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Community Development Block Grant Disaster Recovery “Ike” Program Illinois Affordable Rental Housing Program Component: Public Housing Rehabilitation
Frequently Asked Questions
The Illinois Housing Development Authority (the Authority) has developed the following to respond to questions raised at the Community Development Block Grant (CDBG) Disaster Recovery “Ike” Program Public Housing Rehabilitation application workshop on March 16, 2011, and via phone and email since that date.
Minimum/Maximum Funding Amounts
Q: How will the Authority determine whether to fund a project that requires funding below or above the funding limits as described on page 7 of the Request for Applications?
A: The applicant should document the extenuating circumstances in its actual application, via a narrative. The scope of work and physical needs assessment should support any claims that the extent of work necessary will either result in a low or high funding request.
1. Definition of a Project
Q: What is considered by the Authority to constitute a project? Any of the following may constitute a project:
• any site or sites covered by a single Asset Management Project number
• any site or scattered sites that share a name (for example, Spring Valley Apartments) • any activity covered under a single application (for example, new windows in all units)
Regardless of the combination of units and sites submitted as a project, the project’s scope of work should address critical/immediate physical needs and CDBG Disaster Recovery program priorities for all sites included in the project, and submit mandatory application items that cover all sites in the project. For the latter, this means that a project with multiple sites must submit PNAs, floodplain maps, etc. for every site included in the project. The Authority reserves the right to adjust funding levels in order to address physical needs and CDBG Disaster Recovery program priorities across projects and make the best use of CDBG funds.
2. Zoning and Environmental
Q: If the project’s locality has no zoning administrator, who can provide the mandatory zoning letter described on page 13 of the Request for Applications?
A: If there is no zoning administrator, the letter must come from the chief local elected official (examples: mayor, county chief/executive or his/her designee such as city/village manager).
Q: Can floodplain maps acquired in 2010 be submitted to comply with the floodplain map requirements described on page 14 of the Request for Applications?
A: The FEMA floodplain maps required by the Authority can be downloaded for free at http://msc.fema.gov. Therefore, all applicants should submit the most up-to-date version found at this site. Follow these steps:
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2. In the Product Search By box on the upper left of the page, choose Flood Maps and enter the address of the site (if your project has multiple sites, you may have to follow these steps for each site, depending on how far the sites are from one another). Click Search by Street Address.
3. A list of FEMA Issued Flood Maps will appear – likely only one will be available, since you used a search by address rather than by a larger area. Click on the icon under the word View.
4. Depending on your internet connection, it may take a few moments for the resulting map to appear. Once the map appears, look to the left of the page and click Make a FIRMette.
5. A shaded box will appear in the upper left corner of the map. Left click and drag it until it covers the site location(s). To the left of the map, choose letter or legal size paper, then choose either Adobe pdf or Image File.
6. A new map will appear that is zoomed in on the area you chose. Click Save Your FIRMette. If a window pops up asking you to open or save, make sure you save the file so you don’t have to repeat all these steps. Save a copy onto your computer, preferably with the project name as part of the new file name. 3. Development Team and Unacceptable Practices
Q: How are we to describe capacity for all development team members as described on page 17 of the Request for Applications, if we will be required to go through a public procurement process to select team members? A: Describe the roles and experiences of those organizations and individuals you know will be involved, as of the time of application submittal. On an individual level, this should include individuals within the Public Housing Authority that are likely to be instrumental in project completion and management, inspections, payouts, grant management, etc.
Q: My PHA is currently listed by HUD as “Troubled.” Does this mean that my application will not be eligible, as described on page 17 of the Request for Applications?
A: In your application submission, include an explanation of the circumstances surrounding this designation. The Authority will consult with HUD, and then determine whether the application is eligible, and whether troubled PHA issues can be cured in a timely manner.
4. Scoring Category: Addressing Damage Caused by Natural Disasters
Q: My project consists of scattered sites. The sites that were damaged by natural disasters have already been repaired using other funds – funds that would otherwise have been used for planned capital improvements. Is my project eligible for points under scoring item A. Addressing Damage Caused by Natural Disasters, found on page 20 of the Request for Applications?
A: Because the damage caused by natural disasters has already been addressed, you will not be eligible for 30 points under this category; however, if your scope of work includes preventive improvements for mitigation of subsequent disasters of a similar nature, you MAY be eligible for 15 points, assuming the documentation you provide adequately supports the project’s eligibility.
Q: My project consists of more than one site, and a small percentage of the proposed scope of work addresses damage caused by natural disasters. Is my project eligible for points under scoring item A. Addressing Damage Caused by Natural Disasters, found on page 20 of the Request for Applications?
A: The Authority will look at the documentation you provide and may determine that a sliding points scale is needed for this category, based on the project’s scope of work and budget.
3 5. Fees and Matching Requirements
Q: Can we budget for a developer fee? A: No, a developer fee is not allowed.
Q: Can we budget for fees for staff functions related to the project completion and management?
A: The Authority will not allow administration fees; however, please take a look at the Budget spreadsheet on tab 6 of the CDBG Ike Program Public Housing Rehabilitation Application to get a sense of the development costs that are allowed. This CDBG funding will NOT pay for operating or management costs – it is strictly to be used for costs associated with development. In addition, CDBG program rules allow the State to determine the eligibility of incurring pre-agreement costs by grantees, but this is generally not allowed for application preparation costs. The Authority is also requiring a higher level of architectural work as part of the application submission materials. Given that there are federal procurement procedures that must be followed to hire an architect, do your best to estimate what costs will be incurred in the budget submitted at application. Please be aware that only grantees will be reimbursed for such services with grant funds, as reflected in the budget submitted at application, assuming federal procurement requirements have been met. Please review the Authority’s “Guidelines for Architectural Planning and Construction 2009,” as amended and found on the Authority’s website at www.ihda.org under Multifamily Programs Construction/Architectural Policies.
Q: Are there any matching requirements for the CDBG grant?
A: No, but other funds may be needed to complete scope of project. PHAs need to consult with HUD and the Authority if leveraging with PHA Capital Fund grants or other federal/state funds to avoid co-mingling of funds and future potential audit problems.
6. Physical Needs Assessment and Scope of Work
Q: For the Physical Needs Assessment submission requirement described on page 16 of the Request for
Applications, is a PNA in HUD’s format acceptable? If IHDA requires Grantees commission an updated PNA at a later date, can we use HUD’s format or must we use IHDA’s preferred vendors/format?
A: For the purpose of application submittal, two copies of your most recent PNA for the project in question will be acceptable. IHDA’s Architectural Services Department will review the PNA and determine whether an updated PNA will be required, and whether a different format will be necessary.
Q: Could this funding cover improvements not specifically mentioned in the Request for Applications, such as sidewalk and parking lot improvements?
A: Ancillary, CDBG-eligible improvements are acceptable, as long as they do not constitute the majority of the funding request. Please note, however, that the Authority’s priority will be addressing critical or immediate items identified in the physical needs assessment, as well as meeting the priorities of accessibility, energy efficiency and disaster mitagation.
Q: Page 7 of the Request for Applications includes the statement, “funding to be allocated will not exceed the amount necessary to make the project financially feasible." What does this mean?
A: Repairs/renovations should be those reasonably expected to complete the job. It should not include what are termed cosmetic repairs or improvements. As described on page 18 of the Request for Applications, it is
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mandatory that development budgets include a construction contingency line item to cover unforeseen construction costs (concealed conditions).
Q: Page 16 of the Request for Applications states that a PNA is needed for each site. Is the PHA required to identify its funding source for all of these repairs, especially those going out 5-7 years?
A: CDBG Disaster Recovery funding is not a recurring source. Applicants should select projects that are self-contained in terms of financing or that can be completed without being in jeopardy of being damaged due to needed follow-up work. It is assumed that future improvements to the project site or sites will be primarily funded via HUD's Capital Fund.
Q: Can an applicant just apply for window replacements to increase energy efficiency in a project? A: Yes, but the applicant should read over the Enterprise Green Communities Criteria 2008 to determine if window replacements alone will qualify the project for points in the Energy Efficiency and Sustainable Design criteria described on page 21 of the Request for Applications.
The Authority also recommends that applicants research Illinois Department of Commerce and Economic Opportunity’s (DCEO) Weatherization Assistance Program, which can now be used to assist rental properties, under which public housing and other federally-assisted rental properties have an expedited application process through local Community Action Agencies. See: http://iacaanet.org/.
Q: Do all of the improvements being done have to meet all of the Energy Efficiency and Sustainable Design criteria described on page 21 of the Request for Applications?
A: No – Energy Efficiency and Sustainable Design is not a mandatory item. However, an applicant seeking points under this category may choose to address one or more of the scoring items listed, by including the listed items in the project’s scope of work. If the applicant seeks points under this category, the project’s scope of work must address the selected items as a contingency of receiving funding.
Q: There is now a 2011 version of the Enterprise Green Communities Criteria, updated from the 2008 version referenced in the Energy Efficiency and Sustainable Design criteria described on page 21 of the Request for Applications. To which version should an applicant seeking points under this category adhere?
A: Please use the 2008 version, as described in the Request for Applications. 7. Post-Application Requirements
Q: Is a building permit mandatory if local code does not call for it for the type of work the applicant is doing? A: The Authority will work with the grantee to determine what type of documentation will be required if local code does not require a building permit for the project’s scope of work.
Q: The CDBG “Ike” Program page on the Authority’s website includes a Historic Preservation Checklist under the Public Housing Rehabilitation Program application materials list, but the Application Checklist does not list a Historic Preservation Checklist. Is the Historic Preservation Checklist required to be submitted at application? A: No. The Historic Preservation Checklist is a post-application requirement. During application review, the Authority will work with HUD to secure copies of the most recent letter from the State Historic Preservation Officer of the Illinois Historic Preservation Agency; however, up-to-date clearance letters must be obtained prior to funding approval by the Authority’s Board.
5 8. Application Review and Approval Timeline
Q: What is the timeline of review and approval of applications, notification of CDBG grant awards, and closing? A: Applications are due on May 2, 2011. Each application will be assigned a Project Identification Number and assigned to an IHDA Development Officer within a week. Applications will be reviewed for completeness (see the Application Checklist included on tab 1 of the CDBG Ike Program Public Housing Rehabilitation Application), then to determine whether it meets all the mandatory requirements described in the Request for Applications. Only those applications that meet mandatory requirements will be scored. Applications will be ranked according to score. Recommendations will be made to the Authority’s internal Loan Committee. A list of recommended projects will be transmitted to Illinois Department of Commerce and Economic Opportunity (DCEO) for review and concurrence.
PHAs with projects approved by the Authority’s Loan Committee will be notified and asked to submit certain documents required before applications are recommended for IHDA Board approval. It is estimated that these steps will be completed by end of August. Projects approved by the Authority’s Board will then go through a post-application period of due diligence, providing items listed in Section 3: Post-Application Requirements, found in the Request for Applications. Closing is generally expected to occur within 6 months of approval by the
