20. Section VI(B)(2) says a PHA must disclose
"all prior HUD public housing assistance received for the project(s)
you have targeted for the physical revitalization…." What categories
of information would that include and how far back must you go?
Section (VI)(B)(2) is a threshold requirement that requires applicants
to disclose all prior HUD public housing assistance received for
the project(s) targeted for the physical revitalization related
to the proposed revitalization activities. Accordingly, applications
must disclose any public housing funds they have received for
Capital Improvements as far back in time as possible.
21. Section V(G)(3)(c) says a PHA cannot use
HOPE VI funds to pay for non-public housing office facilities. Can
a PHA still use HOPE VI funds to pay for a rental office in a mixed-income
rental complex even if all of the units are not under an ACC?
Yes. A PHA can use HOPE VI Revitalization funds to pay for a
rental office in a mixed-income rental complex, even if all units
are not under an ACC, provided that the public housing residents
are still the primary beneficiaries.
22. What income guidelines apply to potential
homeowners who purchase homes that have been renovated with HOPE
VI funds prior to sale? Can HOPE VI funds be used to rehabilitate
public housing units for sale to low and moderate income families?
Can HOPE VI funds be used to rehabilitate public housing units for
sale as market units?
HOPE VI funds can be used to rehabilitate public housing units
for sale to low and moderate income families up to 80 percent
of median income, provided that the homeownership program is developed
in accordance with Sections 24 or 5(h)/32 of the U.S. Housing
Act of 1937. In accordance with Section VI(D)(7), HOPE VI funds
cannot be used to rehabilitate public housing units for sale as
market rate units which do not qualify as public housing or homeownership
replacement units. It should be noted that, in accordance with
Section I(C) of the NOFA, public housing agencies, not individuals,
can apply for HOPE VI Revitalization grant funding.
23. Section XIII(C)(2) says an applicant must
be "in full compliance with any desegregation or other court order
related to Fair Housing." Who defines "full compliance"?
HUD's Office of Fair Housing and Equal Opportunity (FH&EO) determines
compliance with any desegregation or other court order related
to Fair Housing, in accordance with the 2002 HOPE VI Revitalization
24. If a public housing site is no longer appropriate
for residential purposes, can all the replacement housing go into
a distressed neighborhood if the intention is to reinvest in minority
neighborhoods, improving the quality and affordability of housing
in the distressed neighborhood as a way to provide a real choice
for assisted households, as described in Section XIII(C)(3)(b)(ii)?
Yes, replacement housing can be developed in a distressed neighborhood,
provided that it is done in accordance with the site and neighborhood
standards stated at Section XIII(C)(3). Section XIII(C)(3)(e)
states HUD will consider the location of replacement housing,
on site or in the surrounding community, in assessing the application
for funding under the 2002 HOPE VI Revitalization NOFA.
Additionally, in accordance with Section XIII(C)(1), as a threshold
requirement, all applicants and their subrecipients must comply
with all Fair Housing and civil rights laws, statues, regulations
and executive orders as enumerated in 24 CFR 5.105(a). In accordance
with Section XIII(C)(2), as a threshold requirement, applicants
must be in full compliance with any desegregation or other court
order related to Fair Housing that affects their public housing
and is in effect on the application due date. In accordance with
Section XIII(C)(3)(c), applicants comply with the Fair Housing
Act and Title VI of the Civil Rights Act of 1964, and implementing
regulations, in determining the location of any replacement housing.
25. Could you explain in more detail the term
"area of minority concentration," as described in Section XIII (Fair
Housing and Equal Opportunity) (C)(3)(g).
HUD believes that Section XIII of the NOFA provides sufficient
criteria and references to define the term "area of minority concentration."
26. When discussing leverage, HUD requires
applicants to have firm commitments. Can HUD define "firm"?
Firm commitments must be evidenced by a written agreement, to
provide specific amounts of cash, signed by an official legally
able to make the commitments on behalf of the organization. The
written agreement may only be contingent upon receiving a HOPE
VI grant award.
27. Section IX(A)(5) says, "Grantees must pursue
and enforce any commitment (including commitments for services)
obtained from any public or private entity for any contribution
or commitment to the project or surrounding area that was used for
leverage in their HOPE VI applications." How does HUD suggest this
HUD believes Section IX(A)(5) is self-explanatory. Grantees are
expected to pursue and enforce commitments that were obtained
in a reasonable and justifiable manner.
28. Section IX(D)(6) discusses types of resources
that may be counted as leverage. It says, "Funds committed to build
private sector housing in direct connection with the HOPE VI Revitalization
Plan" may count. Can you explain this further?
In accordance with Section IX(D), types of development resources
that may be counted as leverage include funds committed to build
private sector housing in direct connection with the HOPE VI Revitalization
Plan. This would mean that the development of the private sector
housing will occur as a direct result of the proposed HOPE VI
29. In Section IX, could you clarify how cash
and in-kind services can be used in order to count towards the match?
Match requirements as described in Section IX (A) is limited
to cash. Leverage and other resources described in Section IX
(B) - (F) is not limited to cash and may include in-kind services
and other types of contributions such as tax credits.
30. Must a mixed-finance proposal be submitted
for HUD review before the HOPE VI Revitalization application is
due? Must a homeownership proposal be submitted for HUD review before
the HOPE VI Revitalization application is due?
No, a mixed finance proposal or homeownership proposal should
not be submitted to HUD prior to the application.
31. Are design principles of New Urbanism still
a part of the HOPE VI Revitalization Program?
Applicants should consult the NOFA for criteria related to design.
The concepts of New Urbanism, though not specifically named in
this NOFA, remain principles of design in the HOPE VI program.
32. Can replacement units be a different size
than the units being replaced?
Yes, replacement units can be a different size than the units
33. Under Section XV(B)( 3), the NOFA indicates
that the applicant will receive 1 point "if you have held 5 or more
public planning sessions leading to resident acceptance of the Plan."
In Section X(A)( 2), the NOFA requires applicants to hold at least
one training session and, in Section X(A)(3), at least three public
meetings to involve residents and stakeholders in developing the
Plan. Do the public meetings count toward the 5 public planning
Yes, the three public meetings required by Section X(A)(3) may
count toward the five public planning sessions, as would the one
training session required by Section X(A)(2). These are threshold
requirements and must be certified to in order to be considered
for funding. In order to receive the one point possible at Section
XV(B)(3)(e), you must be able to demonstrate that you have held
five or more public planning sessions.
34. Does Section VII (A)(6)(b) mean that an
applicant must formally comply with 24 CFR 966.3 (the requirement
that residents be given 30 days to comment on lease changes) before
a HOPE VI grant application is filed?
No. Section VII(A)(6)(b) states that an application must include
a certification that you will ensure that you and/or your procured
property manager have complied (to the extent required) with the
provisions of 24 CFR 966.3 in planning for the implementation
of the operation and management principles and policies described
in Section VII(A)(6)(b)(i)-(viii).
35. Could you clarify Section XIV(B)(4) and
(5), concerning site control for off-site properties and environmental
site assessments, as stated at Section XX? Must an applicant complete
a Phase I environmental site assessment prior to submitting the
HOPE VI application in order to meet the threshold?
An applicant does not need to have a Phase I environmental site
assessment completed in order to be funded and to meet the threshold
described at Section XIV(B)(4). However, in order to receive the
one point at Section XIV(B)(5)(b), the applicant must demonstrate
the Phase 1 has been completed.
36. Section VIII(B)(1)(d) says, “You will receive
3 Points if you demonstrate that there are extreme levels of unmitigated
lead-based paint, PCBs, mold, and/or asbestos that make the site
or a portion of the site and its housing structures unsuitable for
residential use.” What is the implication for scoring if a PHA has
already abated environmental hazards. Is it penalized on this factor?
In accordance with Section 24(a) of the U.S. Housing Act of 1937,
the purpose of the HOPE VI Revitalization program is to address
severely distressed public housing projects, through improvements
of the physical living environment for residents, revitalization
of the severely distressed sites and surrounding community, provision
of housing to avoid or decrease concentration of very low-income
families, and building of sustainable communities. Accordingly,
in order to receive points under this NOFA related to need for
revitalization, including Section VIII(B)(1)(d), applicants must
respond to the stated criteria.
37. Section XIV(A)(1) says you can earn up
to 3 points if you propose a mixed income community on the site
with more than 35% of the units being ACC units. What if the site
is no longer suitable for housing and you do not plan to build back
on-site? Do you get the points for this factor?
In order to receive points under Section XIV(A), applicants must
respond to the criteria stated in that section. To get the three
points possible under Section XIV(A)(1), your application must
propose a mixed-income, well functioning community on the revitalized
site that includes a unit mix of more than 35 percent public housing
38. If a PHA wants to supplement a HOPE VI
grant with other public housing funds (i.e. Capital Funds or Housing
Replacement Factor Funds) does this reduce the maximum HOPE VI grant?
No, if a PHA wants to supplement a HOPE VI grant with other public
housing funds, it does not reduce the maximum grant amount that
an applicant can request. However, the project must be developed
within the TDC/HCC limits applicable to the project.
39. Section VIII(B)(1)(c) says, "You will receive
3 points if you demonstrate that the project has major design deficiencies,
including:….," and then lists five criteria. Do you need to demonstrate
that all 5 criteria apply to the targeted project to get the full
It is not necessary to meet all five criteria listed under Section
VIII(B)(1)(c)(i)-(v). Rather, an applicant must be able to demonstrate
that the project has "major design deficiencies," which would
include the conditions listed at Section VIII(B)(1)(c)(i)-(v).
An applicant must be able to show that the design deficiencies
of the project targeted for revitalization are both major and
within the criteria listed under Section VIII(B)(1)(c)(i)-(v).
40. Section VII(A)(6)(b)(iii) mentions lease
requirements that promote "involvement in the resident association."
What can an applicant legally do in this area? What have you seen
from previous grantees?
Section VII(A)(6)(b) advises applicants that, if they become
HOPE VI Revitalization Grantees, they will be required to develop
Management Agreements that describe operation and management principles
and policies for their public housing units. Accordingly, applicants
must certify that they or their procured property manager have
complied (to the extent required) with the provisions of 24 CFR
966.3 in planning for the implementation of the operation and
management principles and policies described at Section VII(A)(6)(b)(i)-(viii).
These resource references should provide sufficient guidance on
how to encourage self-sufficiency by including lease requirements
that promote involvement in the resident association, as well
as performance of community service, participation in self-sufficiency
activities, and transitioning from public housing. HUD is not
permitted to provide examples of previous grantees work for the
application process, as that would constitute technical assistance.
41. Section VIII(B)(3) says "HUD will use data
from the latest quarterly obligation report available at the time
of the grant application deadline date to determine the amount of
unobligated FY 1999-2001 Capital Grant (including CIAP and CGP)
funds currently available that could be used to carry out the proposed
revitalization activities. Applicants must ensure that their obligation
and expenditure information was updated in LOCCS prior to March
31, 2002, unless an extension has been approved by the Deputy Secretary.
Information provided in the application will not be considered,
except in the case of some moving to work applicants, which are
not required to enter obligations into LOCCS in accordance with
their MTW agreements. Those PHAS must provide a certification of
their obligation rate in their applications in order to receive
any points for this rating factor." Which LOCCS report will HUD
use: September 30th (the last one before the deadline) or March
31st? What does an MTW agency have to do?
In order to meet the threshold requirement stated at Section
VII(A)(2) of this NOFA, an applicant must have obligated no less
than 90 percent of its FY 1998-1999 Capital Funds, as required
by the Quality Housing and Work Responsibility Act of 1998, by
September 30, 2001, unless an extension has been approved by the
Deputy Secretary. HUD will use the LOCCS disbursement system to
determine the obligation rate as of September 30, 2001. Those
MTW applicants, who are exempt from the statutory Capital Fund
obligation and expenditure deadlines, will not be subject to this
provision. If an applicant does not satisfy this threshold requirement,
their application will be ineligible for funding.
In order to receive points under the rating factor found at Section
VIII(B)(3), an applicant must have ensured that their obligation
and expenditure information was updated prior to March 31, 2002
(the deadline for such updates). HUD will use the latest quarterly
obligation report available at the time of grant application deadline,
which would be from September 30, 2002, to determine the amount
of unobligated FY 1999-2001 Capital funds. As stated also at Section
VIII(B)(3), MTW applicants which are not required to enter obligations
into LOCCS must certify to their obligation rate in their application
in order to receive points for this rating factor.
42. Anticipatory Resources Leveraging is a
new concept. Do past neighborhood improvements in the targeted neighborhood
count or just on-site previous expenditures?
HUD encourages applicants to review Section IX(G)(3) and (4)
for the rating factors addressing Anticipatory Resources Leveraging
and Collateral Investment Leveraging. In accordance with Section
IX(G)(3), anticipatory resources may include expenditures that
occurred on the site of the targeted development or in the surrounding
neighborhood. However, it should be noted that these expenditures
cannot duplicate any other type of resource, and cannot be counted
43. In order to receive relocation or replacement
vouchers, a PHA must have a 97% lease-up rate. When is your lease-up
rate measured to determine whether or not you get the vouchers?
HUD will measure the lease-up rate as of the end of each PHA's
most recent fiscal year.
44. The NOFA requires applicants to have control
and proper zoning for any off-site properties in the plan. Does
this mean you do not need to have things like subdivision approvals,
building permits, etc.?
If an applicant plans development on off-site properties, they
must have site control and proper zoning approvals for those properties,
or the confirmation that the request for zoning approval is on
the agenda for the next meeting of the appropriate zoning authority.
Subdivision approvals and building permits are not necessary at
the application deadline.