By Contributor published 6-12-2018 updated 6-15-2018
DISASTER RECOVERY INITIATIVE
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Allocations, Waivers and Alternative Requirements for Grantees Receiving Community Development Block Grant
Disaster Recovery Funds in Response to Disasters Occurring in 2016
The Continuing Appropriations Act, 2017 (Public Law 114-223 and 114-254)
Federal Register Docket No.
FR-5989-N-01 and FR–6012–N–01
LOUISIANA OFFICE OF COMMUNITY DEVELOPMENT, DISASTER RECOVERY UNIT
STATE OF LOUISIANA PROPOSED
ACTION PLAN AMENDMENT NO. 1
FOR THE UTILIZATION OF
COMMUNITY DEVELOPMENT BLOCK GRANT FUNDS
IN RESPONSE TO THE GREAT FLOODS OF 2016
Public Comment Period: February 1 – 15, 2017
John Bel Edwards
Governor
Billy Nungesser
Lieutenant Governor
The sections below outline the State of Louisiana's plan to utilize the full amount of funding appropriated to date.
Unmet Needs
The state amended the following areas of the unmet needs from the initial Action Plan:
Method of Distribution and Connection to Unmet Needs
The state refreshed the Method of Distribution and Connection to Unmet Needs to include the updated
unmet needs numbers based on the new data and the connection to the second allocation of funding.
Restore Louisiana Homeowner Rehabilitation, Reconstruction and Reimbursement Program
The state provided an updated summary of the program and with the increase in funding expanded the prioritization Phases to include Phases II-VI. The state also added a methodology for ensuring the benefit cost analysis was completed to determine if a voluntary acquisition or buyout should be considered.
Restore Louisiana Rental Housing Programs
The state updated the summary of the programs, eligible activities, and expanded the budget to include
the second allocation of funds.
Infill and Rehabilitation Rental Program
This program name was changed along with a change to the eligibility criteria for the program.
Multifamily Rental Gap Program
The state updated the summary of the program, the eligible applicants and the prioritization to include affordability requirements. Additionally, the state changed the maximum award to a per unit maximum award rather than a project maximum award.
Piggyback Program
The state added in a Piggyback program which will leverage CDBG-DR with low income housing tax credits (LIHTCs) or other sources to address the longer-term affordable housing recovery needs of the impacted communities.
Rapid Rehousing Program
The state added the Rapid Rehousing Program to address the needs of the homeless and persons at risk of becoming homeless by providing a combined solution of affordable housing and support services that assist displaced households in their endeavors to become self-sufficient.
Permanent Supportive Housing Services Program
The state added a Permanent Supportive Housing Program to further address the unmet needs of those experiencing homelessness and the at-risk homeless population. The model described will assist individuals in transitioning into Permanent Supportive Housing and maintaining successful, long-term tenancies.
Restore Louisiana Economic Revitalization Programs
The state updated the summary of the programs, eligible activities, and expanded the budget to include the second allocation of funds. Additionally, the state further described the tie of the impact of the Economic Revitalization Programs to meeting the unmet housing needs.
Small Business Loan and Grant Program
The state updated the Small Business Loan and Grant Program to include updated eligible activities, additional information regarding the eligibility criteria and a change in the maximum award.
Small Business Technical Assistance Program
The state updated the Small Business Loan and Grant Program to include updated eligible activities and additional information regarding the eligibility criteria.
Small Business Bridge Loan Program
The program description was updated to note that the state will not administer the program at this time.
Louisiana Farm Recovery Grant Program
To address the unmet needs of the Agricultural sector, the state has added the Louisiana Farm Recovery Grant Program. The program will assist individual farm enterprises impacted by the great floods of 2016.
FEMA Public Assistance Nonfederal Share Program
To meet the unmet infrastructure needs outlined in the Action Plan and Action Plan Amendment, the state has created the FEMA Public Assistance Nonfederal Share Match Program. This program will work with eligible entities to pay the nonfederal share cost of the disaster cleanup and recovery efforts.
Leverage of Funds
The Action Plan Amendment provides updates regarding the leverage of funding sources identified.
Citizen Participation
The Citizen Participation section provides updates to the process for the Action Plan Amendment. Additionally, as part of the outreach and consultation with local governments, the state has continued the resilient long-term recovery planning. This section reflects the additional work and efforts the state has undertaken, and demonstrates the commitment to continue efforts throughout the state.
In 2016, Louisiana had two separate events that qualified for appropriation under Public Laws 114-223 and 114-254. The state experienced severe storms and flooding in both March (Disaster Number 4263) and August (Disaster Number 4277) 2016 – collectively referred to as the 2016 Severe Storms and Flooding – resulting in 56 of the state's 64 parishes receiving a federal disaster declaration. From the March event, more than 16,462 homes have Federal Emergency Management Agency (FEMA) Verified Loss and 5,222 renters have FEMA Verified Loss (FVL), for a total of 21,684 households. The National Weather Service designated the August flooding event that dropped an unprecedented 7 trillion gallons of rainwater in South Louisiana as a “1,000-year” rainfall event. It resulted in the flooding of more than 68,380 homes with FVL and 23,248 renters with FVL, for a total of 91,628 households. The August storm claimed 13 lives.
A. March Storm (DR-4263)
In early March 2016, a storm system brought heavy thunderstorms from west to east across most of
Louisiana. In addition to wind damage, record flooding occurred along the Bogue Falaya River in Covington
and Bayou Dorcheat at Lake Bistineau. Governor John Bel Edwards declared a state of emergency for
several parishes and sent the National Guard to help with search-and-rescue missions.
The State of Louisiana estimates that this storm caused damage to more than 21,684 residences, forced
13,000 evacuations and 2,780 rescues, damaged another 6,143 structures, and caused numerous road
closures. Road and bridge damage estimates totaled $20 million. Agricultural losses totaled approximately
$15 million, with long-term impacts to farmers estimated at $80 million. In addition, more than 40,000
citizens registered for FEMA Individual Assistance (IA).
Thirty-six Louisiana parishes were declared eligible for FEMA IA: Allen, Ascension, Avoyelles, Beauregard,
Bienville, Bossier, Caddo, Calcasieu, Caldwell, Catahoula, Claiborne, DeSoto, East Carroll, Franklin, Grant,
Jackson, LaSalle, Lincoln, Livingston, Madison, Morehouse, Natchitoches, Ouachita, Rapides, Red River,
Richland, Sabine, St. Helena, St. Tammany, Tangipahoa, Union, Vernon, Washington, Webster, West
Carroll and Winn. Seven of these parishes also flooded in August: Ascension, Avoyelles, Livingston, St.
Helena, St. Tammany, Tangipahoa and Washington.
B. August Storm (DR-4277)
In mid-August 2016, a slow-moving storm impacted multiple South Louisiana parishes with sustained
heavy rain. In what was a 1,000-year flood, within two days more than two feet of rain was measured in
some areas, causing extensive surface and river flooding. Both the Amite and Comite rivers overtopped,
as well as numerous bayous, lakes and canals located within these drainage basins. Governor John Bel
Edwards declared a state of emergency for several parishes and sent the National Guard to help with
search-and-rescue missions.
An estimated 8,000 people were evacuated to emergency shelter sites. The American Red Cross, the state
and faith-based organizations operated these sites. A state-operated medical site was established to serve
individuals with medical needs. Roughly 30,000 search and rescues were performed, with 11,000 citizens
sheltered at the peak of the flood.
The damage to infrastructure, businesses and homes across the southern region of the state was
extensive. Large sections of state roads remained under water for extended periods. An estimated 30
state roads washed out and 1,400 bridges require inspection. Along with more than 200 highways that
closed during the event, sections of Interstates 10 and 12 closed for multiple days due to floodwaters.
Some stretches of I-10 remained closed for nearly a week, significantly interrupting interstate commerce.
More than 91,628 homes have documented damages to date, with the number expected to rise as FEMA
registrations and inspections conclude. An estimated 31 percent of homes in the declared parishes were
impacted by flooding, with only 11 percent of households in these areas carrying flood insurance. Based
on current registration numbers and historic trends, it is estimated that nearly 200,000 households will
apply for IA, with an estimated housing unmet need in excess of $2.7 billion.
Immediately following the August 2016 flooding event, the Louisiana Department of Economic
Development partnered with Louisiana State University to conduct an assessment of economic losses
resulting from the floods.
Key details are:
>> At the peak of the August event, 19,900 Louisiana businesses or roughly 20 percent of all Louisiana
businesses were disrupted by the flooding event. FEMA has since referred approximately
22,000 businesses to SBA for recovery assistance.
>> A disruption of 278,500 workers or 14 percent of the Louisiana workforce occurred at the peak of
the flooding event.
>> An economic loss estimated at roughly $300 million in labor productivity and $836 million in
terms of value added during the period immediately surrounding the flood.
>> Approximately 6,000 businesses experienced flooding.
>> The LSU Ag Center estimates Louisiana agricultural losses of over $110 million.
Twenty-two Louisiana parishes were declared eligible for FEMA IA: Acadia, Ascension, Avoyelles, East and
West Baton Rouge, East Feliciana, Evangeline, Iberia, Iberville, Jefferson Davis, Lafayette, Livingston,
Pointe Coupee, St. Helena, St. James, St. Landry, St. Martin, St. Tammany, Tangipahoa, Vermilion,
Washington and West Feliciana. Seven of these parishes also flooded in March: Ascension, Avoyelles,
Livingston, St. Helena, St. Tammany, Tangipahoa and Washington.
C. Anticipated Unmet Needs Gap
During the October 10 Congressional Session, state government officials, including Gov. John Bel Edwards,
traveled to Washington D.C. and worked collaboratively with Louisiana's Congressional Delegation to
secure long-term disaster recovery resources in response to DR-4263 and DR-4277. Working with limited
disaster loss unmet need information, Louisiana's delegation proposed a relief package of nearly $3.8
billion. This package focused primarily on housing needs, as the state has prioritized housing as the most
urgent and pressing recovery concern following the two flooding events. Through this Action Plan, the
state now presents revised unmet need estimates based on current best available data. Over time, the
state will likely continue to update these estimates as additional assessments are made and more
complete data become available.
Accounting for the initial appropriation of $437,800,000 and the second appropriation of $1,219,172,000
for long-term recovery purposes, the state has calculated a remaining unmet need of $5,070,928,237.
Summary of Total Unmet Needs
Category Losses/Gaps
Known
Investments
Remaining Unmet
Need
Owner-Occupied Housing $2,448,293,435 $2,448,293,435
Homeowner Rehabilitation and Reconstruction (CDBG-DR) ($1,293,693,120) ($1,293,693,120)
Rental Housing $254,798,970 $254,798,970
In-fill and Repair Rental Program (CDBG-DR) ($45,000,000) ($45,000,000))
Multi-family Gap Program (CDBG-DR) ($45,000,000) ($45,000,000)
Piggyback Program (CDBG-DR) ($19,000,000) ($19,000,000)
Public Housing $8,539,159 ($4,492,053) $4,047,106
Homeless Assistance $5,250,232 $5,250,232
Rapid Rehousing (CDBG-DR) ($16,000,000) ($16,000,000)
PSH Support Services (CDBG-DR) ($5,000,000) ($5,000,000)
Agriculture Losses (DR-4277) $110,244,069 $110,244,069
Agriculture Losses (DR-4263) $80,285,185 $80,285,185
Business Structures $595,600,000 $595,600,000
Business Equipment $262,800,000 $262,800,000
Business Inventories $1,425,500,000 $1,425,500,000
Business Interruption Loss $836,400,000 $836,400,000
SBA Business/EIDL Loans ($160,400,000) ($160,400,000)
Small Business Program (CDBG-DR) ($51,200,000) ($51,200,000)
Small Business Technical Assistance Program (CDBG-DR) ($800,000) ($800,000)
Louisiana Farm Recovery Program ($10,000,000) ($10,000,000)
PA State Share $106,096,475 $106,096,475
FEMA PA Match Program (CDBG-DR) ($105,000,000) ($105,000,000)
HMGP State Share $92,705,885 $92,705,885
Resilience Gaps $600,000,000 $600,000,000
Totals $6,826,513,410 ($1,755,585,173) $5,070,928,237
*CDBG-DR investments are inclusive of program delivery costs.
D. Conclusion
As a result of the 2016 Severe Storms and Flooding, the State of Louisiana received two allocations (Public
Law 114-223 and 114-254) of Community Development Block Grant Disaster Recovery (CDBG-DR)
funding. To fulfill the requirements of this allocation, the state must submit an Action Plan for Disaster
Recovery that identifies its unmet recovery and resilience needs to the Department of Housing and Urban
Development (HUD). Governor Edwards has designated the state Office of Community Development -
Disaster Recovery Unit (OCD-DRU) as the administering agency for these recovery funds. On behalf of the
State of Louisiana, OCD-DRU developed the following Action Plan to outline the proposed use of the
CDBG-DR funds and eligible activities available to assist declared parishes to meet unmet housing,
economic revitalization, public service, infrastructure, planning and other needs that arose as a result of
these two storm events.
E. Maps
1. FEMA Impacted Parishes and Federal Declarations: DR-4263 (March 2016 floods)
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2. FEMA Impacted Parishes and Federal Declarations: DR-4277 (August 2016 floods)
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3. Army Corps of Engineers Map – August Deluge Amounts
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3. Impact and Unmet Needs Assessment
A. Background
In accordance with HUD guidance, the State of Louisiana completed the following unmet needs
assessment to identify priorities for CDBG-DR funding allocated as a result of two separate significant rain
and flooding events, DR-4263 in March and DR-4277 in August. Combined, these disasters affected 56 of
the state's 64 parishes, with 51 parishes declared eligible for FEMA IA. The assessment below utilizes
federal and state resources, including data provided by FEMA, HUD and the Small Business Administration
(SBA), among other sources, to estimate unmet needs in three main categories of damage: housing,
economy and infrastructure. HUD has identified the 10 most impacted parishes from these two events as
Acadia, Ascension, East Baton Rouge, Lafayette, Livingston, Ouachita, St. Tammany, Tangipahoa,
Vermilion and Washington. This unmet needs assessment focuses on statewide impacts, with specific
sections detailing particular needs within the most impacted areas, and where relevant, smaller
geographic units.
B. Housing Impact & Needs
1. Demographic Profile of the Affected Areas
More than 72 percent of the state's population is located within the 51 IA parishes affected by DR-4263
or DR-4277 floods. Of this total, 48 percent of the population residing in the 51 IA parishes is located
within one of the 10 parishes identified by HUD as most impacted, including three of the state's largest
metropolitan areas, Baton Rouge, Lafayette and Monroe, as well as two parishes currently experiencing
significant population growth, Ascension and Livingston. It is important to note that the population
residing within the 10 most impacted parishes comprises 34.84 percent of the state's total population.
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Although the affected region tends to share similar demographic trends with the state as a whole, there
are several key areas (African-American population, education level, and poverty indicators) in which the
data differ. Unless otherwise noted, all data cited in this section are from the Census Bureau's 2014 fiveyear
estimates from the American Community Survey (ACS).
With respect to the parishes HUD has designated as most impacted, six were included in the initial
allocation of CDBG-DR funding and an additional four were included in the second allocation. A breakdown
of the parishes designated in each allocation is in the table below:
HUD-Designated Most Impacted Parishes
Initial Allocation Second Allocation
Ascension Acadia
East Baton Rouge St. Tammany
Lafayette Vermilion
Livingston Washington
Ouachita
Tangipahoa
Of the 10 most impacted parishes, six parishes, including Ascension, East Baton Rouge, Lafayette,
Livingston, Ouachita and Tangipahoa were more severely impacted than Acadia, St. Tammany, Vermilion
and Washington. The initial six most impacted parishes have a slightly larger African-American population
compared to the balance of state and the other IA parishes. By percentage, 32.31 percent of the
population in the six most impacted parishes is African-American, which is roughly 1 percentage point
more than that of the state as a whole (31.91 percent) and almost 2 percentage points more than that of
the 51 IA parishes (30.67 percent). By comparison, the African American population of the additional four
most impacted parishes is 15.1 percent. At the parish level, East Baton Rouge (45.20 percent) and
Ouachita (37 percent) parishes have the largest proportion of African-American residents, while another
most impacted parish, Livingston is only 6 percent African-American.
Within the initial six most impacted parishes, 27.74 percent of the population age 25 years or older had
attained a bachelor's degree or higher. This number is roughly 5 percentage points more than both the
statewide total (22.55 percent) and the 51 IA parishes (22.13 percent). Educational attainment for the
additional four most impacted parishes was also higher than both the state and the 51 IA parishes (25.10
percent). This may be attributable to the presence of five major universities within the most impacted
parishes. Louisiana State University (East Baton Rouge), Southern University (East Baton Rouge), the
University of Louisiana at Lafayette (Lafayette), the University of Louisiana Monroe (Ouachita) and
Southeastern Louisiana University (Tangipahoa) are five strategically important educational institutions
as well as significant economic drivers for their regions and the state as a whole.
Of the initial six most impacted parishes, there are significant outliers worth noting in reference to
educational attainment. For example, in Tangipahoa Parish 19.45 percent of the population aged 25 or
older has a bachelor's degree or higher, proportionally 14.86 percentage points less than that of East
Baton Rouge Parish and 8.29 percentage points less than the six most impacted parishes combined. Of
the 10 most impacted parishes, East Baton Rouge had the highest proportion of population age 25 or
older with a bachelor's degree or more at 34.31 percent, followed by St. Tammany Parish at 30.37 percent.
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Housing and income demographics also highlight differences between the 51 IA parishes and the state as
a whole. For instance, the 51 IA parishes have a median owner-occupied housing unit value and median
household income that are significantly lower than that of the state. The median value of owner-occupied
housing units in the 51 IA parishes is $91,225, $49,175 less than the statewide total ($140,400).
Meanwhile, the most impacted parishes collectively have a higher median owner-occupied housing unit
value than the statewide total. The median owner-occupied housing unit value for the initial six most
impacted parishes is $157,450, $17,050 higher than statewide. Those same parishes also have a larger
proportion of renters than both the state and the other IA parishes. At 30.87 percent, the initial six most
impacted parishes collectively are home to a renter population that is almost 3 percentage point higher
than the other IA parishes (27.73 percent) and more than 1 percentage point higher than the statewide
total (29.12 percent). Renter population for the additional four parishes is 21.7 percent.
The 51 IA parishes have a median household income of $39,347, $5,644 less than the statewide median
household income of $44,991. In addition to a lower median household income, the 51 IA parishes have
a per capita income that is significantly less than that of the state as a whole. The 51 IA parishes have a
per capita income of $21,456, $3,319 less than the statewide per capita income of $24,775.
Poverty indicators across the affected area also deviate from statewide totals. In the initial six most
impacted parishes, the proportion of people with income below the poverty line is higher than the other
IA parishes or statewide totals. 27.22 percent of households in the most impacted area have incomes
below the poverty line, 8.21 percentage points more than statewide totals and 7.89 more than the other
IA parishes, respectively. Comparatively, 14.8 percent of households in the additional four most impacted
parishes had incomes below the poverty line.
Demographic Profile
2010-2014 American Community Survey 5-Year Estimates
Louisiana 51 PDD Parishes 10 Most Impacted Parishes
Demographics Estimates % of State Estimates
% of 51
PDD Estimates % of 10 MI
TOTAL
POPULATION: 4,601,049 100.00% 3,317,519 100.00% 1,602,912 100.00%
Under 5 years 311,324 6.77% 227,206 6.85% 109,202 6.81%
65 years and over 593,807 12.91% 430,421 12.97% 191,914 11.97%
White alone 2,748,538 59.74% 2,084,305 62.83% 1,086,731 67.80%
Black or African
American alone 1,468,208 31.91% 2,084,305 30.67% 449,596 28.05%
American Indian
and Alaska Native
alone 25,498 0.55% 13,542 0.41% 4,420 0.28%
Asian alone 74,878 1.63% 41,325 1.25% 26,133 1.63%
Native Hawaiian
and Other Pacific
Islander alone 1,604 0.03% 1,147 0.03% 391 0.02%
Two or more races 64,641 1.40% 45,508 0.99% 24,929 1.56%
Hispanic or Latino 210,524 4.58% 109,878 3.31% 59,724 3.73%
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Population 16 years
and over in civilian
labor force 2,192,054 47.64% 1,555,399 46.88% 769,514 48.01%
Louisiana 51 PDD Parishes 10 Most Impacted Parishes
Housing
Demographics Estimates % of State Estimates
% of 51
PDD Estimates % of 10 MI
TOTAL HOUSING
UNITS: 1,988,460 100.00% 1,410,498 100.00% 665,392 100.00%
Average Household
Size 2.61 (X) 2.60 (X) 2.66 (X)
Owner-occupied 1,139,756 57.32% 836,710 59.32% 405,347 60.92%
Renter-occupied 579,120 29.12% 391,076 27.73% 189,930 28.54%
Median Value of
owner-occupied
housing units (in
2014 dollars) $140,400.00 (X) $ 91,225.00 (X) $143,250 (X)
Median gross rent
(in 2014 dollars) $ 786.00 (X) $ 614.25 (X) $ 759.00 (X)
TOTAL
HOUSEHOLDS: 1,718,876 100% 1,227,786 71% 595,277 89.5%
Civilian
noninstitutionalized
population without
health insurance 747,454 16.25% 527,873 15.91% 245,780 15.53%
Estimate of
noninstitutionalized
population with a
disability* 674,156 15% 495,017 15% 221,242 9.79%
Language other
than English
Spoken at Home,
Over Age of 5* 369,719 9% 221,293 7% 120,374 8%
2015 Building
Permits** 12,222 (X) 10,264 (X) 6,726 (X)
Louisiana 51 PDD Parishes 10 Most Impacted Parishes
Income/Economic
Demographics Estimates % of State Estimates
% of 51
PDD Estimates % of 10 MI
Median household
income (in 2014
dollars) $ 44,991.00 (X) $ 39,347.75 (X) $ 47,939.50 (X)
Per capita income
(in 2014 dollars) $ 24,775.00 (X) $ 21,456.25 (X) $ 24,405.50 (X)
Income in the past
12 months below
poverty level: 874,638 19.01% 641,395 19.33% 273,554 17.46%
Louisiana 51 PDD Parishes 10 Most Impacted Parishes
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Education
Demographics Estimate % of State Estimate
% of 51
PDD Estimates % of 10 MI
Population 25 years
and over: 2,932,993 100.00% 2,081,554 100.00% 1,026,485 100.00%
Less than high
school graduate 486,080 16.57% 333,637 16.03% 140,378 13.68%
High school
graduate (includes
equivalency) 991,471 33.80% 718,245 34.51% 322,095 31.38%
Some college,
associate's degree 793,996 27.07% 568,935 27.33% 284,411 27.71%
Bachelor's degree
or higher 661,446 22.55% 460,737 22.13% 268,800 26.19%
Source: U.S. Census Bureau, 2010-2014 American Community Survey 5-Year Estimates
**U.S. Census Bureau, 2015 Building Permits, Reported Units, http://censtats.census.gov/bldg/bldgprmt.shtml
TABLES: B17001, S1701, DP03, DP04, DP05
Social Vulnerability Index (SoVI)
SoVI is a tool for assessing pre-existing vulnerabilities to environmental hazards. The index is a
comparative metric that facilitates the examination of differences in social vulnerability at a certain level
of geography. The index, in this iteration, synthesizes 27 socioeconomic variables, which, with support
from research literature, can contribute to a reduction in a community's ability to prepare for, respond to
and recover from hazards. The SoVI built in this assessment is primarily derived from U.S. Census Bureau
data. SoVI uses a combined assessment of 2010 U.S. Census data and the Five-Year American Community
Survey (2010-2014) and pulls from the mentioned 27 individual data points across geographic boundaries
to determine relative social vulnerability across any given geography and is always relative to whatever
specific geography being analyzed. These 27 individual data points cut across six component groups: Class
and Race, Non-Extractive (less rural) and Race, Age, Ethnicity and Race, Gender, Housing Characteristics
(proportion of renters, occupants per unit, female heads of household, etc. For modeling purposes, both
2010 U.S. Census data and the Five-Year Community Survey are current until the 2020 Census is completed
and released.
The SoVI created for the 51 IA parishes affected by DR-4263 or DR-4277 incorporates six general
components synthesizing these 27 socioeconomic variables:
>> Class and race
>> Non-extractive (less rural)
>> Age
>> Ethnicity
>> Gender
>> Housing characteristics (persons per unit, renters, unoccupied units, female-headed households)
SoVI has high utility as a decision-support tool for emergency management. The tool shows where there
is uneven capacity for preparedness and response and where resources might be used most effectively to
reduce the pre-existing vulnerability. The SoVI metric turns historical disaster impact measures into
actionable information for emergency managers, recovery planners, and decision makers as a whole. It
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empirically measures and visually depicts a population's inability and/or ability to adequately prepare for,
respond to, and rebound from disaster events.
By coupling SoVI with other data sources, such as the IA dataset, NFIP data and SBA data, the state is
capable of identifying concentrations of greatest need for additional recovery resources. The state has
collaborated with its counterparts in South Carolina, who used this methodology to plan long-term
recovery efforts following its 2015 flooding events, to strategize how SoVI can be an apolitical approach
for distributing scarce disaster recovery dollars to provide optimal benefit to the places that were worst
impacted and least able to recover on their own from this disaster.
A SoVI analysis of the 51 IA parishes indicates the areas with the highest levels of pre-existing social
vulnerability are in the metropolitan areas of Alexandria, Baton Rouge, Lafayette, Lake Charles, Monroe
and Shreveport. For example, there are total of 38 “high” SoVI census tracts in these six metropolitan
areas, representing more than 80 percent of the 47 “high” SoVI census tracts across the total 51 IA
parishes. This is significant due to large concentrations of damage found in a few of these areas, notably
Baton Rouge, Lafayette and Monroe. Specifically, there are 18 “high” SoVI tracts in these three impacted
metropolitan areas. The six impacted metropolitan areas also have a high proportion of “medium high”
SoVI tracts. Of the 140 total “medium high” SoVI tracts in the 51 IA parishes, 119 of those census tracts,
or more than 66 percent, are within these six metropolitan areas. 66 of these “medium high” SoVI tracts
are located within Baton Rouge, Lafayette and Monroe.
The state will use the information from the SoVI analysis as a planning and implementation tool to ensure
the most vulnerable populations are engaged in the programs. Understanding the locations of the
“medium high” to “high” SoVI census tracts will equip the state's outreach team with the information
needed to further engage local governments, non-profits and other stakeholders representing these areas
in order to coordinate efforts and understanding as how to best serve “medium high” to “high” SoVI
census tracts residents. Additionally, the state will be able to use the SoVI analysis as a tool to ensure
robust engagement and participation of “medium high” to “high” SoVI census tracts through the
targeted efforts of the homeowner program manager who will ensure vulnerable populations are
provided the support needed to access the program. Another way in which the SoVI analysis will be
deployed as a useful tool for program planning is in the state's assessment and strategy for the
development of affordable housing. Using the SoVI bivariate analysis will allow the state to consider
racial, ethnic and low-income concentrations in order to work to provide affordable housing in lowpoverty,
non-minority and low-risk areas.
SoVI Summary:
>> Alexandria – 3 “high” SoVI tracts (6 percent of the IA parish total) and 13 “medium high” SoVI
tracts (7 percent of the IA parish total).
>> Baton Rouge – 8 “high” SoVI tracts (17 percent of the IA parish total) and 38 “medium high”
SoVI tracts (21 percent of the IA parish total).
>> Lafayette – 5 “high” SoVI tracts (11 percent of the IA parish total) and 16 “medium high” SoVI
tracts (9 percent of the IA parish total).
>> Lake Charles – 2 “high” SoVI tracts (1 percent of the IA parish total) and 14 “medium high” SoVI
tracts (8 percent of the IA parish total).
>> Monroe – 5 “high” SoVI tracts (11 percent of the IA parish total) and 12 “medium high” SoVI
tracts (7 percent of the IA parish total).
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>> Shreveport – 15 “high” SoVI tracts (32 percent of the IA parish total) and 26 “medium high”
SoVI tracts (14 percent of the IA parish total).
>> There are a total of 710 census tracts in the 51 IA parishes.
>> There are 47 “high” SoVI tracts in the 51 IA parishes.
>> There are 180 “medium high” SoVI tracts in the 51 IA parishes.
Housing Affordability
The state is specifically concerned about housing affordability and the high proportion of households
statewide and in the affected area considered to be “cost burdened.” The standard measurement of rental
unaffordability considers any household that spends more than 30 percent of its pre-tax income on
housing as having an affordability problem. Housing is considered “affordable” if the rent (including
utilities) is no more than 30 percent of its pre-tax income. Households spending more than 30 percent are
“cost burdened” or “rent-stressed,” and those spending more than 50 percent are labeled “severely cost
burdened” or “severely rent-stressed.”
In a recent report released by the National Low Income Housing Coalition (NLIHC), in no state can a
minimum wage worker afford a two-bedroom rental unit at the average fair market rent, working a
standard 40-hour work week, without paying more than 30 percent of their income for housing. The
minimum wage in Louisiana is $7.25 per hour; however a household must earn $15.81 per hour to avoid
16
paying more than 30 percent of income on housing (and utilities) to afford a 2-bedroom unit at the fair
market rent of $822 per month.
According to ACS data, 46 percent of Louisiana renters and 21 percent of homeowners are cost burdened,
while 25 percent of renters and 9 percent of homeowners are severely cost burdened. In total, 501,610
households statewide are cost burdened and 241,725 are severely cost burdened.
Within the 51 IA parishes, a similar percentage of renters experience cost burden (45 percent) or severe
cost burden (23 percent) as compared to the state overall. Similarly, a comparable percentage of
homeowners are cost burdened (19 percent) or severely cost burdened (8 percent) compared to the state
overall. In total, 337,380 households in IA parishes are cost burdened, and 157,187 are severely cost
burdened.
By comparison, renters in the 10 ten most impacted parishes experience cost burden (47 percent) and
severe cost burden (25 percent) at slightly higher rates than the state or IA areas overall. Homeowners
within the most impacted parishes experience similar levels of cost burden (21 percent) and severe cost
burden (8 percent) compared to the IA parishes and state overall. In total, 173,139 households in the most
impacted parishes are cost burdened, and 81,522 are severely cost burdened.
Cost Burdened Renters and Owners
State of
Louisiana
Presidentially Declared
Disaster Areas
10 Most Impacted
Parishes
Cost Burdened Renters 267,146 174,938 88,921
Percent of Renters with Cost
Burden 46% 45% 47%
Severe Cost Burden Renters 144,224 91,611 48,308
Percent of Renters with Severe
Cost Burden 25% 23% 25%
Cost Burdened Owners 234,464 162,442 84,218
Percent of Homeowners with
Cost Burden 21% 19% 21%
Severely Cost Burdened Owners 97,501 65,576 33,214
Percent of Homeowners with
Severe Cost Burden 9% 8% 8%
Source: U.S. Census Bureau, 2010-2014 American Community Survey 5-Year Estimates
Mortgage Status by Selected Monthly Owner Costs as a Percentage of Household Income in the Past 12
Months for Owner Occupied Housing
Gross Rent as a Percentage of Household Income in the Past 12
months
Note: Cost Burden is defined as renter or owner households spending over 30 percent of household
income on rent or mortgage.
2. Statewide Housing Damage and Loss Assessment
To articulate the extent of damage, the state compiled information to document damages across several
different population stratifications, including owner-occupied and renter households, households without
flood insurance, households located outside of the Special Flood Hazard Area (SFHA), households within
the six most impacted parishes, Low and Moderate Income (LMI) households, households with Access and
Functional Needs (AFN) and households with applicants aged 62 and older.
17
For the purposes of this analysis, the state used full applicant-level data collected through FEMA's IA
program. DR-4263 IA data were pulled on Nov. 10, 2016 and DR-4277 IA data were pulled on Nov. 3, 2016.
Unless otherwise noted, all housing summary data were compiled from these two datasets.
Furthermore, unless otherwise specifically noted, the state has defaulted to HUD's definitions of unmet
need for owner-occupied and renter households. For rental properties, to meet the statutory requirement
of “most impacted,” homes are determined to have a high level of damage if they have damage of "majorlow"
or higher. That is, they have a FEMA personal property damage assessment of $2,000 or greater or
flooding over 1 foot. Furthermore, landlords were presumed to have adequate insurance coverage unless
the unit is occupied by a renter with income of $20,000 or less. Units occupied by a tenant with income
less than $20,000 were used to calculate likely unmet needs for affordable rental housing.
To calculate the level of damage for rental households, the state used the following criteria:
>> Minor-Low: Less than $1,000 of FEMA inspected personal property damage
>> Minor-High: $1,000 to $1,999 of FEMA inspected personal property damage
>> Major-Low: $2,000 to $3,499 of FEMA inspected personal property damage or more than 1 foot
of flooding on the first floor.
>> Major-High: $3,500 to $7,499 of FEMA inspected personal property damage or 4 to 6 feet of
flooding on the first floor.
>> Severe: Greater than $7,500 of FEMA inspected personal property damage or determined
destroyed and/or 6 or more feet of flooding on the first floor.
To calculate the level of damage for owner-occupied households, the state used the following criteria:
>> Minor-Low: Less than $3,000 of FEMA inspected real property damage
>> Minor-High: $3,000 to $7,999 of FEMA inspected real property damage
>> Major-Low: $8,000 to $14,999 of FEMA inspected real property damage and/or more than 1 foot
of flooding on the first floor.
>> Major-High: $15,000 to $28,800 of FEMA inspected real property damage and/or 4 to 6 feet of
flooding on the first floor.
>> Severe: Greater than $28,800 of FEMA inspected real property damage or determined destroyed
and/or 6 or more feet of flooding on the first floor.
The average cost for full home repair to code for a specific disaster within each of the damage categories
noted above is calculated using the average real property damage repair costs determined by the SBA for
its disaster loan program for the subset of homes inspected by both SBA and FEMA for 2011 to 2013
disasters. Because SBA inspects for full repair costs, it presumes to reflect the full cost to repair the home,
which is generally more than FEMA estimates on the cost to make the home habitable.
For each household determined to have unmet housing needs, their estimated average unmet housing
need less assumed assistance from FEMA, SBA, and Insurance was calculated at $27,455 for major damage
(low); $45,688 for major damage (high); and $59,493 for severe damage. Unless otherwise noted, when
quoting an estimated total for unmet housing need, the state has relied on these estimates to calculate a
specific dollar amount. Data is not currently available from HUD respective to estimated needs at the
minor-high and minor-low categories.
18
19
Owner-Occupied Households Estimated Unmet Need Baseline
Damage Category Estimated Needs
Severe $ 59,493
Major-High $ 45,688
Major-Low $ 27,455
Minor-High $ -
Minor-Low $ -
The state reserves the right to revisit this methodology, once it has conducted its own analysis specific to
DR-4263 and DR-4277 comparing damages documented through FEMA's real property inspections,
inspections conducted in response to claims made to the National Flood Insurance Program (NFIP) and
inspections conducted for the purposes of the SBA disaster loan program. Additionally, the state intends
to use real-time unmet needs assessments gathered through its own program intake and inspection
process to further inform this analysis over time.
Total Impact (Owner-Occupied and Renter Households)
The information below outlines the total household population with documented damages. For the
purposes of this analysis, the state has concluded a household has documented damage if FEMA reported
a FEMA FVL of greater than $0. Across both disasters, 113,312 households were found to have some level
of documented damage, including 84,842 owner-occupied and 28,470 renter households. While the
majority of instances of housing damage can be attributed to DR-4277 (91,628 of 113,312, or 81 percent),
the state is aware this is at least partially attributable to the fact DR-4277 generally affected larger
population centers like Lafayette and metropolitan Baton Rouge, while DR-4263 generally affected more
rural parishes and communities.
While these data validate HUD's identification of the ten most impacted parishes, the state is also
concerned about levels of damage in several parishes just below this most impacted threshold, specifically
Iberia, Morehouse, St. Landry and St. Martin, parishes. The map below includes all documented instances
of housing damage, irrespective of the level of damage.
20
Households with Damage
Disaster Parish Owners Renters Total
4263 Ouachita 3,449 2,684 6,133
Tangipahoa 2,378 769 3,147
Washington 1,133 303 1,436
Morehouse 1,021 290 1,311
St. Tammany 933 178 1,111
Caddo 594 120 714
Bossier 612 78 690
Natchitoches 613 76 689
Richland 451 147 598
Webster 533 50 583
Livingston 453 72 525
Union 412 33 445
West Carroll 351 31 382
St. Helena 342 25 367
Vernon 320 34 354
Calcasieu 286 38 324
21
Households with Damage
Disaster Parish Owners Renters Total
Grant 296 27 323
East Carroll 241 53 294
Bienville 214 17 231
Claiborne 203 23 226
Winn 183 33 216
Lincoln 156 17 173
Rapides 151 21 172
De Soto 145 14 159
Caldwell 148 9 157
Beauregard 127 17 144
Ascension 109 21 130
Sabine 102 2 104
Madison 86 16 102
Allen 77 6 83
LaSalle 76 7 83
Jackson 73 4 77
Catahoula 74 1 75
Franklin 62 3 65
Red River 46 3 49
Avoyelles 12 - 12
Total 16,462 5,222 21,684
4277 East Baton Rouge 24,255 12,683 36,938
Livingston 15,972 4,746 20,718
Ascension 6,395 1,438 7,833
Tangipahoa 4,655 1,104 5,759
Lafayette 4,798 852 5,650
Vermilion 1,819 360 2,179
Acadia 1,555 445 2,000
St. Landry 1,600 398 1,998
Iberia 1,466 400 1,866
St. Martin 1,339 120 1,459
St. Helena 922 105 1,027
East Feliciana 653 102 755
Evangeline 531 142 673
Jefferson Davis 507 62 569
Pointe Coupee 451 100 551
Iberville 356 39 395
Avoyelles 262 75 337
St. Tammany 216 18 234
Washington 199 28 227
22
Households with Damage
Disaster Parish Owners Renters Total
West Feliciana 160 11 171
St. James 159 10 169
West Baton Rouge 107 10 117
Calcasieu 2 - 2
Rapides 1 - 1
Total 68,380 23,248 91,628
Grand Total 84,842 28,470 113,312
Impact on Owner-Occupied Households
By far, the greatest number of instances of significant owner-occupied housing damage occurred in the
Baton Rouge Capital Region, specifically in East Baton Rouge, Livingston, Ascension and Tangipahoa
parishes. Other population centers around Monroe (Ouachita Parish) and Lafayette (Lafayette Parish) also
experienced significant owner-occupied housing damages. Finally, the state is mindful of two additional
pockets of significant damage along the Sabine River, in Calcasieu and Vernon parishes, respectively.
For the purposes of this section, the state includes all documented damages to the owner-occupied
household population at all levels of damage in tabular format. For mapping purposes, this analysis only
includes those households with “major-low,” “major-high” and “severe” levels of damage at the census
tract. This map illustrates those housing units with significant and likely unmet needs.
23
Owner-Occupied Households with Damage
Disaster Damage Category Households
4263 Severe 675
Major-High 2,276
Major-Low 3,979
Minor-High 1,503
Minor-Low 8,029
Total 16,462
4277 Severe 11,249
Major-High 24,270
Major-Low 15,182
Minor-High 3,849
Minor-Low 13,830
Total 68,380
Grand Total 84,842
This analysis generally assumes areas with greatest need are going to be those that have both high
concentrations of damage as well as a high level of pre-existing social vulnerability. Utilizing this bivariate
approach identifies specific corridors of concern. For owner-occupied household populations, a
concentration of need is found in corridors throughout the Baton Rouge Capital Region. There are a total
of six census tracts in the 51 IA declared parishes classified as having high levels of damage as well as high
levels of social vulnerability. All six of these census tracts are located within the Capital Region. Five of the
census tracts are located within East Baton Rouge Parish, specifically, and one is located in Livingston
Parish. These census tracts are all within a five-mile area and five of the six census tracts are located in a
line along the I-12/Florida Boulevard corridor that runs between Baton Rouge and Denham Springs. The
state will note these particular areas of interest as it conducts programmatic outreach and intake.
24
Owner-Occupied Households with Damage (SoVI Designation)
Disaster SoVI (5-Class) Households
4263 High 659
Medium-High 4,122
Medium 3,743
Medium-Low 7,515
Low 423
Total 16,462
4277 High 895
Medium-High 10,335
Medium 18,994
Medium-Low 32,424
Low 5,732
Total 68,380
Grand Total 84,842
25
Of particular concern is the high proportion of owner-occupied households with damage who did not
report carrying insurance through the National Flood Insurance Program (NFIP). In total, 72 percent of all
impacted owner-occupied households, or 61,069, did not report having insurance. This represents a
unique situation for the state, as in previous significant disaster events – hurricanes Katrina, Rita, Gustav,
Ike and Isaac - there was a reasonable anticipation some damages may have been attributable to wind or
other events that may have been covered by a homeowner's hazard insurance policy. As these events
were flood-exclusive, the state has no such reasonable anticipation any of the losses incurred by this
population were met by other insurance policies.
Additionally, it is important to note the high instances of owner-occupied households with significant
levels of damage who were uninsured. 36,510 households of the 61,069 uninsured total had damage
levels of “major-low,” “major-high” or “severe,” accounting for more than 59 percent of the affected and
uninsured owner-occupied population.
Owner-Occupied Households with No Flood Insurance
Disaster Damage Category Households Percent of Total Damaged
4263 Severe 481 71%
Major-High 1,448 64%
Major-Low 3,079 77%
Minor-High 1,258 84%
Minor-Low 7,563 94%
26
Owner-Occupied Households with No Flood Insurance
Disaster Damage Category Households Percent of Total Damaged
Total 13,829 84%
4277 Severe 6,071 54%
Major-High 14,470 60%
Major-Low 10,961 72%
Minor-High 3,130 81%
Minor-Low 12,608 91%
Total 47,240 69%
Grand Total 61,069 72%
To drilldown on affected owner-occupied populations in the ten-parish most impacted area, the state
prepared the following detailed maps illustrating instances of owner-occupied household damages at the
census tract. As the state conducts housing program intake, it will attempt to coordinate outreach efforts
in accordance with locales with high-levels of documented damages.
It is important to note 68,319 of the total 84,842 owner-occupied households with damage are located
within the ten-parish most impacted area, representing more than 81 percent of the total. Additionally,
51,742 households within that population are likely to have unmet needs, with damage levels at “majorlow,”
“major-high” or “severe.” This population represents more than 90 percent of the 57,631 affected
owner-occupied households likely to have unmet needs.
27
Represents households with “major-low,” “major-high” and “severe” levels of damage.
28
Represents households with “major-low,” “major-high” and “severe” levels of damage.
29
Owner-Occupied Households in 10 Most Impacted Parishes
Disaster Damage Category Households
4263 Severe 226
Major-High 1,339
Major-Low 2,297
Minor-High 906
Minor-Low 3,687
Total 8,455
4277 Severe 11,107
Major-High 23,657
Major-Low 13,116
Minor-High 3,075
Minor-Low 8,909
Total 59,864
Grand Total 68,319
Represents households with “major-low,” “major-high” and “severe” levels of damage.
30
The rainfall events associated with DR-4263 and DR-4277 were each considered to be, in some areas, “one
in 1,000 year” events, or events with an annual expected occurrence rate of 0.001 percent. As a result, an
unusually high proportion of affected owner-occupied households were located outside of the 100-year
floodplain, or the Special Flood Hazard Area (SFHA). Accordingly, these households were not required to
carry flood insurance if they had a mortgage. Combined with the high proportion of affected households
without flood insurance, the state believes these factors have exacerbated housing unmet needs relative
to past disasters.
Specifically, 46,016 impacted owner-occupied households were located outside of the SFHA, representing
more than 54 percent of the total affected owner-occupied household population. Additionally, 24,615 of
these households are likely to have unmet housing needs, with damage levels of “major-low,” “majorhigh”
or “severe.” This represents more than 42 percent of the owner-occupied population likely to have
unmet needs.
Owner-Occupied Households Outside SFHA
Disaster Damage Category Households
4263 Severe 292
Major-High 1,043
Major-Low 2,116
Minor-High 1,031
31
Minor-Low 6,800
Total 11,282
4277 Severe 2,896
Major-High 10,395
Major-Low 7,873
Minor-High 2,513
Minor-Low 11,057
Total 34,734
Grand Total 46,016
Given HUD requirements associated with this CDBG-DR allocation, the state must expend at least 70
percent of its allocation toward the benefit of LMI populations. 43,643 affected owner-occupied
households are LMI, or more than 51 percent of the total affected owner-occupied population.
Additionally, only 25,157 of this total are households expected to have remaining unmet needs (based on
HUD's methodology), with damage levels of “major-low,” “major-high” or “severe.” This represents
approximately 43 percent of the affected population likely to have remaining unmet needs. As such, if the
state receives substantially greater resources, in addition to the $1.6 billion already allocated by Congress,
to address unmet needs in a more comprehensive fashion, it anticipates it may face a challenge in meeting
its requirement to expend at least 70 percent of its CDBG-DR allocation toward the benefit of LMI
populations.
32
LMI Owner-Occupied Households
Disaster Damage Category Households
4263 Severe 282
Major-High 999
Major-Low 2,293
Minor-High 909
Minor-Low 5,934
Total 10,417
4277 Severe 4,088
Major-High 9,495
Major-Low 8,000
Minor-High 2,116
Minor-Low 9,527
Total 33,226
Grand Total 43,643
As the state attempts to prioritize the expenditure of CDBG-DR resources that are dwarfed by the total
anticipated unmet needs from DR-4263 and DR-4277, one area of prioritization will be elderly households
as it conducts program intake. There are at least 26,783 households with members aged 62 or older in
33
the impacted owner-occupied population, accounting for the limitation that IA data only includes date of
birth for the applicant representing the entire household. Using this figure as a baseline, however, at least
31 percent of the affected owner-occupied household population has a member that is 62 or older.
Isolating just those households likely to have unmet needs, at least 18,997 have a household member
aged 62 or older. This is at least 32 percent of the owner-occupied household population likely to have
unmet needs.
Owner-Occupied Households with Applicant Aged 62+
Disaster Damage Category Households
4263 Severe 262
Major-High 927
Major-Low 1,363
Minor-High 478
Minor-Low 2,491
Total 5,521
4277 Severe 4,069
Major-High 8,132
Major-Low 4,244
Minor-High 1,139
Minor-Low 3,678
Total 21,262
Grand Total 26,783
34
In addition to those households with a member aged 62 or older, the state will also prioritize those
households with persons with disabilities, as identified initially by those households that indicated they
had access and/or functional needs through their IA applications. According to the FEMA data, there are
2,590 owner-occupied households with documented access and/or functional needs, representing more
than 3 percent of the total impacted owner-occupied household population. 1,900 of these households
have levels of damage indicating they likely have remaining unmet needs, accounting for more than 3
percent of the total owner-occupied household population likely to have unmet needs.
Owner-Occupied Households with Access/Functional Needs
Disaster Damage Category Households
4263 Severe 28
Major-High 77
Major-Low 108
Minor-High 33
Minor-Low 176
Total 422
4277 Severe 474
Major-High 835
Major-Low 378
Minor-High 95
Minor-Low 386
35
Total 2,168
Grand Total 2,590
Impact on Renter Households
The greatest number of instances of renter household damages occurred in Ouachita (DR-4263), East
Baton Rouge and Livingston (both DR-4277) parishes. Other parishes with significant impacts to renter
populations include Ascension and Tangipahoa parishes.
For the purposes of this section, the state has included all documented damages to the renter household
population at all levels of damage in tabular format. For mapping purposes, this analysis only includes
those households with “major-low,” “major-high” and “severe” levels of damage.
Renter Households with Damage
Disaster Damage Category Households
4263 Severe 279
Major-High 1,204
Major-Low 1,309
Minor-High 876
Minor-Low 1,554
Total 5,222
4277 Severe 3,838
Major-High 8,097
Major-Low 6,182
Minor-High 1,818
36
Minor-Low 3,313
Total 23,248
Grand Total 28,470
This analysis generally assumes areas with greatest need are going to be those that have both high
concentrations of damage as well as a high level of pre-existing social vulnerability. Utilizing a bivariate
approach for rental household populations and SoVI census tracts, the Baton Rouge Capital Region and
the Monroe metropolitan area have large concentrations of damage as well as areas with notably high
levels of social vulnerability. In the Capital Region, there are a total of nine census tracts (8 in East Baton
Rouge and 1 in Livingston) classified as having high levels of both damage and social vulnerability. Most
of these census tracts are located within a five-mile area in a line along the I-12/Florida Boulevard corridor
that runs between Baton Rouge and Denham Springs; however, there are two census tracts meeting these
characteristics in northern Baton Rouge. Both are located south of the Baton Rouge Metropolitan Airport,
one of which is in a neighborhood west of Howell Park and the other is located west of Airline Highway
between the Airline Highway and I-110 and the Airline Highway and Prescott Road intersections.
In the Monroe metropolitan area, there are five total census tracts classified as having both high
concentrations of rental household damage as well as high levels of social vulnerability. Three of these
census tracts are within a three-mile area. These tracts run north and south along Highway 165 from south
of the University of Louisiana Monroe at the intersection of Martin Luther King Jr. Drive (Highway 165)
and DeSiard Street down to Richwood. The other two census tracts are outliers, but still within six miles
of each other. One of the outliers is located between Glenwood Regional Medical Center and the Ouachita
River. For reference, West Monroe High School is roughly the center point of this census tract. The second
outlier is located north of the University of Louisiana Monroe. It is bounded by Sterlington Road (Highway
165) to the west, Chauvin Bayou to the south, and the winding Bayou DeSiard to the north, northeast, and
east. The state will note these particular areas of interest as it conducts programmatic outreach and
intake.
37
Renter Households with Damage (SoVI Designation)
Disaster SoVI (5-Class) Households
4263 High 555
Medium-High 2,343
Medium 1,076
Medium-Low 1,193
Low 55
Total 5,222
4277 High 659
Medium-High 6,543
Medium 6,973
Medium-Low 8,066
Low 1,009
Total 23,250
Grand Total 28,472
To drilldown on affected renter populations in the 10-parish most impacted area, the state has prepared
the following detailed maps illustrating instances of renter household damages at the census tract level.
38
As the state conducts housing program intake, it will attempt to coordinate outreach efforts in accordance
with locales with high-levels of documented damages.
It is important to note 25,701 of the total 28,470 renter households with damage are located within the
10-parish most impacted area, representing more than 90 percent of the total.
Represents households with “major-low,” “major-high” and “severe” levels of damage.
39
Represents households with “major-low,” “major-high” and “severe” levels of damage.
40
Renter Households in 10 Most Impacted Parishes
Disaster Damage Category Households
4263 Severe 214
Major-High 968
Major-Low 1,061
Minor-High 697
Minor-Low 1,087
Total 4,027
4277 Severe 3,778
Major-High 7,895
Major-Low 5,801
Minor-High 1,508
Minor-Low 2,692
Total 21,674
Grand Total 25,701
Represents households with “major-low,” “major-high” and “severe” levels of damage.
41
Like the owner-occupied household population, an unusually high proportion of affected renter
households were located outside of a Special Flood Hazard Area (SFHA). As such, while this may not
inherently indicate exacerbated need for the renter population itself, it may indicate an enhanced need
for landlords who may not have carried flood insurance. Furthermore, as has been discussed previously,
there was a lack of affordable housing stock prior to the 2016 flooding events. The impacts described
below have further exacerbated the need for an increase in affordable housing options across the state.
Specifically, 12,921 impacted renter households were located outside of the SFHA, representing more
than 45 percent of the total affected renter household population.
Renter Households Outside SFHA
Disaster Damage Category Households
4263 Severe 119
Major-High 532
Major-Low 619
Minor-High 541
Minor-Low 1,160
Total 2,971
4277 Severe 940
Major-High 2,802
42
Renter Households Outside SFHA
Disaster Damage Category Households
Major-Low 2,728
Minor-High 1,148
Minor-Low 2,332
Total 9,950
Grand Total 12,921
Per HUD requirements associated with this CDBG-DR allocation, the state must expend at least 70 percent
of its allocation toward the benefit of LMI populations. 21,806 affected renter households are LMI, or
more than 76 percent of the total affected renter population.
LMI Renter Households
Disaster Damage Category Households
4263 Severe 205
Major-High 916
Major-Low 1,037
Minor-High 737
Minor-Low 1,350
43
LMI Renter Households
Disaster Damage Category Households
Total 4,245
4277 Severe 2,850
Major-High 5,822
Major-Low 4,717
Minor-High 1,441
Minor-Low 2,731
Total 17,561
Grand Total 21,806
As the state prioritizes the expenditure of CDBG-DR resources that are dwarfed by the total anticipated
unmet needs from DR-4263 and DR-4277, it may prioritize elderly households as it conducts program
intake. There are at least 2,642 households with applicants aged 62 or older in the impacted renter
population, accounting for the limitation that IA data only includes data of birth for the applicant
representing the entire household. Using this figure as a baseline, however, at least 9 percent of the
affected renter household population has a member that is 62 or older.
44
Renter Households with Applicant Aged 62+
Disaster Damage Category Households
4263 Severe 15
Major-High 121
Major-Low 130
Minor-High 76
Minor-Low 117
Total 459
4277 Severe 265
Major-High 951
Major-Low 575
Minor-High 146
Minor-Low 246
Total 2,183
Grand Total 2,642
In addition to those elderly households, the state may also prioritize those populations with access and/or
functional needs to prioritize how it will assist the affected population. There are 1,268 renter households
with documented access and/or functional needs, representing more than 4 percent of the total impacted
renter household population.
45
Renter Households with Access/Functional Needs
Disaster Damage Category Households
4263 Severe 12
Major-High 54
Major-Low 57
Minor-High 38
Minor-Low 55
Total 216
4277 Severe 197
Major-High 407
Major-Low 233
Minor-High 70
Minor-Low 145
Total 1,052
Grand Total 1,268
46
Impact on Public Housing Authorities
The Louisiana Housing Corporation (LHC), in conjunction with HUD's New Orleans Field office, has
remained in constant contact with Public Housing Authorities (PHAs) throughout the impacted area. In
total, 13 of the state's 102 PHAs reported some disaster impact, impacting 132 households and displacing
95 households. Additionally, 16 Housing Choice Voucher (HCV) properties were affected, impacting 864
households and displacing 850 households.
Public Housing Assessment (Statewide)
Public Housing Housing Choice Vouchers Total
Total Properties/PHAs 102 91 193
Units 19,988 54,357 74,345
Properties/PHAs Impacted 13 16 29
Households Impacted 132 864 996
Households Displaced 95 850 945
HUD's New Orleans Field office provided an update relative to PHA damages and unmet needs on Jan. 17,
2017 (see table below). The state is committed to continued coordination with PHAs, particularly with
respect to assessing the unmet repair and rebuilding needs not otherwise covered by insurance or FEMA.
In addition, the state is committed to working with PHAs to develop and implement measures that will
make their units more resilient in the wake of future storms. With an understanding that many of the
individuals who reside in subsidized housing represent the most vulnerable residents of our state, it is of
the utmost importance to ensure that impacted PHAs are provided the tools and resources they need to
rebuild effectively and sustainably.
Seven multifamily public housing developments reported damage attributable to DR-4263 or DR-4277.
These facilities hold 619 total units, of which 300 were damaged. Two facilities, Livingston Manor and
Charleston Oaks, suffered damage to all of their units, while a third development, Tangi Village, suffered
damage to all but four units. Tangi Village, in particular, is notable as it was impacted by both disaster
HA Name
Insurance
Award
FEMA
Award
CFP
Reallocated
Funds
Operating
Funds
Available
COCC
Damages
Public
Housing
Damages
PH
Relocation
Costs
Additional
Funds
Needed
Months
to
Complete
Mod
Eunice $0 $0 $162,263 $750,000 $0 $2,297,500 $34,000 $1,419,237 24
New Iberia $0 $0 $0 $0 $0 $213,380 $0 $213,380
Rayne $0 $0 $0 $75,000 $0 $75,000 $2,000 $2,000 5
Crowley $73,864 $0 $0 $0 $0 $71,800 $0 $0 4
Ville Platte $0 $77,000 $0 $0 $0 $56,000 $1,619 $0 3
Welsh $0 $0 $0 $0 $0 $20 $0 $20 0
Lake Arthur $33,610 $0 $0 $0 $0 $44,937 $0 $11,327
Donaldsonville $0 $0 $26,858 $0 $0 $203,000 $0 $176,142 60
Erath $455,027 $0 $0 $0 $0 $406,903 $0 $0 5
Opelousas $0 $0 $0 $0 $0 $0 $0 $0
Denham Springs $2,900,000 $0 $0 $0 $265,000 $4,770,000 $0 $2,135,000 15
Jennings $0 $0 $8,000 $0 $0 $98,000 $0 $90,000
Duson $0 $0 $0 $0 $0 $0 $0 $0
Totals $3,462,501 $77,000 $197,121 $825,000 $265,000 $8,236,540 $37,619 $4,047,106
47
events (DR-4263 and DR-4277). Also notable, Cypress Gardens tested positive for mold, and will need to
be remediated. With the exception of Cypress Gardens, all units are expected to be back online by Q2
2017.
Multifamily Assessment (Statewide)
Total Units Total Damaged Percent Damaged
Bacmonila Gardens 150 35 23%
Tangi Village 96 92 96%
Livingston Manor 45 45 100%
St. Edwards Subdivision 98 38 39%
Charleston Oaks 30 30 100%
Cypress Gardens 100 4 4%
Shady Oaks 100 56 56%
Total 619 300 48%
The multi-family developments noted above are utilizing a number of funding sources to repair damaged
units, including flood insurance, USDA Rural Development loans, and HOME (via LHC). LHC is working
directly with the property management firms to determine where funding gaps exist and how to fill those
gaps.
Impact on Homeless Populations
The Point-in-time count is an annual count of sheltered and unsheltered homeless persons on a single
night conducted by Continuums of Care (CoC) across the United States. Louisiana has nine Continuums of
Care, which are regional planning bodies that coordinate housing and services for homeless families and
individuals. The list below provides the name of each CoC in the state, along with parishes and major cities
included within each CoC (http://www.dhh.louisiana.gov/assets/docs/OAAS/publications/regionalcontinuum-of-care-list.pdf).
>> Lafayette/Acadiana CoC - City of Lafayette, Acadia, Evangeline, Iberia, Lafayette, St. Landry, St.
Martin, St. Mary, Vermillion
>> Shreveport/Bossier/Northwest Louisiana CoC - City of Shreveport, Bossier City, Bienville, Bossier,
Caddo, Claiborne, DeSoto, Natchitoches, Red River, Sabine, Webster
>> New Orleans/Jefferson Parish CoC - City of New Orleans, Orleans, Jefferson, St. John, St. Charles,
St. James, Metairie
>> Baton Rouge CoC - East Baton Rouge, Ascension, West Baton Rouge, East and West Feliciana,
Iberville, Pointe Coupee
>> Monroe/Northeast Louisiana CoC - City of Monroe, Caldwell, East and West Carroll, Franklin,
Jackson, Lincoln, Madison, Morehouse, Ouachita, Richland, Tensas, Union
>> Alexandria/Central Louisiana CoC - City of Alexandria, Avoyelles, Catahoula, Concordia, Grant,
LaSalle, Rapides, Vernon, Winn
>> Houma-Terrebonne, Thibodaux CoC - Lafourche, Terrebonne, Assumption
>> Louisiana Balance of State CoC – Beauregard, Allen, Calcasieu, Jefferson Davis, Cameron, City of
Lake Charles, Plaquemines, St. Bernard, Natchitoches, and Sabine
According to the Jan. 25, 2016, Point-in-time count, a total of 3,994 people were counted as homeless,
with 1,444 counted in emergency shelters, 1,409 in transitional housing and 1,141 unsheltered.
48
To understand the homeless population prior to flooding within IA parishes and the 10 most impacted
parishes, this analysis counts CoCs that contain at least one IA or most impacted parish. Eight CoC's
contain IA parishes, with a total of 3,848 people counted as homeless (1,414 in emergency shelters, 1,296
in transitional housing, and 1,138 unsheltered). Four CoCs contain the 10 most impacted parishes, with a
total of 1,398 people counted as homeless (422 counted in emergency shelter, 719 in transitional housing,
and 257 unsheltered). 96 percent of people counted as experiencing homelessness on Jan. 25, 2016 were
within IA parishes, and 35 percent of the state's total people experiencing homelessness were within most
impacted parishes.
2016 Point in Time Count
Type of Shelter State of Louisiana
Continuums of Care
Containing IA Parishes
Continuums of Care
Containing 10 Most
Impacted Parishes
Emergency Sheltered 1,444 1,414 422
Transitional Housing 1,409 1,296 719
Unsheltered 1,141 1,138 257
Total Homeless Persons 3,994 3,848 1,398
Source: Department of Housing and Urban Development, CoC Housing Inventory Count Reports, 2016
https://www.hudexchange.info/programs/coc/coc-housing-inventory-count-reports/
To respond to DR-4263 and DR-4277, the LHC deployed staff of the Louisiana Housing Authority (LHA) into
disaster shelters to assist with closing those shelters without leaving affected populations homeless. In
response to the need of those who were pre-disaster homeless and precariously housed before the
flooding events, LHC/LHA set up two different programs that can be expanded to meet the needs of other
households that may find themselves in similar situations.
>> HOME TBRA – LHC allocated $500,000 of HOME funds to provide Tenant-Based Rental Assistance
(TBRA). To be eligible for assistance, households must be elderly or disabled, 30 percent Area
Median Income (AMI) or below and lack the financial resources to obtain the necessary housing.
There are currently 63 households issued a voucher. In order to provide these households with a
year of rental assistance and case management services, an additional $481,436 in unmet need
remains. There are 56 households currently on the waiting list for HOME TBRA. $2,209,116 is the
total budget to assist all 119 households with a year of rental assistance and case management
services, or $1,709,116 in unmet need. However, HOME TBRA allows up to two years of rental
assistance, requiring a total budget of $4,418,232, an unmet need gap of $3,918,232.
>> Rapid Re-Housing – LHC allocated $320,000 of Emergency Solution Grant (ESG) funds to provide
a Rapid Re-Housing (RRH) program for pre-disaster homeless and precariously housed flood
survivors. All households must have income at or below 30 percent AMI. There are currently 55
households issued a voucher for rental assistance and 19 households on a waiting list. LHC will
assist the 48 households with RRH for five months with the $320,000 allocation. Due to the lack
of long-term affordable rental units in the affected region, five months is an insufficient amount
of time to provide assistance. LHC anticipates adding an additional $200,000 from its FY2016
allocation to the RRH program. Even with the addition of these funds, there is still an unmet gap
of $1,332,000 to assist all 74 households for a 12-month period.
49
Daily phone calls and emails from flood impacted households that are now experiencing homelessness
continue to occur. The households that have reached out to LHC are actively added to the waiting list.
Other organizations assisting in flood recovery are also getting emails and phone calls. Additionally, the
number of households in need of RRH will continue to rise once FEMA's Transitional Sheltering Assistance
(TSA) ends. As of Jan. 19, 2017, there 1,093 households, representing 3,633 individuals checked in to the
TSA program. Households that are currently staying with family and friends are another population that
are at risk of homelessness as are households that are living in flooded and moldy homes. As the living
situations for these households become untenable, they will require alternate living arrangements and
will be in need of rental assistance.
The state understands that the full impact of the storms on the pre-disaster homeless and precariously
housed population will not be known for some time. Through the resources provided below, LHA is able
to provide interim assistance as the long-term housing solutions are finalized. The state is committed to
ensure that the needs of this population are met and will identify programs in future Action Plan
Amendments.
Additionally, there have been impacts to service providers. The Salvation Army in Baton Rouge, one of the
Capital Region's largest emergency shelters, flooded during DR-4277, taking on up to 7.5 feet of water. All
clients and staff were relocated. As a result, currently 24 emergency shelter beds and 50 transitional
housing units are offline. As the weather turns colder, more flood impacted households that are living in
untenable environments, like cars and tents, are expected to seek warmer places to stay, exacerbating
the need for safe housing options. With the Salvation Army rendered inoperable and unable to expand
for freeze night capacity, the state is concerned substantial populations at risk of homelessness will remain
unserved.
Focusing further on Baton Rouge, the City has surveyed some of the major homeless support agencies to
determine their client's needs post-flooding. The Volunteers of America (VOA) and the Bishop Ott St.
Vincent de Paul both reported a 29 – 30 percent increases in persons seeking housing and homeless
services. VOA reported that the number of calls per day seeking housing services have doubled from 100
to 200 and that they have no resources available to which to refer clients. In addition, VOA reported a 60
percent increase in persons classified with special needs requesting housing services. They have a waiting
list which continues to grow. Prior to the flood, VOA served 86 clients with mental health and substance
abuse issues. They have turned away 28 persons because of a lack of staff and operating funds to assist
these individuals. Currently, there are 58 persons on the emergency shelter grant waiting list.
Bishop Ott St. Vincent de Paul, with the help of the Red Cross, increased shelter beds for men by 58
percent after the flood. Monies to support the extra beds will end Dec. 30, 2016. Bishop Ott St. Vincent
de Paul serves between 1,300 – 1,400 homeless persons per year. Staff reported that, of the number of
new unique persons entering the shelter post-flood, between 20 – 50 percent of the extra beds are filled
with first-time homeless clients.
While the City has made great progress in reducing the number of homeless persons over the past 10
years, the flood has brought those numbers back to where they were in 2015. Additional shelter beds and
extended shelter stays are required because of the impact of the flood on pre-flood, precariously housed
residents, the shortage of housing, the increase in rental costs, and the reduction and termination of
FEMA, HUD, and Red Cross emergency services. All agencies reported the need for funding to increase
shelter beds, increase the number of case managers and support services needed to help the vulnerable
homeless in accessing housing and navigating the complex post-flood housing programs and resources.
During the East Baton Rouge Metro Council meeting in December 2016, the Council approved the
50
allocation of approximately $1 million of its CDBG-DR funding to provide funding to homeless agencies to
support the homeless. As of the date of this document, decisions regarding the specific uses of the
allocated funding have not yet been made. The state is currently working closely with East Baton Rouge
Parish to develop the final homelessness support program and will provide additional details as they
become available.
The state is actively working to gather additional information relative to the impacts to and unmet needs
of homeless populations across the state. LHA is in the process of reaching out to the CoCs identified
above to determine the extent of the need across the state.
Furthermore, the state is working in close coordination with the Disaster Case Management (DCM)
program, particularly as it relates to the households in the TSA program. Based on reports from the DCM
service providers, there are 678 renters and 415 homeowners in the TSA population.
Due to a host of factors, most notably the lack of available affordable rental units, the most vulnerable,
and potentially at-risk of homelessness, of the TSA population are those who are renters. They are unlikely
to be eligible for a number of housing solutions typically made available to homeowners and many no
longer have the FEMA Rental Assistance funds provided to them. In many cases, the rental assistance
funds were not utilized for the appropriate purpose due to other needs, meaning those individuals are
unlikely to be eligible for additional Rental Assistance funding.
The state recognizes the challenge of ascertaining the vulnerability index relative to predicting
homelessness. It is difficult to determine if the renters currently in TSA were independently housed with
any stability prior to the disaster or if they were precariously housed prior to the disaster. In addition, it
is not clear as to which of these were living in some sort of pre-disaster subsidized or supported housing
situation. These variables and situations, coupled with a reduction in available and affordable rental stock,
are ultimately what will be the best predictors of homelessness from within the TSA population.
FEMA staff working directly with households in the TSA program conducted overt 2,500 face-to-face visits
with applicants in hotels since Oct. 10, 2016. From those meetings, 515(21 percent) stated their primary
barrier was not being able to afford rentals. An additional 203 (8 percent) said they can't find rentals,
which often means they can't find rentals they can afford.
The state reviewed the data collected on the TSA population in an effort to determine which households
are most at-risk of homelessness once TSA benefits are no longer available. Due to the reasons stated
above, the state contends that uninsured renters are the most likely to be at-risk of homelessness once
the TSA program concludes. The chart below provides a breakdown of key aspects of the data collected
on the current TSA population.
51
The state is committed to providing temporary housing solutions and, wherever possible, permanent
housing to households that are homeless or at-risk of homelessness. Recognizing that, while a temporary
housing solution may meet an immediate need, the ultimate goal is to find permanent housing solutions
for individuals and families that are currently homeless or at-risk of homelessness. To that end, the state
will submit a formal request in the coming weeks for 1,000 permanent supportive housing vouchers.
Moving forward, the information gathered through the CoC outreach, coordination with the DCM
program, and other efforts will serve as the basis for additional requests and future allocation decisions.
Furthermore, the state received an extension to TSA until February 2017. With the approval of the
extension, the state has engaged with federal, state and local public and private agencies to work through
possible interim and long-term solutions for this population. The state has proposed two programs- the
Rapid Rehousing and Permanent Supportive Housing Support Services- within the Method of Distribution
which specifically address housing unmet needs faced by vulnerable populations either currently
experiencing homelessness or at-risk of becoming homeless. Additional long-term solutions that are
implemented by partner organizations and/or the state will be outlined in subsequent Action Plan
Amendments.
3. Unmet Housing Needs
In discussing a full scope of unmet housing needs, it is imperative to understand other resources that have
and will be expended, and where those resources have been and will be geographically deployed. To this
effect, as of Jan. 12, 2017, SBA has approved $664,634,100 in real estate structural loans.
Real Estate Structural Loans Approved by SBA (as of 1/12/17)
Disaster Parish
Approved Structural
Loan Amount
Number of
Approved Loans
52
4263 Allen $135,600 10
Ascension $496,300 32
Avoyelles $96,700
2
Beauregard $506,800 37
Bienville $269,000 29
Bossier $2,219,700 190
Caddo $1,629,900 148
Calcasieu $2,106,600 103
Caldwell $531,700 51
Catahoula $1,500 12
Claiborne $489,500 34
De Soto $223,100 21
East Carroll $30,600 29
Franklin $0
7
Grant $587,400 62
Jackson $0
0
LaSalle $235,400 18
Lincoln $73,700 19
Livingston $1,114,700 154
Madison $0
4
Morehouse $1,944,400 208
Natchitoches $1,984,600 113
Ouachita $20,285,700 1,224
Rapides $509,000 29
Red River $0
7
Richland $567,100 90
Sabine $112,300 16
St. Helena $48,600 77
St. Tammany $5,450,700 339
Tangipahoa $5,160,500 599
Union $1,819,800 119
Vernon $2,435,100 93
Washington $2,585,900 241
Webster $2,899,100 149
West Carroll $338,700 69
Winn $805,600 42
Total $57,695,300 4,377
4277 Acadia $3,184,600 285
Ascension $72,686,100 2,915
Avoyelles $221,200 26
Calcasieu $0
0
53
Cameron $0 0
East Baton Rouge $274,243,000 12,766
East Feliciana $1,603,800 152
Evangeline $897,400 67
Iberia $1,388,900 237
Iberville $849,100 82
Jefferson Davis $742,200 62
Lafayette $32,953,500 1,520
Livingston $187,068,300 7,260
Pointe Coupee $646,200 73
Rapides $0 0
St. Helena $1,198,800 198
St. James $102,500 18
St. Landry $2,424,700 217
St. Martin $2,976,300 241
St. Mary $0 1
St. Tammany $939,700 75
Tangipahoa $15,819,700 1,269
Vermilion $6,364,000 393
Washington $219,100 35
West Baton Rouge $36,600 10
West Feliciana $373,100 28
Total $606,938,800 27,930
Grand Total $664,634,100 32,307
Additionally, FEMA has provided housing assistance to eligible households through the IA program. As of
Nov. 22, 2016, FEMA had approved $651,261,396 in housing assistance through the IA program.
IA Housing Assistance Approved (as of 11/22/16)
Disaster Total Approved
DR-4263 $ 72,992,887
DR-4277 $ 578,268,509
Total $ 651,261,396
As previously presented, to calculate anticipated unmet needs for the owner-occupied household
population, this analysis defers to HUD's methodology described in the Federal Register Notice (FRN) for
these two disaster events. Under this methodology, for each household determined to have unmet
housing needs, their estimated average unmet housing need less assumed assistance from FEMA, SBA,
and Insurance was calculated at $27,455 for major damage (low); $45,688 for major damage (high); and
$59,493 for severe damage. Therefore, as this methodology already contemplates unmet needs
accounting for other forms of assistance, this analysis does not incorporate resources deployed by FEMA,
SBA or NFIP. Data is not currently available respective to estimated needs at the minor-high and minorlow
categories. While the state is currently relying on the best available data from federal agencies for
54
this information, ultimately the assessment of the homeowner unmet needs will be updated once the
program has conducted a survey of impacted homeowners and started application intake. It is anticipated
the program survey and first phase of applications will be launched in the second quarter of calendar year
2017.
Owner-Occupied Households Unmet Need Calculation
Disaster Damage Category Households Estimated Needs
4263 Severe 675 $ 40,157,775
Major-High 2,276 $ 103,985,888
Major-Low 3,979 $ 109,243,445
Minor-High 1,503 $ -
Minor-Low 8,029 $ -
Total 16,462 $ 253,387,108
4277 Severe 11,249 $ 669,236,757
Major-High 24,270 $ 1,108,847,760
Major-Low 15,182 $ 416,821,810
Minor-High 3,849 $ -
Minor-Low 13,830 $ -
Total 68,380 $ 2,194,906,327
Grand Total 84,842 $ 2,448,293,435
Additionally, the FRN methodology contemplates unmet needs for rental housing units occupied by
households with incomes less than $20,000. As outlined in the map and table below, there are 13,721
such households impacted by DR-4263 or DR-4277, with high concentrations of these populations located
in the Monroe and Baton Rouge metropolitan areas. However, the FRN methodology does not
contemplate a specific dollar amount for these unmet rental needs. Therefore, in the Initial Action Plan,
the state used the best available data from the Disaster Housing Task Force, a task force that includes
representatives from the Louisiana Housing Corporation, HUD, FEMA and other state, federal and local
partners. According to this task force, the average unmet need to repair a rental unit is $17,000.
The state has updated its analysis to include an average cost of unmet need per rental unit to include data
received from the SBA on businesses listed under NAICS code 531110 (lessors of residential buildings and
dwellers). Using aggregated and average information on SBA verified real estate loss for rental properties
($20,431), multiplying that average loss by the number of rental housing units with a FEMA verified loss
(28,470), the total loss and need for rental repair is estimated to be $581,670,570. When the state
subtracts the total actual amount of funding approved by SBA for real estate assistance to residential
landlords ($47,942,000), there is an estimated unmet need of $533,717,970, or an average of $18,570 per
unit. This estimate does not include a deduction for assumed proceeds from NFIP or private flood
insurance. Using this assessment, the state has updated the estimated unmet needs of rental repair units
from $17,000 per unit to $18,570. Using this revised average unmet need to repair a rental unit ($18,570)
and multiplying it by the population identified and contemplated through the FRN (13,721), the total
unmet rental repair need for the March and August 2016 flooding events is estimated to be $254,798,970.
55
Renter Households Income <$20k
Disaster Damage Category Households
4263 Severe 128
Major-High 619
Major-Low 737
Minor-High 566
Minor-Low 1,074
Total 3,124
4277 Severe 1,397
Major-High 3,238
Major-Low 2,999
Minor-High 975
Minor-Low 1,988
Total 10,597
Grand Total 13,721
This analysis estimates a rental and owner housing unmet need of $2,708,342,637. Given the unique
attributes of these two disasters (low rates of affected populations with flood insurance, high rates of
affected populations located outside the SFHA), it is reasonable to view this unmet need estimation as a
56
floor, rather than a ceiling. Additionally, over time, and as more detailed information becomes available,
the state will continue to work with various stakeholder groups, affected populations and HUD itself to
further refine this estimate.
Housing Unmet Need Summary
Category Amount Relative Percentage of
Unmet Housing Need
Owner-Occupied $ 2,448,293,435 90.4%
Renter $ 254,798,970 9.4%
Homeless Assistance and Prevention $
$5,250,232 0.2%
Total $2,708,342,637 100%
C. Economic Impact & Needs
1. Statewide Economic Damage & Loss Assessment
Immediately following the August event, the Louisiana Department of Economic Development (LED)
partnered with Louisiana State University (LSU) to conduct an assessment of economic damages resulting
from the DR-4277 flooding event. Key details are:
>> At the peak of the August event, 19,900 Louisiana businesses or roughly 20 percent of all Louisiana
businesses were disrupted by the flooding event. FEMA has since referred approximately 22,000
businesses to SBA for recovery assistance.
>> A disruption of 278,500 workers or 14 percent of the Louisiana workforce occurred at the peak of
the flooding event.
>> An economic loss estimated at roughly $300 million in labor productivity and $836 million in terms
of value added during the period immediately surrounding the flood.
>> Approximately 6,000 businesses experienced flooding.
>> The LSU Ag Center estimates Louisiana agricultural losses of over $110 million.
Throughout the event, severe weather, flooding and resources redirected to response efforts led to
business interruption losses across the region. To characterize those losses, LED and LSU estimated the
percent of businesses closed each day based on the extent of flooding drawn from the Governor's Office
of Homeland Security and Emergency Preparedness (GOHSEP) and FEMA flood maps as well as the
duration of the flooding based on flood level exceedances from USGS streamgages along rivers and bayous
across the impacted area. However, closures extended beyond those businesses directly impacted by
flooding due to road closures and the severe weather that disrupted travel for both employees and
customers. To assess these broader disruptions, LED and LSU reviewed situation reports from the
GOHSEP, school closures and government closures.
These estimated industry closures were then adjusted by industry sector to account for the fact that some
sectors were closed entirely while other sectors (e.g. large manufacturing facilities) generally continued
to operate at normal, or close to normal capacity. To characterize these business interruption losses, LED
and LSU estimated the number of businesses and employees impacted each day as well as the lost worker
productivity, measured in terms of wages. While a number of these employees receive pay even if they
were not working, the worker's productivity is lost to the employer – thus creating losses to the region.
57
Of the most impacted parishes, East Baton Rouge and Livingston had the greatest impacts. Livingston,
specifically, was acutely impacted with peak impacts in that parish occurring later in the event, as
floodwaters continued to rise and also receded more slowly in some areas. Livingston was also most
acutely impacted with a large majority of businesses disrupted to some degree, and more than half of
businesses potentially flooded. The severity of flooding creates a greater risk of long-term closure, which
can lead to business failure and long-term negative impacts to the region's economy.
Peak Disruption by Parish (DR-4277)
Parish Businesses Employees
East Baton Rouge 8,000 143,700
Lafayette 3,100 40,000
Livingston 1,800 18,700
Tangipahoa 1,500 17,000
Ascension 1,200 17,100
St. Tammany 900 8,000
Iberia 600 8,200
St. Landry 600 6,300
Acadia 400 3,900
Vermilion 400 3,700
St. Martin 400 3,100
Jefferson Davis 300 2,200
Evangeline 200 1,500
Iberville 100 2,000
Avoyelles 100 1,200
East Feliciana 100 800
Pointe Coupee 100 400
Washington <100 300
St. Helena <100 200
West Feliciana <100 200
Total 19,900 278,500
Business & Wage Losses
As flooding impacted different areas at different times, the peak number of businesses and employees
impacted by DR-4277 is larger than was seen at any specific point in time. In total, approximately 19,900
businesses in Louisiana experienced temporary closures, or significant operational reductions. These
businesses employ approximately 278,500 workers. While many employers may have continued paying
employees during closures, some hourly workers may have experienced reduced pay. LED and LSU
estimated that 45,000 to 75,000 of these employees work at businesses that experienced flooding and
periods without pay, or with reduced pay. At this time, the State does not have access to comparable loss
data for DR-4263.
Lost Productivity and Value Added (DR-4277)
Parish Lost Labor Productivity Lost Value-Added
East Baton Rouge $ 213,000,000 $ 540,200,000
Livingston $ 27,000,000 $ 97,800,000
Ascension $ 24,900,000 $ 68,500,000
58
Tangipahoa $ 17,400,000 $ 62,200,000
Lafayette $ 8,600,000 $ 31,100,000
St. Tammany $ 2,900,000 $ 8,400,000
Iberia $ 1,800,000 $ 8,000,000
Iberville $ 1,100,000 $ 2,900,000
St. Landry $ 1,000,000 $ 3,300,000
Vermilion $ 700,000 $ 2,700,000
Acadia $ 600,000 $ 2,400,000
St. Martin $ 500,000 $ 2,500,000
Avoyelles $ 400,000 $ 1,600,000
Jefferson Davis $ 300,000 $ 1,700,000
East Feliciana $ 300,000 $ 900,000
Evangeline $ 200,000 $ 900,000
Pointe Coupee $ 100,000 $ 500,000
Washington $ 100,000 $ 400,000
St. Helena $ 100,000 $ 200,000
West Feliciana $ 100,000 $ 200,000
Total $ 300,900,000 $ 836,400,000
Total regional impacts attributable to lost labor productivity and lost value-added were compiled for the
first three weeks of the event, providing a rough picture of the gross negative impacts of disruptions to
the area. Lost labor productivity is estimated to be $300 million and lost value-added is estimated to be
$836 million. During the three-week period measured, this represented approximately 6 percent of all
economic activity in the state.
To estimate damage to businesses, LED and LSU relied on GOHSEP flood maps and FEMA flood maps, as
well as flood maps published by parishes in the flooded area. Researchers then overlaid infoUSA point
level data on business locations for the impacted parishes to estimate the extent of business flooding in
each parish. The total number of businesses estimated to have flooded is 6,100 across the 20 parish area.
It is worth noting that 60 percent of businesses in Livingston parish are estimated to have experienced
some flooding and 19 percent of those in Ascension as well as 15 percent of those in East Baton Rouge,
the parish with by far the largest overall number of businesses in the impacted area.
Data from the Bureau of Economic Analysis was used to estimate the value of business structures and
equipment based on the size of employer and industry. LED and LSU estimated damage to business
structures totaled $595.6 million and damage to fixed equipment will add another $262.8 million to
business losses.
Many businesses experiencing flooding lost substantial inventories, which were estimated based on the
sales of impacted businesses and data from the Bureau of Economic Analysis that relates average
inventories to sales for businesses in manufacturing, wholesale trade and retail trade. LED and LSU
estimated a total of $1.4 billion in inventory damaged by DR-4277 flooding. This figure represents an
average of over $200,000 in inventory for each flooded business. While many impacted businesses were
likely smaller businesses that would have significantly lower inventories, a relatively small number of large
wholesalers and retailers with substantial inventories can heavily skew the average relative to the typical
loss. For example, the Dixie RV Superstore, a recreational vehicle dealership in Hammond estimated as
much as $30 million in damage attributable to a large portion of their vehicular inventory being flooded.
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Similarly, stores like the Walmart and Home Depot in Denham Springs flooded and would have lost
inventory values much higher than what is typical across the 6,000 businesses that flooded.
Agricultural Losses
In response to DR-4263 and DR-4277, Kurt M. Guidry of the LSU AgCenter conducted impact estimates on
Louisiana's agriculture sector. Following DR-4263, 24 parishes reported agribusiness impacts totaling an
estimated loss of $80 million. The March 2016 flood event occurred at the beginning of the year's planting
season, impacting pasture and livestock infrastructure, causing livestock deaths and requiring extensive
replanting of crops. Extensive rainfall after the event further exacerbated crop problems, delaying
replanting past normal planting windows and reducing crop yields.
The LSU AgCenter and Farm Service Agency surveyed damages specific to DR-4263. The table below
provides details on the acreage impacted by crop. Overall, almost 90,000 acres of crops were impacted
by the flooding event.
DR-4263 Crops Impacted
Crop Acres Impacted
Corn 7,545
Cotton 7,960
Soybeans 18,000
Pasture 52,200
Rice 2,000
Sorghum 2,000
Total 89,705
Following DR-4277, the LSU AgCenter estimated impacts to the agricultural sector to exceed $110 million.
This estimate is conservative, as it only included selected commodities including rice, soybeans,
sugarcane, sweet potatoes, fruits and vegetables, corn, sorghum, cotton and lost grazing days for
livestock. The economic estimates used acreage, historic yields and pricing data to predict yield loss
resulting from DR-4277.
Estimated Agricultural Losses
Crop DR-4263 DR-4277
Corn $43,454,125 $10,901,631
Soybeans $25,182,504 $46,754,976
Cotton $117,077 $3,695,816
Sorghum $251,771 $417,931
Rice $7,240,111 $33,624,629
Sweet Potatoes $401,200 $4,465,247
Wheat $3,638,397 N/A
Sugarcane N/A $3,203,320
Grazing N/A $1,973,528
Fruits/Vegetables N/A $5,206,991
Total $80,285,185 $110,244,069
OCD-DRU is working with the LSU AgCenter and its partners to gain a clearer understanding of impacts
and unmet needs across Louisiana's agriculture sector. To that end, information is being collected relative
to crop loss insurance policies, the Non-insured Crop Disaster Assistance Program (NAP) and any payments
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made to livestock, aquaculture, bee keepers and others under permanent disaster assistance programs.
A coordination of efforts and sharing of information amongst USDA' Risk Management Agency, the Farm
Service Agency, and LSU AgCenter will enable OCD-DRU to assess the impacts of DR-4263 and DR-4277
and accurately target recovery funds to address the greatest needs.
Combined Losses
Economic Loss Summary
Category Loss Estimate
Agriculture (DR-4277) 110,200,000
Agriculture (DR-4263) $ 80,285,185
Business Structures $ 595,600,000
Business Equipment $ 262,800,000
Business Inventories $1,425,500,000
Business Interruption Loss $ 836,400,000
Total $3,310,829,254
2. Unmet Economic Needs
As with housing, in discussing a full scope of unmet economic needs, it is imperative to understand other
resources that have and will be expended, and where those resources have been and will be
geographically deployed. To this effect, as of Dec. 30, 2016, SBA had approved $160,400,000 in Business
and Economic Injury Disaster Loans (EIDL) to affected populations from DR-4263 and DR-4277. Highest
concentrations of these approvals have been in the Baton Rouge Capital Region and in the metropolitan
Lafayette region. In addition, OCD-DRU is working to gather data relative to private insurance claims in
order to more accurately identify the remaining unmet needs of the business community.
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SBA Business/EIDL Loans (as of 12/30/17)
Disaster Parish
Number
of Loans
Total Loan
Amount
4263 Ascension 2 $39,700
Ashley 1 $18,200
Beauregard 1 $39,000
Bienville 1 $25,000
Bossier 8 $709,500
Caddo 11 $537,100
Caldwell 3 $79,400
Cameron 1 $25,000
Catahoula 1 $14,300
Grant 1 $25,000
Lincoln 3 $91,000
Livingston 1 $25,400
Morehouse 13 $1,240,600
Natchitoches 8 $462,000
Ouachita 84 $8,022,500
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Rapides
3 $100,700
Red River
1 $115,300
Richland
3 $101,400
Saint Tammany 13 $1,903,100
Tangipahoa 13 $528,700
Union
6 $242,800
Vernon
4 $201,300
Washington 14 $557,500
Webster
5 $111,500
West Carroll
2 $54,000
Winn
3 $424,800
Total 206 $15,694,800
4277 Acadia 19 $755,300
Ascension 111 $7,711,200
Avoyelles
1 $18,700
Calcasieu
2 $37,000
East Baton Rouge 774 $77,951,500
East Feliciana
6 $284,300
Evangeline
4 $179,000
Iberia 14 $802,500
Iberville
2 $76,000
Jefferson
1 $65,300
Jefferson Davis
4 $178,200
La Salle
1 $24,200
Lafayette 95 $6,166,800
Livingston 361 $41,577,400
Orleans
1 $15,100
Pointe Coupee
9 $751,300
Saint Helena
6 $432,700
Saint Landry 10 $650,400
Saint Martin 13 $1,232,200
St John The Baptist
1 $25,000
Tangipahoa 48 $4,836,900
Vermilion 16 $745,100
Washington
2 $34,300
West Baton Rouge
3 $225,200
Total 1,504 $144,775,600
Grand Total 1,710 $160,470,400
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Accounting for resources disbursed through SBA loans, this analysis estimates an unmet economic need
of $3,150,429,254. Note, this analysis contemplates that a portion of these needs may have been
mitigated by resources disbursed through NFIP. These resources are discussed in the subsequent section
outlining the state's total unmet need calculation.
Economic Unmet Need Summary
Category Amount
Agriculture Losses $ 190,529,254
Business Losses $ 3,120,300,000
SBA Loans $ (160,400,000)
Total $ 3,150,429,254
D. Infrastructure Impact & Needs
1. Statewide Infrastructure Damage & Loss Assessment
Infrastructure Systems affected by DR-4263 and DR-4277 included damage and disruptions to levees,
roadways and bridges (especially rural roadways), culverts, utilities, wastewater treatment systems,
drinking water treatment and collection systems. Across Louisiana, flood basins were overwhelmed by
record-breaking or near record-breaking rainfall. In some of the coastal parishes, the runoff of rain was
compounded by southern winds that elevated tidal basins and thus inhibited drainage runoff.
Damages to roadways and bridges inflicted the most significant damages. Impacts to Interstates 10, 49,
and 20 rendered vehicle traffic into and out of Louisiana impossible for multiple days during the height of
each flooding event. During and in the aftermath of DR-4263, the Red River was rendered unnavigable for
several days. Multiple railways across the state were unable to safely pass cargo due to elevated flood
waters. In addition, data showed indications of stress and wear on many urban drainage systems.
2. Unmet Infrastructure Needs
FEMA Public Assistance
The FEMA Public Assistance (PA) Program is designed to provide immediate assistance to the impacted
jurisdictions for emergency work and permanent work on infrastructure and community facilities. For DR4263,
the state's obligation has been established as not less than 25 percent of eligible project costs. For
DR-4277, the state's obligation has been established as not less than 10 percent of eligible project costs.
As of Nov. 21, 2016, $36,501,492 has been identified in PA need for DR-4263 and $247,039,464 has been
identified for DR-4277. GOHSEP estimates these totals to rise to $93,751,791 for DR-4263 and
$750,000,000 for DR-4277. Based on these data, the current unmet need is $12,167,167 for DR-4263 and
$27,448,829 for DR-4277. Long term, based on GOHSEP's projections, the state estimates this unmet need
to grow to $31,250,597 for DR-4263 and $83,333,333 for DR-4277, respectively, for a grand total of
$114,583,930. The PA match unmet needs provided by GOHSEP and calculated by OCD-DRU are estimates
at this time, based on current best available data and an understanding of the match needs. However, the
state will work with GOHSEP, local governments, non-profit organizations and other entities eligible for
FEMA PA to gather additional information related to needs as projects are reviewed and approved
through the Project Worksheet process. The state will be able to update and identify the actual unmet
needs related to the FEMA PA match once the CDBG-DR-funded FEMA PA Match program is underway
and the state receives information directly from the applicants to that program.
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PA Intake & Projections (as of 12/28/16)
Disaster Category Total PWs Federal Share State Share
4263 (25% State Share) A 80 $4,016,450 $1,338,817
B 214 $16,760,650 $5,586,883
C 241 $12,861,249 $4,287,083
D 10 $1,091,779 $363,926
E 104 $3,031,827 $1,010,609
F 65 $1,895,337 $631,779
G 44 $2,849,768 $949,923
Z 1 $792,857 $264,286
Current 4263 Total 759 $43,299,917 $14,433,306
Projected 4263 Total 909 $96,460,853 $31,096,475
4277 (10% State Share) A 29 $59,113,326 $6,568,147
B 165 $215,005,895 $23,889,544
C 41 $1,637,874 $181,986
D 5 $565,686 $62,854
E 55 $4,165,270 $462,808
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F 20 $488,875 $54,319
G 2 $73,711 $8,190
Z 1 $5,636,250 $626,250
Current 4277 Total 318 $286,686,887 $31,854,099
Projected 4277 Total 1,224 $750,000,000 $75,000,000
Current Grand Total 1,077 $329,986,804 $46,287,404
Current Projected
Grand Total
2,133 $846,460,853 $106,096,475
Hazard Mitigation Grant Program
The Hazard Mitigation Grant Program (HMGP) will be a critical part of the long-term recovery process in
both rebuilding and protecting housing stock and vital infrastructure. These grant funds are calculated at
15 percent of the total FEMA Individual Assistance and Public Assistance allocations attributable to DR4263
and DR-4277. As of Nov. 15, 2016, the state had received an award letter from FEMA indicating a
$26,117,655 grant in response to DR-4263. Additionally, the state estimates it will receive an additional
$252 million HMGP grant in response to DR-4277.
Unlike PA, the state's obligation for both DR-4263 and DR-4277 has been established as not less than 25
percent of eligible project costs. Therefore, the state's unmet need estimate is $8,705,885 for DR-4263
and $84 million for DR-4277, with a combined total in excess of $92.7 million.
HMGP Award & State Share
Disaster Federal Share State Share
DR-4263 $ 26,117,655 $ 8,705,885
DR-4277 $ 252,000,000 $ 84,000,000
Total $ 278,117,655 $ 92,705,885
Therefore, this analysis contemplates a total unmet infrastructure unmet need gap of $207,289,815.
Infrastructure Unmet Need Summary
Category Amount
PA Cost Share $ 114,583,930
HMGP Cost Share $ 92,705,885
Total $ 207,289,815
3. Resilience Gaps
Broadly, the state recognizes DR-4263 and DR-4277 have exposed a wide array of resilience gaps within
the communities affected by these two events. Specifically, these gaps include needs for planning and
implementation of strategically-focused projects and programs at all scales, from individual investments
at the household level to large-scale structural investments designed to impact entire watersheds. These
will include basin-wide planning and modeling initiatives in all impacted areas to provide the best
information necessary to make wise DR investment decisions delivering optimal benefits. The ultimate
purpose of the investments is to reduce floodplain risk exposure throughout the entire impacted region,
reducing the necessity of structure elevations while protecting the substantial long-term recovery
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investments to be made with private and public funds over the next several years as a result of DR-4263
and DR-4277.
Such an approach envisions need for both structural and nonstructural interventions. Structural
investments may include large-scale diversions, retention/detention ponds and canals, channel
modifications and other large and small-scale structural approaches. Nonstructural strategies may include
an elevation program for those households substantially damaged within the floodplain, flood-proofing,
voluntary buy-outs of high risk properties, modified building codes, land-use planning and management,
targeted infrastructure investments, technical and staffing support, small-scale retention and detention
techniques for homes and businesses and public outreach and education efforts. Nonstructural
approaches are expected to reduce risk by reducing the need for elevations and by creating a greater
buffer between assets and floodplains.
Predicting what types of programs and projects will be funded and at what level is premature prior to
modeling for current and future risk within the state's affected watersheds and floodplains. Once these
efforts have been undertaken, and the state is able to apply specific measures within risk models to
determine optimal return on investment with respect to future damages and resilience, the state will
propose a full slate of resilience-oriented investments paired with demonstrable measures of
effectiveness.
It is important to note that the state is already applying planning funds to the process of better
understanding the impacted basins in anticipation of funding to implement these strategies.
Generally, the state has identified five general types of resilience-building activities for potential CDBGDR
investment:
Structural Investments to Address Regional Watershed Protection
Currently, there are three major diversion projects under consideration across southern Louisiana. Two
diversion projects, which will be located at the southern reaches of the Mississippi River, have recently
received $250M in funding as a result of the Deepwater Horizon settlement with British Petroleum. The
Mississippi diversions are intended to divert sediment and create new land. There is also a project plan in
place to divert floodwaters from the Comite River in East Baton Rouge Parish to the Mississippi River.
According to best data available to the state, the Comite River diversion project, if it had been
implemented prior to the August flooding event, potentially could have substantially reduced the
disaster's impacts in the Baton Rouge metropolitan area.
In addition to diversions, reservoir creation and channel modification projects have been used to help
reduce flood levels in the floodplain. Such projects have been identified within the most-affected areas,
and like the Comite River diversion, could have substantially mitigated the disaster's impact had they been
implemented prior to the August event.
Resilience Add-Ons to Planned Public Infrastructure Projects
The state will strive for all public buildings erected with CDBG-DR funds to be certified LEED to ensure
lower water and power bills as well as healthy indoor air quality for residents. In addition, the state will
encourage the incorporation of a combined heat and power (CHP) system, which will be designed to
continue providing a reduced level of electricity and cooling to the building in the event of a grid/power
outage, in the construction of houses or complexes. By incorporating smart-grid designs, the state would
seek to lower its overall energy risk profile, mindful of the frequency in which it experiences outages
attributable to significant disaster events.
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Stormwater Retention by Household
At 62.45 inches of rain per year, Louisiana experiences some of the highest annual rainfall in the country,
as evidenced by DR-4263 and DR-4277. Stormwater runoff during heavy rain events causes flooding that
affects the well-being, property, and livelihood of every inhabitant. Outdated stormwater and pumping
systems, designed to alleviate flooding, are often overwhelmed during heavy rains. Not only are these
systems costly, outdated, and inadequate for the high levels of rain, but they have become recognized as
one of the main causes of subsidence.
One approach to addressing the abovementioned issues is implementing stormwater management
projects and programs at the individual household level. Individual household measures can help keep
rainwater out of drainage systems, reducing overall system requirements.
Like natural systems, stormwater management projects and programs can contribute to diverting,
holding, and moving excess stormwater. If one household were to purchase and regularly use a rain barrel
every day, that household would likely not be able to fully address all of their stormwater needs. However,
if all households were to implement stormwater management measures to help slow the flow of water
to the drainage system, the demands on the management system are dramatically decreased.
According to sources at the Urban Conservancy (UC), a nonprofit in New Orleans that helps individual
households address their stormwater management needs, this systematic approach can be done in steps.
Step number one, according to the UC, is the elimination of excess paving. Large amounts of impermeable
concrete keeps water from flowing back into the natural system and quickly pushes large amounts of
water to the drainage system where it can overload the system, causing flooding. Where hard surfaces
are necessary, like for parking, installation of permeable pavement can reduce flow to drainage systems.
Permeable paving uses interlocking, recycled materials to create a grid in place of the old impermeable
surfaces, and instead of filling that grid with concreate, they instead fill it with different types of
permeable gravel. This gravel allows for the flow of rainwater back into the natural system. In other words,
permeable paving functions practically like concrete, while allowing infiltration of the rain that falls on it.
The third step recommended by the UC is to divert roof run-off into featuressuch as rain barrels, retention
ponds and rain gardens where the water is held and then released or used at a later date.
In anticipation of a large-scale suite of programs designed to effectuate rehabilitation of single-family
homes and businesses impacted by the two flooding events, it would be prudent to embed these
resilience-building, flood-mitigating principles into the deployment of such a homeowner rehabilitation
effort.
Community Stormwater Retention
The recommendations made at the individual level, community level projects to address stormwater
retention and management must be addressed systematically. If one household were to implement all of
the abovementioned recommendations their household would only be managing stormwater at a small,
lot sized scale. If a community as a whole can begin implementing these projects on an intersection-byintersection,
or the neighborhood-by-neighborhood scale, such activities can have a real, demonstrable
impact on the community's flood risk profile.
Another way to promote resilient communities through community level projects can be found in the
NDRC application for the City of New Orleans. In the application, the City of New Orleans made several
recommendations for community level resilience measures. Below is a list:
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>> Blue-Green Parklands – Construct a series of large-scale Blue-Green Parklands on underutilized
sites for significant water storage, ecological benefit and recreational opportunities.
>> Blue-Green Corridors – Install blue or green infrastructure where underutilized sites are located.
>> Neighborhood Networks – Develop a network of green infrastructure interventions in a
concentrated scale.
>> Canals – Transform existing drainage canals into public waterfronts.
Additional recommendations may include:
>> Remove excess paving and impermeable surfaces and replace with permeable surfaces at
locations that are burdened with large amounts of concrete/asphalt such as: Churches,
supermarkets, retail stores, schools, businesses, and community centers.
>> Similar to the City of New Orleans' Blue-Green Parklands and Corridors, take empty lots and/or
blighted properties, and turn them into green space, blue space, and public amenities.
>> Other areas concrete would be used such as sidewalks, basketball or tennis courts, picnic sights
etc., use permeable surfacing.
>> Leverage existing programs, such as the Urban Conservancy's Building Active Stewardship in New
Orleans (BASIN) program or Green Light New Orleans' rain barrel and green light bulb
replacement installation programs, to name a few.
Planning and Flood-Risk Modeling
Planning with LA SAFE
Through this recovery efforts, the state would also seek to leverage its own activities through its National
Disaster Resilience award. Already funded by HUD, the LA SAFE Framework focuses on three typologies –
Reshaping, Retrofitting, and Resettlement – using a forward-thinking, risk-based approach to guide the
state's future land use and development patterns. Areas projected to experience in excess of 14 feet of
flooding in a 100-year storm event 50 years from now are areas in which the state generally recommends
community resettlement projects, like the one it has commenced for the Isle de Jean Charles community
in Terrebonne Parish. Areas projected to experience between 3 feet and 14 feet of flooding in a 100-year
storm event 50 years from now are those in which the state plans to facilitate holistic and strategic
adaptations around the social, cultural and economic assets which it cannot abandon. Areas projected to
experience less than 3 feet of flooding in a 100-year storm event 50 years from now are those in which
the state plans to incentivize future economic and population growth. We know we cannot eliminate
Louisiana's flood-risk profile, but we must preserve – and when possible expand – economic and
community development opportunities in moderately vulnerable areas, while incentivizing population
and economic growth in those areas minimally at risk.
Coastal Protection and Restoration Authority (CPRA) & CLARA
The 2012 Coastal Master Plan, which is being updated for 2017, was based on state-of-the art science and
analysis, and its modeling process provides a holistic understanding of our coastal environment today
while anticipating changes expected over the next 50 years. The Coastal Louisiana Risk Assessment
(CLARA) model is a quantitative simulation model of storm surge flood risk developed by the RAND
Corporation. In the Coastal Zone, this is the model upon which LA SAFE relies. However, the state must
take a more holistic, watershed-based approach to flood-risk modeling, especially in light of these two
rain events in March and August.
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Riverine Flood Modeling – USGS
The CLARA model outlined above does a good job of projecting risk for coastal Louisiana; however, this
modeling system does not consider the risk of riverine flooding from rainfall, which is what occurred in
Louisiana in March and August. The United States Geological Survey (USGS), through their Flood
Inundation Mapping (FIM) Program, provides one option to help the state better understand its riverine
flood risk in the future. Others include The Water Institute of the Gulf, and the Corps of Engineers, all of
which are under consideration at this time. All investments in protective and resilient infrastructure will
be made based on the results of extensive modeling and cost benefit analysis.
Summary of Unmet Resilience Need Gaps
Based on the categories of resilience need gaps articulated above, the State anticipates a total unmet
need of $600,000,000. This total has been derived based on the following:
>> Structural Investments ($75,000,000): This estimate is based on an assumption such structural
investments would be paired with other sources of funding, including but not exclusive to those
articulated in the State's 2017 Coastal Master Plan.
>> Resilience Add-Ons to Planned Infrastructure ($132,915,926): As outlined in the section
documenting unmet infrastructure needs, the State anticipates a total investment of
$1,329,159,261 through FEMA's PA and HMGP programs in conjunction with DR-4263 and DR4277
recovery efforts. Based on similar initiatives in past disaster recovery environments, the
State believes these resilience-building add-ons would increase total project costs by 10%.
>> Household Stormwater Retention ($122,414,672): As outlined in the section documenting unmet
housing needs, the State anticipates a total unmet need of $2,448,293,435 for affected owneroccupied
units. The State believes retention adaptations would increase these project costs by
5%.
>> Community Stormwater Retention ($239,669,402): This estimate is based on the State's
historical precedence in implementing neighborhood-level water management projects,
specifically those following hurricanes Katrina, Rita, Gustav and Ike.
>> Planning & Flood-Risk Modeling ($30,000,000): This estimate is comparable with scale of the
State's Comprehensive Resiliency Pilot Program, implemented following hurricanes Gustav and
Ike. Given the comparable nature of the large geographic areas impacted by both Gustav and Ike
and DR-4263 and DR-4277, the State believes these needs are roughly comparable to one another
in terms of programmatic scale.
These gaps have been summarized as follows:
Resilience Unmet Need Gaps
Category Amount
Structural Investments $ 75,000,000
Resilience Add-Ons to Planned
Infrastructure $ 132,915,926
Household Stormwater Retention $ 122,414,672
Community Stormwater Retention $ 239,669,402
Planning & Flood-Risk Modeling $ 30,000,000
Total $ 600,000,000
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E. Public Service Unmet Needs
Through the implementation of the National Disaster Recovery Framework (NDRF), the state, along with
FEMA and GOHSEP, have held Community Planning and Capacity Building meetings state wide in
accordance with Recovery Support Function 1 (RSF 1). The RSF 1 meetings occurred with Ascension Parish,
the Town of Sorrento, the City of Gonzales, the City of Denham Springs, Livingston Parish, and St.
Tammany Parish. As a result of these meetings, the leadership and key staff of all impacted communities
have identified needs in all service areas handled by a government entity, such as the flooding of fire,
police stations and other government buildings, which provide key public services to citizens as well as
large-scale infrastructure projects that will need to be implemented in order to recover.
Funding is a severe handicap, especially compounded by the fact that sales tax and other revenue streams
to local government have declined, or are expected to decline, once the initial buying of cars, building
materials, etc., subsides. Therefore, the approved budgets for the upcoming fiscal year are having to be
revisited and modified, which includes the deferral of planned projects and a potential decrease in staffing
for fire and police and other services to meet the immediate recovery needs of the parishes. For example,
in Livingston Parish alone, the parish lost a minimum of 10 fire trucks, 33 police vehicles, 61 school buses
and 20 other parish-related vehicles which will need to be replaced, impacting the funding for other
projects.
Due to the limited funding available to address the full breadth of recovery needs, the state is not
prioritizing funding to address the public service needs described above. However, in anticipation of
additional funding being made available, OCD-DRU will be implementing a program by which it will
provide funding to cover the non-federal share of FEMA Public Assistance projects. Funds will be provided
as payment to state or local entities for eligible activities within approved Project Worksheets. The match
funding will lessen the financial burden placed on the entities and assist them to continue normal
operations and address recovery needs.
In addition to those public services traditionally provided by units of local government, through
experience with disaster events in the past, the state understands that following a storm event, there is
an increased need for mental health services, legal counseling and title services, housing counseling, job
search and connection services as well as training for those residents who may have lost their source of
employment as a result of the disaster events.
The FEMA-funded Disaster Case Management (DCM) program implemented by the Louisiana Department
of Health is a process whereby a qualified case manager serves as a single point of contact for individuals
or families who were impacted by the floods. This person helps households return to a state of
independence. The case manager can help families identify their unmet needs and then make referrals to
the appropriate agencies. This includes access to health care including mental health services, housing,
home repairs, transportation and other essential services. It is estimated that over 1,500 families will
receive assistance through the Disaster Case Management program.
In addition, the Southeast Louisiana Legal Services is providing free legal assistance to low income
homeowners facing title challenges. These services will help assisted homeowners participate in the
state's homeowner program.
However, the state also understands from past experience that, while some of these public services needs
may be addressed in the immediate aftermath of the flood event, additional unmet needs for these types
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of services will become apparent as the short-term funding for services ends and the lingering and longterm
impacts from the floods begin to take their toll on individuals and families. The state will continue
to assess the need for public services, as it conducts program intake and continues outreach to local
governments, non-profit and faith-based organizations and other community stakeholders. At this time,
due to the limited funding available to address the full breadth of long term community service needs,
the state is limiting access to CDBG-DR funded public services to the most vulnerable through the Rapid
Rehousing and Permanent Supportive Housing Support Services programs.
F. Summary of Unmet Needs & Additional Considerations
In summary, and outlined in the sections above, through this analysis, the state has noted the following
sources of recovery expenditure through the FEMA IA program and through various SBA loan programs.
IA Housing Assistance Approved (as of 11/22/16)
Disaster Total Approved
DR-4263 $ 72,992,887
DR-4277 $ 578,268,509
Total $ 651,261,396
Summary of SBA Loans Approved (as of 12/30/17)
Disaster All Loans Home Loans Business Loans EIDL
DR-4263 $ 75,383,450 $ 57,695,300 $ 14,689,050 $ 2,999,100
DR-4277 $ 749,650,650 $606,938,800 $ 111,228,750 $ 31,483,100
Grand
Total $ 825,034,100 $664,634,100 $125,917,800 $34,482,200
As of Nov. 22, 2016, there were 33,177 policy claims made through NFIP for DR-4263 and DR-4277 and
$626,583,804 approved or disbursed through the program. As of Jan. 12, 2017, a total of $446,927,484
has been paid for 26,626 NFIP claims for DR-4277, but as of the data of this publication, data from DR4263
is not available. There is a 60-day delay from when a claim is processed and when it is reflected in
NFIP data, so the data from Dec. 12, 2017, only reflects NFIP claims from 60 days prior.
It should additionally be noted this total represents an initial sample of what will ultimately be claimed
and disbursed through NFIP. As of Dec. 3, 2016, FEMA had granted Gov. John Bel Edwards request to
extend the filing deadline by which those affected by DR-4277 must submit a proof of loss claim. With the
extension, applicants will have 180 days from the date of the loss to provide the completed paperwork to
the insurer.
NFIP Payouts for Residential Single Family (Structural Damage Only) –
4277 Only (As of 1/12/17)
Disaster Parish Number of Claims Total Amount Paid Out
4277 Acadia 616 $5,505,109
Allen 2 $36,000
Ascension 3,610 $55,308,648
Avoyelles 27 $168,818
Bossier 3 $39,437
Calcasieu 24 $41,332
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Cameron 8 $17,000
Concordia 1 $0
East Baton Rouge 9,991 $185,306,197
East Carroll 1 $0
East Feliciana 17 $124,000
Evangeline 61 $584,779
Iberia 310 $2,755,212
Iberville 61 $449,611
Jefferson 27 $6,690
Jefferson Davis 73 $343,250
Lafayette 2,277 $39,430,297
Lafourche 3 $38,466
Lincoln 1 $0
Livingston 6,852 $130,761,688
Morehouse 1 $0
Orleans 13 $0
Ouachita 5 $10,000
Pointe Coupee 135 $640,747
Rapides 1 $0
St. Bernard 2 $0
St. Charles 7 $10,600
St. Helena 25 $567,198
St. James 26 $185,028
St. John The Baptist 2 $0
St. Landry 169 $1,247,005
St. Martin 240 $1,752,801
St. Mary 4 $786
St. Tammany 129 $803,403
Tangipahoa 985 $11,343,274
Terrebonne 6 $1,751
Vermilion 852 $9,026,305
Washington 19 $9,000
West Baton Rouge 23 $160,698
West Feliciana 17 $252,355
Total 26,626 $446,927,484
Summary of Unmet Needs
Type Amount
Housing $1,288,696,623
Economic $3,088,429,254
Infrastructure $93,802,360
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Resilience $600,000,000
Total $5,070,928,237
G. Anticipated Unmet Needs Gap
During the Oct. 10, 2016 Congressional Session, state government officials, including Gov. John Bel
Edwards, traveled to Washington D.C. and worked collaboratively with Louisiana's Congressional
Delegation to secure long-term disaster recovery resources in response to DR-4263 and DR-4277. Working
with limited disaster loss unmet need information, Louisiana's delegation proposed a relief package of
nearly $3.8 billion. This package focused primarily on housing needs, as the state has prioritized housing
as its most urgent and pressing recovery concern following the two flooding events. Through this Action
Plan, the state now presents revised unmet need estimates based on current best available data. Over
time, the state reserves the right to continue to update these estimates as additional assessments are
made and more complete data becomes available. The state will use information collected through
application intake and ongoing community outreach, coupled with updated data received on a weekly
and monthly basis from SBA, FEMA and NFIP to update its unmet housing, economic, public infrastructure,
public services and planning needs assessments. As the unmet needs assessment is updated, the state
will review its programs to ensure they are best designed to meet the recovery needs of the state and its
residents and businesses.
Accounting for the initial appropriation of $437,800,000 and the second appropriation of $1,219,172,000
for long-term recovery purposes, the state has calculated a remaining unmet need gap of $5,070,928,237.
Summary of Total Unmet Needs
Category Losses/Gaps
Known
Investments
Remaining Unmet
Need
Owner-Occupied Housing $2,448,293,435 $2,448,293,435
Homeowner Rehabilitation and Reconstruction (CDBG-DR) ($1,293,693,120) ($1,293,693,120)
Rental Housing $254,798,970 $254,798,970
In-fill and Repair Rental Program (CDBG-DR) ($45,000,000) ($45,000,000))
Multi-family Gap Program (CDBG-DR) ($45,000,000) ($45,000,000)
Piggyback Program (CDBG-DR) ($19,000,000) ($19,000,000)
Public Housing $8,539,159 ($4,492,053) $4,047,106
Homeless Assistance $5,250,232 $5,250,232
Rapid Rehousing (CDBG-DR) ($16,000,000) ($16,000,000)
PSH Support Services (CDBG-DR) ($5,000,000) ($5,000,000)
Agriculture Losses (DR-4277) $110,244,069 $110,244,069
Agriculture Losses (DR-4263) $80,285,185 $80,285,185
Business Structures $595,600,000 $595,600,000
Business Equipment $262,800,000 $262,800,000
Business Inventories $1,425,500,000 $1,425,500,000
Business Interruption Loss $836,400,000 $836,400,000
SBA Business/EIDL Loans ($160,400,000) ($160,400,000)
Small Business Program (CDBG-DR) ($51,200,000) ($51,200,000)
Small Business Technical Assistance Program (CDBG-DR) ($800,000) ($800,000)
Louisiana Farm Recovery Program ($10,000,000) ($10,000,000)
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PA State Share $106,096,475 $106,096,475
FEMA PA Match Program (CDBG-DR) ($105,000,000) ($105,000,000)
HMGP State Share $92,705,885 $92,705,885
Resilience Gaps $600,000,000 $600,000,000
Totals $6,826,513,410 ($1,755,585,173) $5,070,928,237
*CDBG-DR investments are inclusive of program delivery costs.
4. Method of Distribution and Connection to Unmet Needs
A. Method of Distribution Process
All programs will be implemented by the State of Louisiana at this time. Depending on a continued
assessment of unmet needs and additional funding, the state may allocate funds to parishes or other
subrecipients through future substantial Action Plan Amendments. The programs established in this
Action Plan are not entitlement programs and are subject to available funding.
B. Connection to Unmet Needs
Based on the unmet needs assessment and input from impacted communities throughout Louisiana, the
state has prioritized programs that will assist in meeting the short- and long-term recovery needs of its
residents and communities. While the impact of the 2016 Severe Storms and Flooding was much greater
than the resources available through these two HUD allocations, these programs will begin to address the
unmet needs in homeowners' primary residences and rental housing, economic recovery and
revitalization, and damages to public infrastructure.
The Continuing Appropriations Act, 2017, and the Further Continuing and Security Assistance
Appropriations Act, 2017, require that all CDBG-DR funded activities address an impact of the disaster for
which funding was appropriated. The CDBG-DR provisions require that each activity: (1) be CDBG eligible
(or receive a waiver); (2) meet a national objective as defined by 24 CFR 570.483; and (3) address a direct
or indirect impact from the disaster in parishes declared by the President to have been impacted by the
disaster. A disaster impact can be addressed through a number of eligible CDBG activities listed in Section
105(a) of the Housing and Community Development Act of 1974, as amended. The recovery activities
described herein will make full use of the three national objectives under 24 CFR 570.483 which include
benefitting low and moderate income persons, preventing or eliminating slums or blight, and meeting
urgent needs to implement a robust and comprehensive recovery for the residents of Louisiana.
As required by the Federal Register, 81 FR 83254, November 28, 2016, and 82 FR 5591, January 18, 2017,
the state will spend 80 percent of the overall grant on activities undertaken in the HUD-identified “most
impacted and distressed” area. The HUD-identified “most impacted and distressed” area for the 2016
Severe Storms and Flooding consists of Acadia, Ascension, East Baton Rouge, Lafayette, Livingston,
Ouachita, St. Tammany, Tangipahoa, Vermillion, and Washington parishes. However, the state may
determine to make the remaining funds available for eligible program activities in all disaster-impacted
parishes.
Up to five percent of the overall grant will be used for administration of the grant. Also, as required by the
Federal Register Notice, the state will spend no less than 70 percent of funds allocated on activities that
benefit low to moderate income (LMI) households, or request a waiver of that requirement.
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The 2016 Severe Storms and Flooding caused significant levels of damage to owner-occupied and rental
housing within impacted parishes. Based on the state's review of the most recent data obtained from
FEMA and SBA, the unmet need for housing repair and replacement is more than $2.7 billion. The need
for safe, decent, and affordable housing is the state's top priority, which is why the state has allocated a
proportion not equivalent to the unmet needs described above. Over 86 percent of the programmatic
funding from the total allocation of CDBG-DR funds goes to housing programs. Proposed housing activities
are intended to assist homeowners in reconstructing, rehabilitating, and elevating homes as well as
provide affordable rental housing for persons displaced by the storm.
In addition to implementing homeowner and rental programs, the state intends to implement programs
that benefit small businesses and state and local entities faced with covering a non-federal match
requirement for FEMA Public Assistance projects.
The state will dedicate the total allocation to date of $1,656,972,000 to address unmet housing, economic,
and infrastructure recovery needs. Of this, $1,423,693,120 will be dedicated to the meet the unmet
housing needs, including rehabilitation of owner-occupied households ($1,293,693,120) and the repair
and increase of the stock of affordable rental housing for impacted renters ($130,000,000). Economic
recovery will be supported by $62,000,000dedicated to assist small businesses and farmers impacted by
the flood events. Local governments and entities eligible for FEMA Public Assistance will be eligible for the
non-federal cost share within the PA Match Program, totaling $105,000,000.
Due to the limited funds received in the first two allocations, the state has prioritized vulnerable
populations throughout each of the programs proposed in this Action Plan. For the owner-occupied
housing programs, low-to-moderate income households, households with a head of household that is 62
or older, or individuals with disabilities are prioritized. In the tenant-based programs, the state will
prioritize these vulnerable populations as well as persons displaced by the disaster event in need of
affordable housing. The programs that create or repair rental stock are designed to stretch limited funding
as far as possible and to maximize the number of affordable units that will be made available to low to
moderate income households. As mentioned in the unmet needs section above, as the state conducts
housing program intake it will coordinate outreach efforts in accordance with locales with high-levels of
documented damages and social vulnerability.
The state's economic recovery and revitalization programs will focus on small businesses, which are
consistently more vulnerable to the impacts of disasters. Small businesses are critical to the revitalization
of the households, neighborhoods and communities in which they are located. Historically, a sizable
portion of small businesses are less able to secure assistance from other sources and struggle to reopen
or maintain operations following a disaster event.
With respect to public infrastructure, OCD-DRU will implement a program by which it will provide funding
to cover the non-federal share of FEMA Public Assistance projects. Funds will be provided as payment to
state or local entities for eligible activities within approved Project Worksheets. The match funding will
lessen the financial burden placed on the entities and assist them to continue normal operations and
address recovery needs.
C. Allocation of Funds
State of Louisiana CDBG-DR Total Allocation
Total Allocation $1,656,972,000
Restore Louisiana Housing Programs $1,423,693,120
Homeowner Program $1,293,693,120
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Rental Housing Programs $ 130,000,000
Restore Louisiana Economic Recovery and Revitalization Programs $62,000,000
Infrastructure Program (PA Match) $105,000,000
Administration and Planning $ 66,278,880
5. Proposed Use of Funds
A. State Implemented Programs
All programs outlined below will be implemented by the State of Louisiana. All eligible activities listed
below are as provided by statute, as may have been amended by the Federal Register Notice or hereafter
affected by waivers from HUD.
1. Housing
The state's housing programs will focus on assisting homeowners to reconstruct, rehabilitate, reimburse,
and elevate their homes, as well as providing affordable rental housing for persons displaced by the storm
through the rehabilitation and creation of rental housing stock and by providing rental assistance and
support services to the most vulnerable persons displaced by the storm.
Allocation for Housing Activities Relative Percentage
Total Allocation for Housing Activities: $1,423,693,120 100%
Homeowner Program $1,293,693,120 90.87%
Rental Housing and Homelessness Prevention
Programs $ 130,000,000 9.13%
General Eligible Housing Activities: Rehabilitation, reconstruction, buyouts, and new construction;
includes any rental housing for LMI households; public housing; emergency shelters and housing for the
homeless; any other HUD-assisted housing; moving expenses; rental assistance; interim mortgage
assistance; housing counseling services; acquisition; and buyouts. Funds may also be used for the creation
of new units or rehabilitation of units not damaged by the flood events if the activity can be clearly linked
to an impact generated by the flooding events in the Most Impacted/Distressed (MID) target area. Code
enforcement is an eligible activity that will be considered by the state for the slate of housing programs.
The following activities under the Housing and Community Development Act of 1974 (HCDA) are eligible:
105(a)1-11, 14-15; 18; 20; 23-25 as well as (42 U.S.C. 5305(a)(4)), (42 U.S.C. 5305(a)(6)); and FR 5989-N01
VI.B.28.
Ineligible Activities: Forced mortgage payoffs; SBA home/business loan payoffs; funding for second
homes; compensation payments; and - as per 42 USC 5154a and the Federal Register Notice - no Federal
disaster relief assistance shall be made available in a flood disaster area to make a payment (including any
loan assistance payment) to a person for repair, replacement, or restoration for damage to any personal,
residential, or commercial property if that person at any time has received Federal flood disaster
assistance that was conditioned on the person first having obtained flood insurance under applicable
Federal law and the person has subsequently failed to obtain and maintain flood insurance as required
under applicable Federal law on such property.
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SBA Declined Loans: Homeowners and property owners approved for SBA loans who declined their loans
will be reviewed for eligible award amounts and duplication of benefits, per the state's program policies
and procedures.
Elevation Requirements: New construction, substantially damaged, or substantial improvement of
structures in the 1 percent annual (or 100 year) floodplain must be elevated (2' above Base Flood
Elevation), per federal rules and regulations and local code enforcement requirements. The state has
allocated other resources to a study that will assess the potential impacts of riverine basin projects on the
flood levels of certain communities impacted by the 2016 Severe Storm and Flooding Events. While it is
anticipated one or more infrastructure projects will have beneficial impacts on mitigating future flooding
events in the impacted communities, these projects may not be complete prior to the implementation of
the programs described herein. Therefore, in those cases where the state determines the cost
reasonableness of rehab/reconstruction of an impacted structure, the state will follow federal elevation
requirements until further assessment and notice.
Building Standards: New construction or replacement of substantially damaged buildings must meet
green building standards and are strongly encouraged to meet a resilient home construction standard.
Flood Insurance: Applicants living in a SFHA that receive federal assistance under these programs must
obtain and maintain flood insurance for rehabilitated or reconstructed properties.
Restore Louisiana Homeowner Rehabilitation, Reconstruction and Reimbursement Program
Summary: The state will enter into grant agreements with homeowners that result in the repair,
reconstruction, elevation, acquisition and/or buyout of flood-damaged residential owner-occupied
structures. Given the time elapsed from the March and August flooding events, homeowners are in varied
states of progress in their rebuilding process depending on the extent of damage and resources available.
In response, the state will implement the Restore Louisiana Rehabilitation, Reconstruction and
Reimbursement Program to cover eligible costs for the repair or replacement of damage to real property;
replacement of disaster-impacted residential appliances; and limited environmental health hazard
mitigation costs related to the repair of disaster-impacted property.
Eligible Activity Rehabilitation, Reconstruction, Buyouts and Acquisitions (42 U.S.C.
5305(a)(4)); HCDA Sections 105 (a)(1), 105(a)(3-4), 105(a)(7-8)). Housing
Incentive, as identified in Federal Register Docket No. FR-5989-N-01.
Also eligible are elevation expenses related to rehabilitation and
reconstruction activities and reimbursement of eligible rehabilitation
and reconstruction activities.
National Objective Urgent Need or benefit to low to moderate income persons
Geographic Eligibility: Disaster-declared parishes impacted by the 2016 Severe Storms and Flooding
Allocation for Activities:
Program Area First
Appropriation
Second
Appropriation
Total % of
Total
Homeowner Rehabilitation
and Reconstruction $385,510,000 $908,183,120 $1,293,693,120 80%
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Administering Entity: State of Louisiana
Proposed Use of Funds: Homeowners will have four potential program solutions from which to choose
based on their progress in the rebuilding process and their capacity to complete the rebuilding process.
The state's programs will give homeowners the option to select their own contractor who will follow the
state's requirements for rebuilding or work with a state-managed contractor. Additionally, homeowners
that have completed partial or full repairs on their home prior to applying to the program, may be eligible
to receive reimbursement for expenses incurred within HUD approved timelines. If homeowners have
partially completed repairs or reconstruction of their homes at the time of application to the program,
they may be eligible for assistance for prospective work as well as reimbursement assistance for eligible
work completed within the HUD established reimbursement guidelines. Consistent with HUD
reimbursement guidelines, certain limited reimbursement may become available for repairs performed
after the homeowner has applied to the program. More details, including when repairs may be made and
which expenses are eligible for reimbursement, will be made available with the publishing of the
program's Policies and Procedures.
Elevations will be included for homeowners that meet requirements determined by the program,
including substantially damaged properties in the floodplain. Elevation will be evaluated on a case-bycase
basis. Elevations will not be conducted on properties outside of the floodplain, with the possible
exception where elevation is required by local ordinance.
State staff and/or contractors will provide guidance to homeowners on the guidelines and requirements
of each solution. Based on their individual conditions at the time of application, homeowners will choose
the program solution that best fits their need.
Program Solutions:
Solution 1: Program Managed: Homeowners may choose to have the state manage and complete
the construction process for the rehabilitation or reconstruction of damaged homes on their
behalf. The state will contract with a pool of contractors and assign them to repair or reconstruct
damaged properties. Homeowners will not select their own contractors and will not contract with
the construction contractor. Homeowners will be required to enter into grant agreements with
the state. Homeowners who have partially completed repairs on their home at the time of
application may select to participate in Solution 1. These homeowners may also be eligible for
assistance under Solution 3: Reimbursement for eligible costs incurred prior to application.
Solution 2: Homeowner Contracted Program: Homeowners may choose to manage their own
rehabilitation or reconstruction process with the state providing construction advisory services
for all homeowners in this solution. Homeowners will select their own homebuilding contractor(s)
and contract directly with homebuilding contractors to rebuild as well as enter a grant agreement
with the state for the CDBG-DR funding. The state will monitor all projects in the Homeowner
Contracted Program. Homeowners who have partially completed repairs on their home at the
time of application may select to participate in Solution 2. These homeowners may also be eligible
for assistance under Solution 3: Reimbursement for eligible costs incurred prior to application.
Solution 3: Reimbursement: Homeowners who have completed partial or full repairs on their
home prior to applying to the program may be eligible to receive reimbursement for expenses
incurred within HUD approved timelines. Furthermore, certain limited reimbursement may
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become available for repairs performed after the homeowner has applied to the program. More
details, including when repairs may be made and which expenses are eligible for reimbursement,
will be made available at a later date with the publishing of the program's Policies and Procedures.
Homeowners who have partially completed repairs to their homes prior to application may also
participate in Solutions 1 or 2 in order to complete the repairs or reconstruction of their homes.
The state will follow the guidance received from HUD and the CPD Notice 2015-07, "Guidance for
Charging Pre-Application Costs of Homeowners, Businesses, and Other Qualifying Entities to CDBG
Disaster Recovery Grants” when implementing Solution 3: Reimbursement. Furthermore, the
state is in the process of consulting with the State Historic Preservation Officer, Fish and Wildlife
Service and National Marine Fisheries Service, to obtain formal agreements for compliance with
section 106 of the National Historic Preservation Act (54 U.S.C. 306108) and section 7 of the
Endangered Species Act (16 U.S.C. 1536).
Solution 4: Voluntary Buyouts or Acquisitions: Based on further analysis of unmet needs, the
state may execute voluntary buyouts or acquisitions in limited situations where the state
determines it is more cost effective to buyout or acquire a property from a homeowner.
Using data from prior acquisition and buyout programs implemented by the state and other HUD
grantees, the program will establish an average cost of buyout that will be used as a threshold for
cost effectiveness to determine whether voluntary acquisition or a buyout should be considered
in lieu of a rehabilitation or reconstruction.
Generally, the state does not intend to elevate homes that are slab on grade and the state has put
mechanisms in place to ensure all structures requiring elevation go through an analysis to
determine whether a) rehab and elevation or b) demolition, reconstruction and elevation of the
structure is the more cost effective approach to helping that homeowner get home. In both cases,
the state will also evaluate the cost effectiveness of the chosen approach as compared to the cost
of buying out or acquiring the property from the homeowner.
Through past experience, the state understands it can be more costly in the long-run to implement
and maintain a buyout and acquisition program than a rehabilitation or reconstruction program;
therefore when assessing the cost reasonableness of a buyout/acquisition approach as opposed
to the a) rehab and elevation or b) demolition, reconstruction and elevation of a home, the state
will consider the costs of acquiring a property at pre-storm value, potentially providing interim
housing assistance to the family, ongoing property maintenance, title work, operational expenses
and all other expenses necessary to reaching final disposition and national objective with the
acquired property.
Following recent changes to FEMA's Severe Repetitive Loss program, which limit buyouts to
neighborhood solutions to reduce unintended negative consequences of single buyouts to a
neighborhood or jurisdiction, the state reserves the right to continue with a rehabilitation or
reconstruction if the impact of a buyout on the neighborhood or jurisdiction could be detrimental.
Eligible Applicants: Homeowners will be eligible for the program if they meet the following criteria:
>> Owner occupant at time of disaster event
>> Damaged address was the applicant's primary residence at the time of disaster event
>> Located in one of 51 disaster declared parishes
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>> Suffered major or severe damages (1+ feet of flooding or $8,000 FEMA Verified Loss) as a result
of the 2016 Severe Storms and Flooding events
>> Eligible structure as determined by program, including but not exclusive to, one or two family
home structures, mobile/manufactured, and modular homes
Due to limits in the funding available in the first two allocations, the state prioritized a first phase of the
program impacted homeowners meeting the criteria outlined below. With additional funding made
available in the second allocation, the state will expand program eligibility criteria to assist additional
homeowners described above as Eligible Applicants with remaining unmet needs. This includes
households of all income levels with primary residences located inside or outside of the floodplain that
can exhibit a remaining need for funding to repair or rebuild their homes in keeping with the guidelines
of the program. Due to the number of impacted homeowners eligible for the program, the state intends
to fund eligible homeowners in phases. As the state collects additional data and information from FEMA,
SBA, NFIP, other funding sources and real and potential homeowner applicants, the state may expand the
criteria listed in the phases below to include homeowners who had a structural flood insurance policy at
the time of the flood and have an eligible remaining unmet need.
Phase I: The equally-weighted criteria for Phase One of the program include all of the requirements
below:
>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or have
damage which meets the major/severe damage standard, as defined by the program;
>> The applicant household meets federal Low- to Moderate-Income (LMI) requirements;
>> The applicant or co-applicant is elderly (age 62 on the date of the disaster event) OR is a person
with disabilities or has a person with disabilities in the household;
>> The home is located outside the Special Flood Hazard Area (floodplain);
>> The homeowner has completed all work or has remaining prospective work to complete at the
time of application; and
>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.
Phase II: The equally-weighted criteria for Phase Two of the program include all of the requirements
below:
>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or have
damage which meets the major/severe damage standard, as defined by the program;
>> The applicant household meets federal Low- to Moderate-Income (LMI) requirements;
>> The applicant or co-applicant is elderly (age 62 on the date of the disaster event) OR is a person
with disabilities or has a person with disabilities in the household;
>> The home is located inside the Special Flood Hazard Area (floodplain);
>> The homeowner has completed all work or has remaining prospective work to complete at the
time of application; and
>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.
Phase III: The equally-weighted criteria for Phase Three of the program include all of the requirements
below:
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>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or have
damage which meets the major/severe damage standard, as defined by HUD;
>> The impacted home is located within one of the ten most impacted and distressed (MID)
parishes;
>> The home is located outside the Special Flood Hazard Area (floodplain);
>> The homeowner has remaining prospective work to complete at the time of application; and
>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.
Homeowners who qualify under Phase III may be eligible for assistance for prospective work and
reimbursement for work incurred prior to application, or within HUD approved guidelines.
Phase IV: The equally-weighted criteria for Phase Four of the program include all of the requirements
below:
>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or have
damage which meets the major/severe damage standard, as defined by HUD;
>> The impacted home is located within one of the ten most impacted and distressed (MID)
parishes;
>> The home is located inside the Special Flood Hazard Area (floodplain);
>> The homeowner has remaining prospective work to complete at the time of application; and
>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.
>> Homeowners who qualify under Phase IV may be eligible for assistance for prospective work
and reimbursement for work incurred prior to application, or within HUD approved guidelines.
Phase V: The equally-weighted criteria for Phase Five of the program include all of the requirements
below:
>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or have
damage which meets the major/severe damage standard, as defined by HUD;
>> The impacted home is located within one of the 51 Presidentially declared parishes;
>> The homeowner has remaining prospective work to complete at the time of application; and
>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.
>> Homeowners who qualify under Phase V may be eligible for assistance for prospective work and
reimbursement for work incurred prior to application, or within HUD approved guidelines.
Phase VI: The equally-weighted criteria for Phase Six of the program include all of the requirements below:
>> The impacted home experienced Major/Severe Damages by either a FEMA-designation or have
damage which meets the major/severe damage standard, as defined by HUD;
>> The impacted home is located within one of the 51 Presidentially declared parishes;
>> The homeowner has completed rehabilitation or reconstruction of their home at the time of
application; and
>> The household did not have a structural NFIP (flood insurance) policy at the time of the flood.
Criteria for Selection: The prioritization criteria outlined above are weighted equally; therefore, the
program will not give preference to any individual homeowner over another so long as all criteria have
been met. In designing the eligibility and prioritization criteria, OCD-DRU has aimed to provide assistance
as soon as possible to those determined to be most in need of such assistance. For a homeowner to
receive assistance in Phase One of the program, all eligibility and prioritization criteria (as they are defined
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above) must be met. Applications from applicants that meet all the criteria above will be processed as
they enter the program. It is anticipated the state will be able to serve all homeowners who meet the
eligibility and prioritization criteria listed herein. Criteria for selection will be further determined within
the program policies and procedures based on availability of funds and number of applications.
Maximum Award: The maximum award will be determined by the scope of work based on a consistent
economy grade of building materials as calculated by the program using national building standard
estimating software, less any duplication of benefits (e.g. NFIP, FEMA or SBA). Duplication of Benefits is
defined further in the program policies and procedures. The state will include details of the program
standards in its policies and procedures.
Due to limited funding, the state will implement the program using two dual-tiered award approaches for
a) prospective work (Solutions 1 and 2) and b) reimbursement (Solution 3). Below are the details of the
two dual-tiered award approaches:
a) Prospective Work (Solutions 1 and 2)
>> At the time of application, homeowners still have repairs or reconstruction work to complete
on their homes
>> Program completes an inspection and generates a scope of work based on economy grade
materials
>> Program completes a duplication of benefits check
>> Program deducts the duplication of benefits from the scope of work
>> Program determines an eligible prospective award amount
>> Program applies the dual-tiered award approach:
a. Homeowners with household incomes of 0-120% Area Median Income are eligible for
100% of the eligible award amount for prospective work
b. Homeowners with household incomes of 120%+ Area Median Income are eligible for 50%
of the eligible award amount for prospective work
b) Reimbursement (Solution 3)
>> At the time of application, homeowners may have completed all or partial repairs or
reconstruction of their homes
>> Program completes an inspection and generates a scope of repaired work based on economy
grade materials
>> Program completes a duplication of benefits check
>> Program deducts the duplication of benefits from the scope of work
>> Program determines an eligible reimbursement award amount
>> Program applies the dual-tiered award approach:
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a. Low to moderate income households with either an owner/co-owner who is elderly (62+)
or has a person with disabilities living in the home are eligible to receive 100% of their
eligible reimbursement award amount
b. All other households are eligible for 25% of their eligible reimbursement award amount
Based on FEMA and SBA data, the current eligibility limitations described in the phased approach, the
dual-tiered award structure and economy grade materials approach, the program currently anticipates
serving around 36,510 homeowners through the program as currently budgeted. Using best available
data, the state anticipates serving the following number (see table below) of homeowners in each of the
phases. These numbers do not reflect a participant cap for each of the phases; the actual numbers served
in each of the phases will be determined once the program is underway.
Projected Number of Homeowners Served per
Phase
TOTAL 36,510
Phase I 3,798
Phase II 4,504
Phase III 11,009
Phase IV 8,586
Phase V 2,972
Phase VI 5,642
Homeowners may provide personal funding to expand the program-approved scope of work or pay for
higher quality materials. Further details will be outlined in the program policies and procedures.
Program Managed and Homeowner Contracted Programs – The sample award calculations below are
based on if a homeowner is eligible for 100% of the eligible award amount. These award amounts are
subject to the dual-tiered award approaches described above:
Example 1
Scope of Work $120,000
Duplication of Benefits
FEMA Assistance for Structural
Repairs to Home $12,000
SBA Loan for Structural Repairs to
Home $25,000
Total duplication of benefits $37,000
Maximum Eligible Award $83,000
Example 2
Scope of Work $100,000
Duplication of Benefits
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FEMA Assistance for Structural
Repairs to Home $12,000
SBA Loan for Structural Repairs
to Home $20,000
Grant from a local non-profit to
purchase sheetrock $5,000
Total duplication of benefits $37,000
Maximum Eligible Award $68,000
Program Timeline: The State of Louisiana anticipates the launch of the Homeowner Program in the second
quarter of 2017. Homeowners will initially complete a survey and then will be invited to apply to the
respective phase of the program under which they claim to meet the respective criteria. As additional
phases open for application review and processing, homeowners who qualified under previous phases
may be able to apply to the program even as later phases are open. The state may add, expand or amend
the program phases following updated assessments of unmet homeowner needs. The state will
communicate which program phases are open for application through direct communication with
homeowners who completed the survey and through the approaches in the state's outreach plan that will
be undertaken by the state's program manager. The program will end when all funds are expended, or six
years after the execution of the grant agreement with HUD.
Restore Louisiana Rental Housing Programs
Summary: The State of Louisiana will establish a portfolio of rental programs to address the immediate
and long-term housing needs of low-to-moderate income families in the flood impacted areas. Due to the
shortage of affordable housing stock, and to meet the unmet needs of renters in the community, it is
imperative to provide solutions that address the immediate housing needs of displaced and vulnerable
renters, but the state has designed programs and plans to provide the majority of funding allocated for
rental programs on long-term recovery solutions that replace and create affordable housing stock. Each
program will address rental availability, affordability and quality standards.
As stated in the 2014 Housing Needs Assessment conducted by LSU, Louisiana residents across the state
are rent burdened. The floods of 2016 made the situation in many areas of Louisiana much worse. The
vacancy rates dropped to about 1 percent and monthly rents increased. Currently, 720 low-income
families are receiving FEMA Temporary Shelter Assistance (TSA), which is currently set to end in February
2017. New construction, substantially damaged, or substantial improvement of structures in the 1 percent
annual (or 100 year) floodplain must be elevated to meet the higher standard of either federal
requirements or local ordinance requirements.
Due to the limited amount of funding available, the state will underwrite applicants for feasibility, cost
efficiencies and ability to meet the goals of the programs. Applicants will be prioritized based on meeting
program eligibility requirements.
Geographic Eligibility: Disaster-declared parishes impacted by the 2016 Severe Storms and Flooding
Allocation for Activities:
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Program Area First
Appropriation
Second
Appropriation
Total % of
Total
Rental Repair and In-fill,
Multifamily Gap, Piggyback,
Rapid Rehousing and PSH
Support Services
$19,000,000 $111,000,000 $130,000,000 6%
Administrating Entity: State of Louisiana
Proposed Use of Funds: Programs may include: repair, rehabilitation of flood-damaged units; new
construction to increase available rental units; assistance to pay for a defined period of rental assistance
or support services; and assistance to pay for a defined period of flood insurance premiums for eligible
program applicants.
Initially, the state will address the affordable rental housing needs through the activities defined below:
>> Repairing Rental Units (Repair and Infill Program and Multi-family Gap Program): The state has
created options within the rental program that will enable some rental units to be restored
within a few months. Property owners will be able to receive funds as a loan to repair units and
in exchange the state will require affordable rents for qualified families.
>> Creating New Rental Units (Repair and Infill Program, Multi-Family Gap Program and
Piggyback): Creating new rental units is another viable approach to provide needed relief for
renters located in the damaged parishes. This program will utilize lots already owned and
controlled by local nonprofits and units of local government. In partnership with local housing
agencies such as redevelopment authorities and community housing development organizations
as well as financial institutions, the state can assist the development of new and rehabilitated
rental units within nine months to a year. The state will require affordable rents for qualified
families.
>> Housing Assistance to Displaced Renters (Rapid Rehousing): Providing tenant-based assistance
to families displaced by the floods who are also at risk of homelessness or experiencing
homelessness.
>> Public Support Services (Rapid Rehousing and PSH Support Services): Providing wrap-around
support services to families displaced by the floods who are also at risk of homelessness and/or
are in need of permanent supportive housing solutions
Duplication of Benefits: All rental programs will include a duplication of benefits review as part of the
application review and award calculation process.
Eligible Applicants: Landlords with vacant units and/or units occupied by low-to moderate income
families that were displaced by the flood, community development nonprofits, Public Housing Authorities
(PHAs), Development Authorities, and Community Housing Development Organizations (CHDOs) and/or
private entities.
Criteria for Selection: Applicants will be prioritized based on meeting program eligibility requirements.
More specific prioritization criteria will be outlined in program policies and procedures. At this time, there
are no specific prioritization criteria given more weight or value than others.
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Program Timelines: The State of Louisiana anticipates launching the Restore Louisiana Rental Housing
Programs in the second quarter of 2017. The program will end the earlier of when all funds are expended
or six years after the execution of the grant agreement with HUD.
In-fill and Rehabilitation Rental Program
Summary: This program seeks to rehabilitate or create new affordable housing units through the creation
of a fully or partially forgivable loan program.
Eligible Activity Rehabilitation, new construction, loan financing (HCDA Sections 105
(a)(4)); 105(a)(8-9); 105(a)(15)).
National Objective Benefit to low to moderate income persons
Program Budget $45,000,000
Proposed Use of Funds: Awards provided to landlords under the program for the repair or creation of
affordable housing for low income families may be issued as a fully or partially forgivable or fully repayable
loan for eligible rehabilitation, reconstruction or new construction costs, as defined in the program
policies and procedures. Reimbursement of eligible expenses may also be eligible and will be detailed in
the program policies and procedures.
Eligible Applicants: Community Housing Development Organizations; 501(c)3 and 501(c)4 Not-for-Profit
Organizations; Public Housing Authorities (PHAs); development agencies of units of local government
(public or quasi-public); for-profit entities registered under the State of Louisiana; or private landlords
Method of Distribution: The award will be issued as a loan or a grant to eligible applicants. The state will
open an application process for all eligible property owners for a defined period of time, following a series
of workshops in which program staff will provide technical assistance to potential applicants so they
understand the requirements of the program. During the workshops, program staff will provide additional
information on the application timeline, process and eligibility criteria. Landlords will be able to ask
questions and understand the full requirements of the program. Potential applicants are not required to
participate in the workshops in order to apply to the program; the program staff will conduct a series of
outreach efforts in order to encourage impacted and eligible landlords to apply to the program. Each
property will be underwritten to ensure project viability for completion and sustainability for the duration
of the affordability period. The sequence in which the program will provide assistance to applicants is
based on those who are able to first demonstrate how they meet the program criteria, complete their
applications in a timely manner, provide all requisite support documentation, secure all funding necessary
to complete and sustain the project in the short and long-term and have a reasonable timeline to begin
construction.
Criteria for Selection: In order to be eligible for the program, applicants will be reviewed based on the
following basic equally weighted criteria. Priority will be given to applicants able to meet the goals and
requirements of the program in a timely and/or cost-efficient manner. If additional criteria are included
in the program application review process, they will be described in detail in the public-facing program
policies and procedures:
>> Owners of flood-damaged properties with 1-7 units in a single structure
>> Private landlords are eligible to apply to the program for the properties they owned prior to the
flood events
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>> Non-profit or public entities may be eligible if they have flood-damaged properties and/or vacant
lots available for new construction
>> All applicants must secure a construction loan or other interim financing to complete the
necessary repairs or construction; CDBG-DR funds will be funded upon satisfactory completion,
as will be defined in the public-facing program policies and procedures;
>> Ability to provide and sustain affordable housing units for low income families for the requisite
time period and terms established by the program; and
>> Cost reasonableness
Maximum Award: The maximum award will be the lesser of the cost of construction or limits set by the
program below. Each project will be reviewed for duplication of benefits, financial feasibility and cost
reasonableness. An applicant landlord may be eligible to receive multiple awards for multiple eligible
properties. Awards per property will not exceed the following amounts for the following structure types:
Building Size Maximum
Award
Single Family Unit $150,000
Double Unit $250,000
Triple Unit $315,000
Four Unit $375,000
Five to Seven Units $500,000
Affordability Requirements:
Definition of Affordable Rents: Housing is considered “affordable” if the rent (including utilities) is no more
than 30 percent of a household's pre-tax income.
Number of Units: In order to be eligible for the program, at a minimum, the recipients must agree to meet
the occupancy rule requirements established by HUD (see below). However, as will be detailed in the
program guidelines, the state may require recipients to provide affordable housing to low-to-moderate
income housing through additional units within assisted structures:
>> All assisted single unit structures must be occupied by L/M income households,
>> An assisted two-unit structure (duplex) must have at least one unit occupied by a L/M income
household, and
>> An assisted structure containing more than two units must have at least 51 percent of the units
occupied by L/M income households.
Duration of Affordability: The provision of affordable rents to qualified tenants will be required at a
minimum for the initial lease-up, but longer affordability terms may be required. The duration of
affordability may be tied to the amount of funding provided to the landlord. This will be further defined
in the final program policies and procedures.
Multifamily Rental Gap Program
Summary: As noted in the unmet needs assessment, many properties outside the floodplain were not
required to hold insurance and thus have no means to offset the cost of repair. For those property owners
that had insurance, the cost of repair may not be fully met. Given these circumstances, each group of
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property owners may face significant gaps to repair units. In addition, insurance rates may increase given
the extensive nature of the disaster. It is anticipated that owners of large developments may have a
financial burden in operation and cash flow, which will impact their ability to recover and offer long-term
affordable housing to qualified renters
Eligible Activity Rehabilitation, loan financing (HCDA Sec. 105 (a)(4); 105(a)(9);
105(a)(14-15))
National Objective Benefit to low to moderate income persons
Program Budget $45,000,000
Proposed Use of Funds: Funding will be provided in the form of a loan to the property owners of floodimpacted
properties with 20 or more units to cover eligible unmet needs. Owners will be required to sign
a completion guaranty, at a minimum. This program will provide assistance for eligible unmet needs
related to the hard and soft costs of repair or reconstruction of eligible properties, subject to program
policies and procedures. Eligible flood insurance premiums may also be covered through program funds,
subject to program limits. Reimbursement of eligible expenses may also be eligible and will be detailed in
the program policies and procedures. New construction is not eligible under this program.
Eligible Applicants: For-profit and non-profit public and private property owners and developers of floodimpacted
properties; Public Housing Authorities. Both property owners of existing affordable housing
properties and owners of market-rate properties are eligible to apply to the program. In return for
program assistance, owners of market-rate properties must agree to convert at least 51% of their units to
affordable units for eligible low income tenants for a defined period of time that is commensurate with
the amount of assistance provided through the program.
Method of Distribution: Funding will be provided in the form of a loan or grant to the public and private
property owners, developers or Public Housing Authority. The program will be implemented on a
competitive basis. The program will be open for application for a defined period of time, as will be
described in the Notice of Funding Availability to request applications from developers. Priority may be
given to properties with existing affordability requirements; the details of the prioritization and
application review process will be detailed in program solicitations issued by the state and/or the program
policies and procedures.
Criteria for Selection: The program will address multi-unit developments in two categories:
>> Flood-damaged properties with 20 units or more; and
>> Properties in a Special Flood Hazard Area (floodplain) with the required flood insurance; or
>> Properties not located in a Special Flood Hazard Area (floodplain).
While priority may be given to properties with existing affordability requirements, the state may also
invest in market-rate properties which have experienced flood-related damages but do not have sufficient
funds to repair and restore the units, and whose property owners would commit to certain affordability
requirements in return for repair funds. Priority will be given to those applicants who demonstrate the
readiness, feasibility, sustainability and cost reasonableness of their projects.
Maximum Award: The maximum award will be set after determination of damage during program
implementation. Each project will be reviewed for financial feasibility and cost reasonableness.
No payment will exceed a total amount of $65,000 per unit.
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Affordability Requirements:
Definition of Affordable Rents: Housing is considered “affordable” if the rent (including utilities) is no more
than 30 percent of a household's pre-tax income.
Number of Units: In order to be eligible for the program, at a minimum, the recipients must agree to meet
the occupancy rule requirements established by HUD (see below). However, as will be detailed in the
program guidelines, the state may require recipients to provide affordable rental housing to low-tomoderate
income housing through additional units within assisted structures:
>> An assisted structure containing more than two units must have at least 51 percent of the units
occupied by L/M income households.
Duration of Affordability: The provision of affordable rents to qualified tenants will be required at a
minimum for the initial lease-up, but longer affordability terms may be required. This will be further
defined in the final program policies and procedures.
Program Timeline:
Piggyback Program
Summary: The state will develop a ‘piggyback' program that will seek to leverage CDBG-DR with low
income housing tax credits (LIHTCs) or other sources to address the longer-term housing recovery needs
in the impacted communities.
Eligible Activity Acquisition, clearance, rehabilitation, reconstruction, and new
construction, elevation, loan financing HCDA Sections 105 (a)(1),(4) and
(14)
National Objective Benefit to low to moderate income persons
Program Budget $19,000,000
Proposed Use of Funds: Assistance will be provided in the form of loans for gap financing for mixedincome,
additional affordability, and PSH developments.
Eligible Applicants: For-profit and non-profit public and private property owners; Public Housing
Authorities.
Method of Distribution: The Piggyback Program funds will be awarded to specific developments in
accordance with a competitive funding process. The state will issue a competitive Notice of Funding
Availability for a defined period of time, inviting eligible developers to apply to the program. The timing
of the application period will coincide with the state's availability of Low Income Housing Tax Credits. The
program will review and underwrite each project for eligibility, feasibility, leverage and cost
reasonableness. Priority will be given to the most cost-effective projects.
Criteria for Selection:
Within the approved developments, the program will provide assistance to medium and large-scale
affordable and mixed income rental housing developments, specifically:
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>> Workforce Housing Units. The program will facilitate the creation of mixed-income projects
including market-rate units and units affordable to (and restricted to occupants by) households
with incomes below both 80% and 60% of area median income (AMI).
>> Additional Affordability Units. The state will facilitate development of units affordable to (and
restricted to occupancy by) households with incomes at or below 20% of AMI, 30% of AMI, and
40% of AMI.
>> Permanent Supportive Housing (PSH). The state will also facilitate the development of
permanent supportive housing for a variety of households including extremely low income
people (20% AMI and below) with serious long term disabilities, and/or who are homeless
and/or who are most at-risk of homelessness.
o The primary strategy is a PSH Set-Aside Program, under which all properties that
receive CDBG-DR funds will be required to make at least 5% of total units available to
PSH clients, who will be supported by appropriate services. Additional incentives in the
form of bonus points in the project selection scoring system may be awarded to
projects that elect to assist greater than 10% of their units.
o An additional strategy is development of PSH properties in which at least 15%, but not
more than 50% of the units are set-aside for PSH. PSH clients will be supported by
appropriate services.
Maximum Award: The maximum award for which a project is eligible will be determined on a case-bycase
basis after a project is thoroughly underwritten. Each project will be reviewed for affordable
housing outcomes, financial feasibility and cost reasonableness. No payment will exceed a total amount
of $65,000 per unit.
Rapid Rehousing Program
Summary: The state has established a model of Rapid Rehousing for households following disasters. The
Rapid Rehousing Program (RRH) is based on an effective solution to address the needs of persons either
experiencing homelessness or at risk of becoming homeless by providing a combined solution of
assistance for affordable housing and support services that help households to be self-sufficient. This
includes preventing homelessness whenever possible by rapidly rehousing people when homelessness is
imminent and providing ‘wrap around' services that stabilize the cost of housing and supports selfsufficiency
for the household.
Eligible Activity HCDA Sec. 105 (a)(4), 105(a)(8)
National Objective Benefit to low to moderate income persons
Program Budget $16,000,000
Proposed Use of Funds and Maximum Award: Funds may be used for up to 24 months of the actual costs
for rental assistance, security and utility deposits, rental and utility arrearages, application and
background check fees charged when applying for housing. Total monthly rental assistance for eligible
program participants will be determined based on an evaluation of rent comparables and will be limited
to a maximum of 24 months of monthly rental assistance. In addition, funds will be provided to the
program subrecipients to provide wrap-around services to those families receiving rental assistance. The
wrap-around services are critical to helping families become independent from the rental assistance.
Eligible Applicants: Displaced households at 30% AMI and below
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Criteria for Selection:
This program will provide rental assistance and support services to renters displaced by the floods who
are experiencing homelessness or are at risk of becoming homeless. Populations deemed at risk of
becoming homeless include very low and extremely low income families receiving Temporary Shelter
Assistance (TSA) from FEMA and very low and extremely income families temporarily living with friends
and family.
The program is limited to those individuals and families who experience a demonstrable hardship. The
state has defined a family or an individual to be experiencing demonstrable hardship for this program if
they were displaced by the flood and lack the resources to obtain housing on their own, are experiencing
literal homelessness, are persons whose primary source of income was impacted by the flood, are
experiencing health issues that were exacerbated by the flood and/or are persons with disabling
conditions prior to the flood that are exacerbated by the flood.
Method of Distribution: The state will open the application period for 90 days, using the Disaster Case
Management (DCM) team, a team implemented and administered by the Louisiana Department of Health
and a network of non-profit organizations, in the selection process for eligible applicants. The DCM will
perform applicant intake and will complete the review and eligibility determination. The state will make
payments for eligible expenses directly to the landlords of eligible program participants.
Permanent Supportive Housing Services Program
Summary: Supportive housing has proven to be a very successful answer to preventing homelessness
because it is a cost effective, community-friendly alternative to shelters that enables individuals to remain
housed and achieve increasing levels of self-sufficiency. Supportive housing is permanent affordable
housing linked to tenancy support services (health, mental health, employment) required to help
individuals rebuild their lives after homelessness, institutional care or other disruptions. Tenancy support
services include any service necessary to help a program participant maintain their rental unit, such as
employment search support, physical and mental health support services, referral services to other
programs and support networks, life skills training, reminders to pay bills on a regular basis, financial
management and budgeting, etc. The support services provided through this program will assist
individuals in transitioning to Permanent Supportive Housing and maintaining successful, long-term
tenancies.
Eligible Activity HCDA. Sec.105(a)(8), 105(a)(11)
National Objective Benefit to low to moderate income persons
Program Budget $5,000,000
Use of Funds and Maximum award: Pre- and post-tenancy support services, up to $5,000 per year per
person receiving services
Eligible Applicants: A household is considered to be in need of permanent supportive housing if all four
of the following conditions are met:
1. A household member has a substantial, long-term disability including but not limited to serious
mental illness, addictive disorder with a co-occurring disorder, developmental disability, physical,
cognitive, or sensory disability, or a disabling chronic health condition, which substantially
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impedes that person's ability to live independently without supports; and is of such nature that
the ability to live independently could be improved by more suitable housing conditions; and
2. The household member with the condition in (1) above is receiving Medicaid-funded or other
funded supports and services operated or managed by the Department of Health and Hospitals
program offices for Behavioral Health, Developmental Disabilities, Public Health or Aging and
Adult Services, the U.S. Department of Veterans Affairs or local Continuum of Care; and
3. The supports or services in (2) above expressly include assisting the qualified member to get and
keep housing; and
4. Have household incomes at or below 50% AMI.
Criteria for Selection: Households that are homeless, at risk of becoming homeless, living in an institution,
or at risk of living in an institution will be prioritized.
Method of Distribution:
The program will use the existing state PSH program that serves as a model for the rest of the country.
The state will work with Louisiana Department of Health and their existing subrecipient service providers
to expand their program to target individuals displaced by the 2016 Severe Storms and Flooding. The
application period will be open to all eligible participants until all funds necessary for the services are
expended by program subrecipients.
2. Economic Revitalization
Restore Louisiana Economic Revitalization Programs
Summary: The state has allocated $62,000,000 to support economic revitalization in impacted areas
through a suite of programs described below. The state understands that residential communities cannot
fully recover and thrive without businesses returning to the community, as they provide essential services
and employment to local residents. It is imperative that the state invest in those businesses that support
recovering neighborhoods, provide local employment opportunities and produce the foods consumed
directly or indirectly by local residents. In order to ensure these businesses remain viable and resilient in
the face of future disasters, it is critical the state provide technical assistance to the impacted businesses.
The state has prioritized businesses that experienced physical or financial losses as a result of the 2016
Severe Storms and Flooding and remain in need of immediate financial assistance to reopen or remain
viable in the impacted communities.
The economic revitalization portfolio included herein aims to support the state's long-term housing
recovery in the following ways:
>> Provide assistance to small businesses that provide income-producing jobs to residents of the
disaster-impacted communities.
>> Provide assistance to small businesses that provide services, goods and amenities to residents of
the disaster-impacted communities.
>> Provide assistance to farmers that produce the crops necessary to directly or indirectly feed the
residents of the disaster-impacted communities and/or contribute to the economic stability of
their communities.
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>> Adding to the local governments' and state's tax base through the generation of sales taxes,
which in turn will allow these governments to continue to provide essential public services to
the disaster-impacted communities.
>> Ensure the financial assistance invested in these programs is sound and secure through the
provision of technical assistance to eligible businesses.
Geographic Eligibility: Disaster-declared parishes impacted by the 2016 Severe Storms and Flooding
Allocation for Activities:
Program Area First
Appropriation
Second
Appropriation
Total % of
Total
Small Business Loan and
Grant Program, Small
Business Technical Assistance
Program and Louisiana Farm
Recovery Grant Program
$11,400,000 $50,600,000 $62,000,000 4%
Administering Entity: State of Louisiana and subrecipients
Proposed Use of Funds: Funds will be in the form of loans and/or grants to businesses, farmers as well as
grants to entities that provide technical assistance services to businesses. Funds may be used for operating
expenses (rent/mortgage, insurance, utilities, non-owner employee wages); replacement of movable
equipment or inventory necessary for a business's recovery; and future crop needs. Funds may also be
used to provide technical assistance services to businesses.
Duplication of Benefits: All economic revitalization programs will include a duplication of benefits review
as part of the application review and award calculation process.
Ineligible Activities: Forced mortgage payoffs; SBA home/business loan payoffs; funding for second
homes; assistance for those who previously received Federal flood disaster assistance and did not
maintain flood insurance; and compensation payments.
SBA Declined Loans: Business owners approved for SBA loans who declined their loans will be reviewed
for eligible award amounts and duplication of benefits, per the state's program policies and procedures.
Small Business Loan and Grant Program
Summary: The state will administer a lending program for disaster-impacted small businesses for nonconstruction
related expenses. The state will enter into subrecipient agreements with implementing
partners including local community development organizations (non-profit organizations, community
development financial institutions, local credit unions, and other eligible organizations) who qualify under
Section 105(a)15 of the HCDA. In the event the state is unable to identify local community development
organizations that can serve the entire impacted area, the state may issue awards directly to small
businesses that meet the program criteria.
Eligible Activity HCDA Section 105(a)8, 105(a) 14-15, 105(a) 17 and 105(a)21-22
National Objective LMI Job Creation and/or Retention, LMI Area Wide Benefit, LMI Limited
Clientele, Urgent Need
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Program Budget $51,200,000
Proposed Use of Funds: Funds will be used for a package of partially forgivable loans or grants up to 20
percent with fully repayable loans up to 80 percent. Loan rates will be zero- to low-interest, amortized
and repaid over a term outlined in the program policies and procedures. Reimbursement of eligible
expenses may also be eligible and will be detailed in the program policies and procedures.
Eligible Applicants: For-profit businesses and private non-profit organizations located in parishes
impacted by the 2016 federally-declared severe storms and flooding events.
Criteria for Selection: In order to be eligible for the program, businesses must meet the following equallyweighted
criteria. If additional criteria are included in the program application review process, they will
be described in detail in the program policies and procedures:
>> Are located in one of the 51 federally declared disaster impacted parishes;
>> Were operating prior to the respective flood events (March or August);
>> Employ 1 to 50 full time equivalent employees;
>> Generate a minimum of $25,000 annual gross revenue; and
>> Were directly impacted by the floods, as a documented physical or financial loss
While the state will continue to prioritize businesses that provide essential goods or services, with the
addition of the second allocation, the state has expanded the pool of businesses to all Eligible Applicants
defined above.
Note: Essential goods or services are considered to be those goods or services necessary for the
immediate and long term housing and community recovery, which will be detailed in the program
policies and procedures. Such goods and services may include grocery stores, pharmacies, healthcare
providers, gas stations, residential construction-related companies, child care providers and locallyowned
restaurants or residential service providers.
Assistance type: The state will decide whether the program awards will be issued to eligible businesses
and non-profits in one of the following award structures:
a) 80 % loan and 20% grant; or
b) 80% fully repayable loan and 20% forgivable loan
Maximum Award: The program will provide standard awards of a maximum of $50,000, with exceptions
allowing for up to a maximum award of $150,000. The state will include its exceptions policy in the
program policies and procedures.
Loan interest rate and loan term: Zero to low interest rate loan, amortized and repaid over terms outlined
in the policies and procedures.
Method of Distribution:
The state will issue a Notice of Funding Availability to secure subrecipient lenders who will implement the
program on behalf of the state. Grants will be made to subrecipients who qualify under Section 105(a) 15
of the HCDA and who meet the requirements outlined in the NOFA, which include the lending applicants'
demonstrated capacity to implement the flood recovery program in eligible parishes.
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The state will conduct extensive outreach to the business community and will open the application period
for one month in the second quarter of calendar year 2017. The first phase of the program is limited to
those businesses considered to provide an essential good or service. Applicant businesses and non-profits
will apply to subrecipient lenders, who will underwrite the businesses for program eligibility, eligible
expenses and financial viability. If additional funds are available after the first phase of the program, the
state may open another phase of the program to include additional small businesses.
Program Timeline:
The state anticipates launching the program in the second quarter of calendar year 2017. The first phase
of the program application will be open for one month. The state may implement additional phases if all
funds are not expended in the first phase.
Small Business Technical Assistance Program
Summary: Business owners recovering from disasters are often in need of specific technical assistance to
respond to losses to their businesses, whether it be a loss of employees or customers or a need for a new
product that may present a growth opportunity for a business. Technical assistance providers support
businesses to develop new business plans and continuity plans, reestablish lost financial records and data
systems and create a disaster resilience plan to help prepare for future disasters.
Eligible Activity Section 105(a)8, 105(a) 15, 105(a) 17, and 105(a) 21-22
National Objective LMI, Urgent Need
Program Budget $800,000
The state will develop a program to provide technical assistance services to businesses to bolster the grant
and loan resources and strengthen the business community.
Proposed Use of Funds: Grants will be awarded to subrecipients who will provide technical assistance
services to small businesses and non-profit organizations. Technical assistance activities may include but
are not limited to: development of business continuity plans; financial management guidance; and longterm
recovery and sustainability plans for businesses impacted by the flooding events.
Eligible Applicants: For-profit small businesses and private non-profit organizations may be referred or
request technical assistance either through the Small Business Loan and Grant program or else may
request technical assistance directly from the subrecipients implementing the Technical Assistance
program.
Method of Distribution:
The state will engage the Small Business Development Centers (SBDC) as subrecipients to the program.
The SBDCs will provide the technical assistance services directly to businesses. SBDCs have a proven track
record working within their business community and have a unique understanding of the challenges facing
businesses in and outside their portfolio. SBDCs may provide technical assistance services to businesses
within their portfolio as well as to those businesses referred to the SBDCs by the subrecipients
implementing the Small Business Loan and Grant program.
Program Timeline:
The state anticipates launching the program in the second quarter of calendar year 2017, in conjunction
with the Small Business Loan and Grant Program.
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Small Business Bridge Loan Program
Summary: The Louisiana Flood Bridge Loan Program provides banks a guarantee against losses for shortterm
bridge loans to assist businesses with immediate capital while they seek flood insurance, SBA
assistance or other longer-term recovery assistance. The program will be designed to provide immediate,
rapid financial assistance using existing banks as the conduit for businesses to gain access to the resources,
and immediately useful in the short term of the first 12-18 months after the disaster.
Due to a change in allocation and funding priorities, the state will not administer this program at this
time.
Louisiana Farm Recovery Grant Program
Summary: To assist the agricultural sector recovery from the 2016 floods, the Louisiana Department of
Agriculture and Forestry (LDAF) designed the Louisiana Farm Recovery Grant Program (LFRGP) to assist
individual farm enterprises impacted by the Great Floods of 2016.
Traditionally, the United States Department of Agriculture (USDA), via the Farm Bill and its crop loss
programs, has addressed storm related losses. However, in 2008, substantial new changes were
incorporated into the Farm Bill. Many of Louisiana's farmers would not qualify for recovery funds from
this new USDA program; therefore, additional assistance is needed to fund the unmet needs faced by
Louisiana producers.
According to LSU Ag Center, the combined $367 million in flood-related damages resulted in a total
estimated economic impact of nearly 6 percent of typical farm value for the Louisiana agricultural
industry. Moreover, most family farms face huge hurdles. Today just 19 cents of the retail food dollar goes
to the farmer. This share represents a drop of more than 50 percent from what farmers received in 1950,
leaving razor-thin profit margins, if any, for their families, and less money to spend in their local
economies. Louisiana farmers are faced with the potential to lose money before the crop is even planted.
They will not have the necessary income to cover farm expenses, and certainly will not be able to cover
family living expenses including housing. This potential negative income not only affects the farmer, but
also employees and local communities that rely on her/his business.
In Louisiana, farming supports not only the jobs generated by the farming operation, but also a number
of agribusiness sectors ranging from farm machinery equipment to food processing plants. Sustaining the
producers directly allows the agricultural industry to yield jobs and generates wealth for Louisiana's rural
communities. Communities that lose family farms lose a base of committed employers and consumers,
causing more businesses to shut their doors, shrinking the local tax base and ultimately leading to
population loss. This pattern drains local businesses and can decimate the social fabric of rural
communities, increasing unemployment rates and placing a higher demand on access to affordable rental
housing. If farmers are faced with a lack of access to adequate recovery resources, when compounded
with an aging farming population and an exodus of rural youth to urban areas, previously vibrant farming
communities will experience a sharp decline. The jobs and the salaries that come with the farm and
agricultural industry allow people in agriculture to remain in their homes.
Furthermore, historically, producers commonly utilize their houses for collateral and in many instances
the farm business operates out of their home. If the farm ceases to exist, the producer can no longer
afford his/her home. The home will have to be sold if it was used as collateral for production loans. If the
producers lose their homes there is limited housing stock available for relocation. If producers do not have
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access to resources necessary to recover from the impacts of the 2016 floods, they may not be able to
stay in their homes. This would force outmigration and make it difficult for communities to experience
long-term housing and economic recovery. While these homes are not aggregated in densely populated
neighborhoods, rural communities thrive on the network of residents living in the area. Closure of farms
and the departure of residents unable to recover from the impacts of the floods would result in the
unraveling of the social, community and residential fabric of Louisiana's flood-impacted rural
communities.
The LFRGP will provide $10 million to eligible impacted farms in all of Louisiana's disaster declared
parishes. The program targets farms that are deemed viable – having a chance to survive and able to
contribute to the economy while maintaining and creating rural jobs. Funds will be available via a direct
grant to the farm. Farms assisted via the program are expected to plant a crop in 2017. Farms must be
able to provide a plan detailing an acceptable use of funds including showing how they would use the
grant, specifically what they intend to plant, anticipated acreage and proposed timeline for their goal.
The Louisiana Agricultural Finance Authority (LAFA, also referred to as “the Authority”) is a public agency
organized pursuant to Louisiana Revised Statues 3§264 et al. and regulations promulgated. Through LAFA,
with administrative assistance provided by LDAF, the state will implement, manage, and monitor LFRGP.
Use of the expertise of LAFA will provide greater efficiencies in program delivery and ensure that
accountability and transparency are achieved, as LAFA and the farming industry have an established
working relationship with other federal disaster recovery programs.
Eligible Activity 105(a)(17)
National Objective Urgent need or benefit to low to moderate income persons
Program Budget $10,000,000
Proposed Use of Funds: Farmers may use the proceeds from the grant program to pay off existing crop
production loans that were originated to initiate production damaged or destroyed by the 2016 floods.
Pre-existing loans that were used for production of crops damaged by the 2016 floods may only be
serviced from the proceeds of this grant program following a commitment from a lending institution to
furnish sufficient funding for preparation, planting, management and harvesting of the 2017 crop. Funds
may not be used for construction-related expenses. Reimbursement of eligible expenses may also be
eligible and will be detailed in the program policies and procedures.
Eligible Applicants: To be eligible for funding, producers must meet the following equally-weighted
criteria:
>> Must have been in operation during the 2016 growing season;
>> Must have received farm revenue in 2014, 2015 or 2016 of at least $25,000; and
>> Must have suffered at least $10,000 in losses, damages, displacement or substantial farming
operation interruption as a direct result of either or both floods.
Method of Distribution: Applicants will apply to the Authority for funding during a defined application
period. Requests for funds are expected to exceed the program's funding capacity. If the total request for
eligible funds for all farms exceeds the total allocation, the Authority may pro-rata allocate funds to ensure
that all eligible entities have access to some funds. The Authority may also use professional judgment to
ensure that farms have access to capital.
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Maximum Award: The maximum grant amount is $100,000.
Program Timeline: The State of Louisiana anticipates the launch of the program in the second quarter of
2017. The program will end when all funds are expended, or six years after the execution of the grant
agreement with HUD.
3. Infrastructure
Summary: The flooding events of 2016 exposed vulnerabilities in the state's infrastructure system. The
State of Louisiana identified over $207 million in infrastructure needs, including over $105 million in nonfederal
share match for FEMA PA Projects throughout the state. Investments in infrastructure repair and
rebuilding are necessary to secure the state's investment in housing repairs throughout impacted
communities. These investments will bolster confidence in communities continuing to rebuild, as well as
leverage the federal investment made in housing repair. Without assistance to meet the local match
requirements, the public services, infrastructure and resources typically provided by state and local
governments will be severely at-risk, as local governments will be required to either a) forgo assistance
from FEMA PA or b) divert funding needed for other community needs toward meeting the match
requirements. Communities need access to these critical public services and infrastructure improvements
in order to realize long-term recovery and restoration of housing. The state will dedicate $105,000,000 to
offset the burden of the non-federal share match requirements faced by state entities and local entities
and jurisdictions.
Program Area First
Appropriation
Second
Appropriation
Total % of
Total
Infrastructure: FEMA Public
Assistance Nonfederal Share
Match
$0 $105,000,000 $105,000,000 6%
FEMA Public Assistance Nonfederal Share Match
Many federal agencies, including FEMA, require jurisdictions to pay a percentage of the costs of disaster
cleanup and recovery efforts. In the aftermath of catastrophic events, such as the Great Floods of 2016,
the cost of this “non-federal share” of recovery can equal a significant portion of a jurisdiction's operating
budget. Requiring a jurisdiction to pay this share can result in a burden on a locality's ability to continue
normal operations in addition to meeting recovery needs. Recognizing that this requirement places a
significant burden on localities, Congress has designated non-federal share as an eligible activity under
CDBG-DR regulations, making it one of the few federal funding sources that can be used to offset a
jurisdiction's non-federal match requirements.
Eligible Activity Non-federal share 105(a)(9)
National Objective Urgent need, benefit to low to moderate income persons,
elimination of slums and blight
Activity Amount $105,000,000
FEMA provides funds to eligible applicants who must document disaster-related damages. As a cost
sharing program, FEMA requires that the state certify that local applicants that receive FEMA funds have
met the “local match” requirement. The federal/local cost-share ratio is normally 75% in federal funds
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and 25% in state or local funds. Due to the catastrophic nature of the August 2016 Floods, the local costshare
was decreased to 10%, thus, following the Great Floods of 2016, Louisiana's communities face two
different non-federal cost share requirements:
Disaster
FEMA Public
Assistance
Nonfederal
Share Match
Requirement
DR-4263 (March 2016 Floods) 25%
DR-4277 (August 2016 Floods) 10%
Proposed Use of Funds: Funds will be provided as payment to state agencies, eligible organizations,
local governments or other local entities for eligible activities within approved Project Worksheets
(PWs). The state anticipates being able to fund the match requirements for all FEMA PA eligible projects.
Duplication of Benefits: The FEMA PA Match program will include a duplication of benefits review as part
of the application review and award calculation process.
Eligible Applicants: All entities eligible for FEMA PA, under DR-4263 and DR-4277. Eligible applicants
for FEMA PA include, but are not limited to, the following entities:
>> Parish and municipal governments
>> State agencies and authorities
>> Schools (K-12) and Universities
>> First responders
>> Critical infrastructure facilities as defined by FEMA (wastewater and drinking facilities)
>> Public Housing Authorities
>> Other parish and local program applicants eligible to receive federal recovery funds, including
eligible private non-profit organizations
Maximum Award: The maximum award will be the lesser of the cost-share requirement or a pro-rata
share based on available funding.
Program Timeline: The State of Louisiana anticipates the launch of the Restore Louisiana FEMA Public
Assistance Non-federal Share Match Program in the second quarter of 2017. The program will end when
all funds are expended, or six years after the execution of the grant agreement with HUD.
4. Vulnerable Populations
OCD-DRU, in coordination with the LHA, has designed a suite of programs that account for the specific
needs of the state's most vulnerable populations, understanding that the funding allocated is not
sufficient to serve all households in need of assistance. As is identified in the program descriptions above,
the state is prioritizing the provision of funding to those most in need of assistance with its owneroccupied
and rental housing programs.
Specifically, the homeowner program will prioritize low-to-moderate income individuals and families,
elderly persons, and persons with disabilities. The design of the proposed portfolio of rental programs
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creates affordable units as quickly as possible to provide immediate housing options to individuals and
families that are currently homeless or at-risk of homelessness.
In addition to the programs proposed in this Action Plan, the state continues to work with its federal
partners to continue to support vulnerable populations who remain displaced from the March and August
floods through TSA and Disaster Case Management (DCM). Currently, FEMA has nearly 1,100 displaced
households (comprising over 3,600 individuals) who are receiving TSA. This program, while temporary, is
providing a much needed recovery function for vulnerable populations. The state, in coordination with
FEMA, seeks to ensure that all households have a permanent housing plan prior to the exit from TSA. The
programs proposed in this Action Plan will play a key role the transition.
Through DCM, the state works with five on-the-ground partners,such as Catholic Charities of the Dioceses
of Baton Rouge, who provide direct case management for over 1,700 households. This crucial case
management service for vulnerable populations ensures that they have access to critical resources to
further their recovery needs. The state understands the gravity of the needs of the most vulnerable
populations, and continues to work with state, local, and federal partners to provide recovery solutions
and a safety net to this population.
Furthermore, the state has requested $92,000,000 in Social Services Block Grant funds to meet the needs
of vulnerable populations through Health Delivery System to rebuild the health care needs of its
populations through child care centers, child abuse prevention, mental health services for children,
developmental disability services and mental health services for adults, child welfare services, child care
services, and a call center/hotline designated to connecting residents with appropriate housing resources.
B. Leveraging Funds
1. Housing
To maximize the impact of the CDBG-DR funding provided to the state, and as part of a continuous effort
to prevent duplication of benefits, there will be an ongoing commitment to identify and leverage other
federal and non-federal funding sources. Further, the state will utilize existing relationships and strive to
create new partnerships with other federal and state agencies, corporations, foundations, nonprofits and
other stakeholders as a means of utilizing all viable sources of funding.
CDBG-DR funds will be used to address critical unmet needs that remain following the infusion of funding
from other federal sources, including FEMA, NFIP and the SBA. Existing state resources and other funds
from the disaster appropriation will also be examined in an effort to ensure that all available funding is
utilized where it is most needed.
Specifically, the state is working directly with FEMA and GOSHEP to implement the Shelter at Home
Program, which provides emergency damage remediation for families so they can return home while
rebuilding. To date the program has assisted over 9,400 households. While the Shelter at Home program
allows for emergency repairs that are different from the long-term repairs funded through the CDBG-DR
programs, further assistance through CDBG-DR funding will continue to leverage this initial federal
investment from FEMA. Additionally, the state has committed existing Tenant Based Rental Assistance
(TBRA) dollars to meet the immediate needs of renters in the impacted parishes. Existing state resources
and other funds from the disaster appropriation will also be examined in an effort to ensure that all
available funding is utilized where it is most needed.
Furthermore, the state has designed all of the housing programs in this action plan to cover the gap
funding needed by leveraging insurance, private funds, and other assistance to complete the repairs from
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the 2016 Floods. Understanding the limited funding for recovery, the state will encourage all applicants
to seek out all other funding sources to meet their full recovery needs.
2. Economic Development
The state will combine funding to address economic development unmet needs from other federal
funding sources such as SBA loans, NFIP, non-disaster CDBG funding, the U.S. Department of Agriculture
(USDA), and the U.S. Department of Commerce. Non-federal resources such as local and state economic
development public funds, as well as private financing and equity investments, will provide additional
leverage to disaster recovery funds.
3. Infrastructure
The state will combine funding to address infrastructure unmet needs from other federal funding sources
such as non-disaster CDBG funding, USDA, and FEMA PA. Additional non-federal resources such as local
and state public funds will provide additional leverage to these disaster recovery funds.
4. Mitigation
The state is committed to a multi-pronged approach to addressing mitigation needs community wide. The
state will leverage FEMA HMGP funds to implement large scale mitigation projects, which provide
mitigation measures at the parcel level, yet impact a community as a whole. Leveraging mitigation dollars
will allow for the state to invest in resilient infrastructure to rebuild impacted areas to standards that will
reduce impacts from future flooding events. For example, the State may consider combining CDBG-DR
funds to leverage HMGP funds used for strategic buyouts in a floodplain. Further details on mitigation
projects will be outlined in future action plans.
5. Other Sources of Funds
As part of the state's ongoing recovery efforts, OCD-DRU leverages CDBG-DR funds with the following
sources of funds which may include but is not limited to:
>> Low-Income Housing Tax Credit Programs;
>> HOME Program;
>> Medicaid Funded Provision of Medical Services;
>> FEMA PA;
>> New Market Tax Credit Programs;
>> Historic Tax Credit Programs;
>> Live Performance Tax Credits Programs;
>> HUD 242 Loan Program;
>> Private Resources (Developers/Non-Profit Organizations/Homeowners/Landlords);
>> Other federal programs and resources; and
>> State Capital Outlay Program.
C. Contractor Standards and Appeals Process
Recovery programs implemented by the State of Louisiana will incorporate uniform best practices of
construction standards for all construction contractors performing work in all relevant jurisdictions.
Construction contractors will be required to carry required licenses, insurance coverage(s) for all work
performed, and state-contracted contractors will be required to provide a warranty period for all work
performed. Contractor standards will be enumerated for each program (e.g. homeowners and rental
property owners) in respective policies and procedures documents, and will pertain to the scale and type
of work being performed. The state will implement an appeals process for homeowners, rental property
owners and small business owners related to program eligibility and program application process. In
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addition, the state will implement an appeals process for the Restore Louisiana state managed
homeowner program to allow for appeals of rehabilitation contractor work that is not in keeping with
established contractor standards and workmanship detailed in relevant policies and procedures manuals
governing the respective program. In the state managed homeowner program, the homeowners will
make an appeal to the state or its designated vendor to contest the work completed by the statecontracted
homebuilding contractor. Details of the point of contact and procedure for submitting the
appeal will be detailed in the program policies and procedures. In the homeowner managed program, the
homeowner will resolve conflicts with the homebuilding contractor directly, as the state is not a party to
the contract between the homeowner and the homebuilding contractor.
The State of Louisiana intends to promote high quality, durable and energy efficient construction methods
in affected parishes. All newly constructed buildings must meet all locally adopted building codes,
standards and ordinances. In the absence of locally adopted and enforced building codes that are more
restrictive than the state building code the requirements of the State Building Code will apply. Future
property damage will be minimized by incorporating resilience standards through requiring that any
rebuilding be done according to the best available science for that area with respect to base flood
elevations.
D. Planning and Coordination
The State of Louisiana has historically experienced flooding, coastal land loss, subsidence and wetland
degradation with a significant portion of the southern half of the state below sea level, and the constant
threat of tropical storms and hurricanes. Since the flooding and damage associated with hurricanes
Katrina and Rita in 2005, followed by hurricanes Gustav and Ike in 2008 and Hurricane Isaac in 2012, the
state has been proactive in undertaking measures that address resiliency and sustainability, as well as
educating the public so that future risk for communities and individuals is minimized. Louisiana articulated
its vision for a recovery that is “Safer, Stronger and Smarter” translated into the following actions:
>> Oversight for ensuring impacted parishes developed Long Term Recovery Plans as required under
FEMA's ESF-14 in 2006;
>> State adoption of the National Building Code Standards in 2006;
>> Proactively ensuring parish adoption of the Advisory Base Flood Elevations (ABFEs) with
concurrent adjustments in permits issued for new construction and height or elevation
requirements issued after the respective adoptions;
>> Funding of “Louisiana Speaks” – a major regional initiative for all of south Louisiana reflecting
visions and strategies for resiliency and sustainable growth practices (May 2007). More than
27,000 citizens, a historical first in the United States, participated in developing the plan. The 94-
page document in hardcopy and disc and two subsequent publications: “Louisiana Speaks:
Planning Toolkit” and “Louisiana Speaks: Pattern Book” were widely distributed to planners,
government entities, local nonprofits and associations and citizens; and
>> The Coastal Protection Restoration Authority (CPRA) funded by the Louisiana Legislature to
develop a 2017 Coastal Master Plan (CMP) with specific projects within each parish designed for
protection of the coast and communities. CPRA collaborates extensively with a wide range of
other federal, state and local agencies, has developed an interdisciplinary planning process that
engages diverse groups of coastal stakeholders, focus groups, and national and international
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experts in order to capture the wide range of perspectives and expertise necessary in developing
a holistic coastal planning effort for the 2017 CMP. Under the CPRA effort, numerous supporting
teams have been formed, which include:
o Framework Development Team (FDT) which serves as the primary cross-disciplinary
collaborative group, consists of representatives from federal, state and local
governments; NGOs; business and industry; academia; and coastal communities.
o Science and Engineering Board (SEB) which includes scientists and engineers with national
or international experience who cover the range of disciplines, including socio-economics,
coastal modeling, water and natural resources, urban planning, wetlands, fisheries,
coastal geoscience, economic policy, and risk reduction
o Resiliency Technical Advisory Committee (TAC) is a small cross-disciplinary advisory group
that offers working-level guidance and recommendations on the programmatic and policy
measures needed to implement a comprehensive flood risk and resilience program. The
TAC comprises experts in the areas of climate adaptation planning, community planning,
socio-economics, social vulnerability, hazard mitigation, disaster planning, and
environmental policy.
Because OCD-DRU has administered CDBG-DR disaster recovery funds since 2006, mechanisms are in
place to serve as guidelines for not only CDBG compliance, but also comprehensive planning and
prioritization of projects for the short-term and long-term recovery of communities. These mechanisms
include:
>> The state's template for the development of a disaster recovery proposal to use CDBG-DR funds
at the parish level is being adapted to incorporate assurances that projects will reflect “unmet
needs” as established in the state's Action Plan, as well as take into consideration and reflect:
o The Flood Recovery Strategy emanating from the NDRF;
o Local ABFEs and Flood Insurance Rate Maps (FIRMs);
o The parish Hazard Mitigation Plan required by GOSHEP;
o The parish's Long Term Recovery Plan (ESF-14);
o An assessment of local land use plans, zoning and floodplain management ordinances
permit requirements;
o The Master Plan of the CPRA (where applicable); and
o Regional coordination with the respective regional planning commission.
This action will enable the leveraging of CDBG-DR funds with other funding sources and already
identified priorities for sustainability and resiliency;
>> The state has guidelines on elevation and costs for specific types of housing and encourages
coordination of CDBG-DR funding with FEMA's HMGP; and
>> The Pilot Comprehensive Resiliency Program, implemented in 2010 under funding from
hurricanes Gustav and Ike, is a proactive program to develop and facilitate local planning that
incorporates sustainability and resiliency into land use plans, zoning and floodplain management.
The program funds were made available to local governments and non-profit entities in parishes
impacted by hurricanes Gustav and Ike through a competitive application process. Twenty-nine
communities were awarded grants through the competitive program. These projects include
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water management, floodplain ordinances, comprehensive plans, zoning codes and a plan for
wetland carbon. In addition, 17 building code inspectors are funded for a two-year period in 10
communities to assist with enforcement and adaptation of permit policies and fees to allow for
those communities to ultimately sustain the effort to manage growth, compliance and blight.
The education component of the Resiliency Program, through a joint venture with the LSU Coastal
Sustainable Studio, has established a permanent online library, reflecting the plans developed through
the Resiliency Program, criteria for determining sustainability and resiliency at the local level and
educational tools. The OCD-DRU and LSU initiative includes a series of statewide webinars and workshops
that provide national perspectives through recognized experts and local tools and strategies for
implementation. Topics to date have included: “Gaining Economic Advantage through Environmental and
Hazard Mitigation”, “Social Resilience: Bridging Planning and Communication through Technology” and
“Retrofitting for Resiliency”. The Forum, “NFIP: Preparing for Changes to Flood Insurance” that was held
June 17, 2013 was designed to help parishes and municipalities develop community-scale strategies that
reduce flood risk and increase their scores on the Community Rating System. All webinars and workshops
are available on the Louisiana Resiliency Assistance Program website at http://resiliency.lsu.edu/.
Outreach for these sessions are statewide to elected officials, disaster recovery subrecipients, floodplain
managers, planners, etc. Distribution is both by LSU, OCD-DRU and through partners such as the Louisiana
Municipal Association, the Louisiana Chapter of the American Planning Association, the Floodplain
Management Association and others. Therefore, in preparation of this Action Plan, the state has ensured
that this document does not conflict with any existing regional recovery plans. The state will continue to
coordinate with regional and local governments to ensure that all recovery efforts are aligned.
6. Citizen Participation
A. Citizen Participation Plan
The State of Louisiana developed a specific Citizen Participation Plan for disaster recovery from the 2016
Severe Storms and Flooding in compliance with CDBG regulations and all applicable waivers. The plan
includes citizen participation requirements both for the state and also the parishes or other entities that
will implement activities under this grant. The State's full Citizen Participation Plan is Appendix B of this
document.
Citizens and other stakeholders will be given an opportunity for reasonable and timely access to
information and a period for submitting comments relating to this Disaster Recovery Action Plan and any
ensuing substantial amendments. Publication of the Action Plan, public comment, and substantial
amendment criteria is located on the OCD-DRU website.
The state is committed to providing access to the Action Plan and programs detailed within to all its
citizens. These efforts include special consideration for those with limited English proficiency (LEP) and
persons with disabilities. The Action Plan and substantial amendments will be translated into Spanish and
Vietnamese to reach the LEP population in the impacted areas. Citizens with disabilities or those who
need technical assistance can contact the OCD-DRU office for assistance, either via:
>> Telephone, voice 225-219-9600 or LA Relay Service 711;
>> Email at ocd@la.gov; or
>> Mail to the Office of Community Development, Disaster Recovery Unit,
Post Office Box 94095, Baton Rouge, LA, 70804-9095.
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The OCD-DRU website (http://www.doa.la.gov/Pages/ocd-dru/Index.aspx) will contain direct links to the
Action Plan, amendments, reports and recovery programs and will be updated to provide additional
information.
1. Citizen Input
The state has been in ongoing communications with its residents, local government leaders, state
legislators and other stakeholders in communities impacted from both the March and August flooding
events. This continuous outreach has helped identify the needs and priorities of the impacted
communities and informs the programs set forth in this Action Plan.
OCD-DRU personnel have provided ongoing support within the parishes since the flooding events. State
officials have held frequent calls and meetings with these and other impacted communities to discuss,
among other things, the storms' effects on the local housing stock, infrastructure and business
communities. These meetings have included seven public meetings held across the state as part of its
Citizen Participation outreach associated with the first allocation of funds, as well as six public meetings
of the Recover Louisiana Task Force.
2. Louisiana Disaster Housing Task Force
FEMA's NDRF is a guide that enables effective recovery support to disaster-impacted states, tribes,
territorial and local jurisdictions. It provides a flexible structure that enables disaster recovery managers
to operate in a unified and collaborative manner. It also focuses on how best to restore, redevelop and
revitalize the health, social, economic, natural and environmental fabric of the community and build a
more resilient Nation. As part of Louisiana's framework, the Disaster Housing Task force was created and
implemented following Hurricane Isaac. Immediately following the March floods, the Louisiana Disaster
Housing Task Force (Task Force) was activated and remained in effect throughout the August flooding
event. The Task Force includes: state personnel from OCD-DRU, GOHSEP, the LHC and the state
Department of Children and Family Services (DCFS); representatives from HUD and FEMA; and members
from the local Voluntary Organizations Active in Disaster (VOAD).
The Task Force has played an essential role in maintaining contact with the leaders of the impacted
parishes, assessing needs on the local level and providing data as needed. The state's outreach efforts will
continue throughout the duration of the program planning and recovery process, in accordance with the
Citizen Participation Plan.
3. Restore Louisiana Task Force
In response to the flooding events in March and August, Governor John Bel Edwards enacted the Restore
Louisiana Task Force (RLTF), charged with overseeing the state's recovery efforts from flooding events in
2016. The RLTF comprises key stakeholders from the public and private sectors who represent the entire
state, including impacted parishes. Their roles as elected officials or advisory roles in the community
position them to provide strategic direction to create policy and advise the governor and OCD-DRU staff
in the aftermath of the 2016 Severe Storms and Flooding.
Furthermore, the RTLF establishes and recommends to state and local agencies both short and long-term
priorities in developing plans for recovery and redevelopment. These priorities and plans focus on the
following areas: housing rehabilitation and redevelopment; economic and workforce development;
education, infrastructure and transportation; healthcare; fiscal stability; family services; and agriculture.
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Additionally, the RLTF coordinates with GOSHEP, OCD-DRU, and the affected parishes and municipalities
to assist in collecting and analyzing data about the ongoing residential, business and public infrastructure
needs for recovery, identifying additional sources of federal funding, and sets priorities and offers
direction to OCD-DRU and GOHSEP related to the use of funds made available through the Robert T.
Stafford Disaster Relief and Emergency Assistance Act and any additional available federal funds.
The state's template for the development of a disaster recovery proposal to utilize CDBG-DR funds has
been adapted to incorporate the NDRF process. As a function of the Restore Louisiana Task Force, Task
Force members engage in smaller working group sessions to deliberate and recommend program
strategies related to particular recovery areas. These working groups have been structured to mirror the
Recovery Support Functions (RSF) outlined in the NDRF: Community Planning and Capacity Building;
Economic Recovery; Health and Social Services; Housing; Infrastructure Systems; and Natural and Cultural
Resources. Each working group has been assigned an OCD-DRU staff member responsible for ensuring
that local, state and federal members of the RSFs are invited and encouraged to participate in each of the
RLTF working group sessions. By combining these functions, the state has been able to draw upon and
incorporate the expertise, strategies and perspectives from local, state and federal stakeholders in the
initial and ongoing programs design process.
The RLTF also establishes a federal and state legislative agenda for the recovery and redevelopment effort
and for coordinating between levels and branches of government to implement that agenda. The RLTF
comprises 21 voting members representing the impacted parishes and communities of Louisiana.
4. Consultation with Units of Local Government, Tribes and Stakeholders
With 56 parishes impacted by the 2016 Severe Storms and Flooding, the state has continued ongoing
dialogue and consultation with all Units of Local Governments (UGLGs), stakeholders and tribes during
and after the direct impacts of the disasters. OCD-DRU's outreach team provides daily support to many of
the impacted parishes and has conducted technical assistance and assessment meetings with impacted
parishes. Additionally, OCD-DRU staff has consulted with representatives from local chambers of
commerce, financial institutions, non-profit organizations and community development financial
institutions to seek input on the experiences of residents and businesses following the storms. Input from
these stakeholders hasinformed the initial program design and ongoing consultation will incorporate best
practices and local knowledge into the development of program policies and procedures.
For specific consultation on Action Plan development, the state worked with both the Louisiana Municipal
Association (LMA) and the Louisiana Police Jury Association to conduct webinars to provide a platform for
UGLGs, non-entitlement, entitlement communities to provide input and consultation. Additionally,
through the RSF 1 – Community and Capacity Building (RSF 1) of the Task Force, OCD-DRU staff in
coordination with FEMA and GOHSEP have conducted numerous meetings with UGLGs to advise and
assess ongoing recovery needs.
In conjunction with the NDRF, the state hosted the Louisiana Symposium on Recovery and Resilience on
December 8, 2016, which provided impacted parishes and municipalities with an opportunity to learn
about and share best practices. The one-day event included 184 participants representing 18 floodimpacted
parishes. The Symposium provided the following to attendees:
>> The opportunity to hear from and dialogue with peers and subject matter experts with experience
in addressing recovery issues and resilience in Louisiana and other parts of the nation.
>> Information about regional and state watershed management within Louisiana with an
opportunity for a targeted discussion on implementation going forward.
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>> Specifics on how the State of Louisiana's approach to responding to the needs created by the
floods.
The symposium included seven breakout sessions, including panels and feedback on risk reduction,
resilient implementation, and long term community planning and recovery. The event will be followed
up by other statewide training opportunities and targeted workshops in individual communities as
needed.
The RSF 1 Planning and Capacity Committee is developing a Community Long-Term Planning Process
specifically for Louisiana, building off of the state's Stronger Communities Together process, which has
been successful in 32 communities across the state. All six RSF's are participating in the development of
the template and will participate in the implementation to be provided to the ten most impacted
communities. GOHSEP, FEMA, and OCD-DRU will collaborate to provide oversight of the project. The
process is being modified to include: (1) guidance on how to set up a local planning advisory group
consisting of a diverse set of key stakeholders who will champion and follow-up on implementation; (2)
guidance on the public process of getting residents educated and involved in all aspects of the
development of the plan so that they are knowledgeable and supportive of decisions going forward; (3)
redesigning the elements to be addressed to reflect the six RSF's as the core – planning/capacity,
infrastructure, housing, economic development, health and social resources, natural and cultural
resources, and a resilience and hazard mitigation component; and (4) guidance on resilience and hazard
mitigation criteria for any projects identified and prioritized so that they are designed to reduce risk. The
criteria mirror what has been developed for the LA SAFE initiative to ensure coordinated efforts and
common messaging within local communities and across the state as a whole.
Timeline for a statewide training kickoff is April 2017 with a goal for all communities impacted by 4277
and 4263 to have a resiliency/recovery strategy within six months. Targeted follow-up and support will
be provided to the ten most impacted communities throughout the process to ensure this effort is
expedited and done as models for other communities within the state and as a template for the NDRF
nationally. Support includes on the ground staff support, review of existing hazard
mitigation/comprehensive land use plans, education on mitigation/resiliency strategies and best
practices, tracking community input, etc.
Combined outreach efforts between GOSHEP, FEMA and OCD-DRU have already been conducted to
conduct preliminary capacity assessments and get buy-in from local leadership and stakeholders for the
Community Long Term Planning Process.
Through the Governor's Office of Indian Affairs, the state conducted outreach to the ten state recognized
tribes after both the March and August flooding events. Two of the ten tribes are located within the
impacted parishes, and the state is committed to working with these tribes to ensure that the recovery
needs are being addressed.
Additionally, the Governor's Office of Indian Affairs has completed outreach to the four federally
recognized tribes and continues to assess impacts and needs of the tribes to ensure recovery needs are
being addressed at the state and federal level.
Because of the widespread impact of the flooding events, the state is committed to ongoing consultation
through regional public meetings, the RLTF, meetings with UGLGs and tribes in impacted parishes and
with the public to ensure the continuation of robust consultation efforts with these key groups throughout
the recovery process.
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B. Citizen Complaints
The state and its subrecipients have established procedures for responding to citizens' complaints
regarding activities carried out utilizing these CDBG-DR funds. The Citizen Participation Plan provides full
details. Citizens will be provided with an appropriate address, telephone number and times during which
they may submit such complaints. The state and subrecipients will provide a written response to each
complaint within 15 days of receiving a complaint, as practicable.
C. Receipt of Comments
This Action Plan was posted for public comment on February 1, 2017. The plan was posted online in
English, Spanish, and Vietnamese. Public notices were published in eight newspapers, including The
Advocate, the state's journal of record, and a press release was also distributed.
D. Amendments to the Disaster Recovery Action Plan
1. Substantial Amendments
Per 81 FR 83254,substantial amendments are defined by a change in program benefit or eligibility criteria;
the addition or deletion of an activity; or the allocation or reallocation of a monetary threshold specified
by the grantee. For purposes of this allocation of funding, the state will define the threshold for a
substantial amendment as the greater of a re-allocation of more than $5 million dollars or a reallocation
which constitutes a change of 15 percent or greater of a program budget.
Only those amendments that meet the definition of a substantial amendment are subject to the citizen
participation process.
2. Submittal of Amendments
A substantial amendment to the Action Plan will follow the same procedures for publication as the original
Action Plan in accordance with the Citizen Participation Plan. All amendments, both substantial and nonsubstantial,
will be posted on the OCD-DRU website in sequential order after HUD has given final approval.
Action Plan Amendments will also be incorporated into the Original Action Plan.