HUD has posted an update to the frequently asked questions (FAQs) related to the competition. This update adjusts some existing questions and provides new questions and answers beginning on page 45 of the document. One new question (Q159, provided below) changes the response to two previous questions and HUD anticipates that the new response will be useful to many eligible applicants.
View the updated National Disaster Resilience Competition FAQs.
Q159: Note that this response is a change to a prior response. Read it carefully. If a disaster repair project is complete and only addressed repair to pre-disaster condition, but did not address a resilience-enhancing action such as elevation of damaged facility due to funding or other issues, can that resilience action (elevation for example) be considered a “funding shortfall” and thus an unmet recovery need?
We note that such costs are eligible costs of rebuilding according to the NOFA. Appendix A states:
“Resilience measures that are not incorporated into rebuilding activities must tie back to the Qualified Disaster and be a necessary expense related to disaster relief, long-term recovery, and restoration of infrastructure, housing, or economic revitalization. HUD has determined that generally, designing a project that improves resilience to negative effects of climate change while meeting an Unmet Recovery Need is a necessary and reasonable cost of recovery.”
As a secondary question, does this mean that the costs of resilience projects that do not involve repair or rebuilding disaster damages may be used toward meeting the Unmet Recovery Need threshold?
A: The previous FAQs 55 and 56 are removed and this is the updated response. On the primary question, the new response is yes, if you completed repairs of a structure (or stabilized natural infrastructure such as a streambed) damaged by a Qualified Disaster to a basic functional, stable, or pre-disaster condition, but are able to demonstrate that resilient measures were not implemented and demonstrate the nature and cost of such resilient measures that could have been incorporated into the repairs in accordance with the Appendix G guidance for the category, HUD will consider the demonstrated cost of the resilient measures related to the damage to be unmet needs for purposes of meeting the Unmet Recovery Need threshold.
For example, if houses in a floodplain were damaged, then repaired to a pre-disaster condition, but not elevated, then the costs of elevation may be considered for threshold. Also for example, if a damaged sewage treatment system was repaired, but resilience measures were not taken in the rebuilding project to mitigate risk, then those costs may be considered for purposes of meeting the Unmet Recovery Need threshold.
The response to the secondary question is not affected by this reconsideration. Although it is true that in Phase 2, an successful proposal may include a CDBG-NDR-eligible project that does not include a rebuilding component, this project must still be the response that meets or addresses an Unmet Recovery Need. Such a project is not itself the Unmet Recovery Need, in the sense of the NDRC.
For example, if houses in a floodplain were damaged by a Qualified Disaster and this damage was demonstrated as sufficient to meet the MID-URN threshold, the applicant could then elect not to address the identified need through repair (resilient or not) of the housing itself. A Phase 2 proposal responsive to the example’s housing damage could involve building new housing in a safer location, constructing a sea wall, or providing relocation services/payments and job training to help the affected households move successfully to a less risky location. The costs of the proposed Phase II project in such a case would not be the same as the costs of the identified Unmet Recovery Need that helped the application meet the MID-URN threshold.