section XIII(B)(7) says that no material on tabs for exhibits or attachments will be considered for review purposes, although pictures are allowed. Can pictures be labeled with text, or will that be counted against the page limitation?
If a tab contains a picture with an identifying text label, it will not count toward the page limit. Tabs are not counted toward the page limits and serve only a functional purpose to identify different sections of the application, not as a vehicle for transmitting additional information. In accordance with Section XIII(B)(7), no material on the tabs will be considered as part of the review. Anything that the applicant wants considered must be part of the narrative pages or attachment pages.
63. Section XVI(C)(5) states that, "Grantees must submit
the development proposal for the first phase of construction within
12 months of grant award. The program schedule must indicate the
date on which the development proposal for each phase of the revitalization
plan will be submitted to HUD." What is meant by development
proposal?
For purposes of the NOFA, "development proposal" refers to whatever the first phase of activity (i.e., development) will be in your revitalization plan, whether it is a mixed-finance development proposal, a homeownership development proposal, etc.
64. Section XVI(C)(6) states that, "The closing of the
first phase must take place within 15 months of grant award."
Does "closing" refer to a financial closing or that the
all activities for the first phase have been completed?
For purposes of the NOFA, "closing" means all financial and legal arrangements have been executed and that the actual activities (construction, etc.) are ready to commence.
65. Do we have to provide conceptual floor plans of replacement
units as part of the HOPE VI application?
No. The FY 2003 HOPE VI Revitalization NOFA does not require floor plans to be submitted in the application.
66. The site we are targeting has already been approved for
demolition and the buildings are currently being demolished. By
the time the application will be submitted, all of the buildings
will have been demolished. What should we show for Attachment 32?
Should we just show the boundaries of the site and just say that
all of the buildings have been demolished so there is no current
site plan per se to speak of? Or should we take an old site plan
that has the buildings that were demolished on it, and mark that
up accordingly?
The attachments serve to support your narrative arguments. So in the case of Attachment 32, its intent is to demonstrate the site plan of the targeted site and thus ultimately why the funds are needed. To this end, applicants should be as clear as possible. If the applicant were to include the original site plan, pre-demolition, they would want to clearly indicate (as they would have in other parts of the application) that these units will have been demolished as of ___ date.