Gustav-Ike Parish Outreach Representatives and other OCD-DRU staff members will,
from time to time, send updates, clarifications, further guidance, etc. to parish and
municipal officials. These communications are gathered here for future reference.
October 13, 2014
Environmental Review Requirements
The following is an environmental reminder for Disaster Recovery CDBG grantees and sub recipients:
The U.S. Department of Housing and Urban Development (HUD) requires that every HUD-assisted project undergo an environmental review to determine whether it meets federal, state, and local environmental standards. There can be no actions or commitment of any HUD or any non-HUD funds, to include the use of program income, which would cause actions that are choice-limiting among reasonable alternatives or would produce an adverse environmental impact, before HUD has approved the environmental certification of compliance, and the request for release of funds.
Examples of “choice-limiting” actions include commitment of funds through the execution of demolition contracts, the execution of construction/rehabilitation/reconstruction contracts, or buy/sell agreements for acquisition of property, prior to the completion of the environmental review process.
What does this mean?
It means that no actions or commitment of funds can occur before HUD approval of the environmental process. This is critical because there is no “do-over” with the environmental process. When federal and/or state auditors review your project(s), if the environmental review process has been done improperly, OCD/DRU and/or the grantee will have a Compliance Finding, and HUD has the right to seek repayment of any and all funds that were handled improperly.
There are different levels of environmental clearance. The first is “exempt” activities; however, there is an environmental process that must be followed before money can be committed to that activity. For example, if a new contract is to be signed with a consulting firm, the contract should not be signed until the environmental has been cleared. Even if the Action Plan was approved today, and this project could be classified as exempt, the environmental process will take approximately one week to complete.
Alternatively, there are certain activities that can be “Categorically Excluded” and do not normally require a full environmental review. These happen when there is rehabilitation or repair of homes, apartments or businesses. As long as these properties have flood insurance, are not historic, and are being rehabilitated using the same footprint, the environmental clearance will take a minimum of four-six weeks after the program description is finalized, and the Environmental Officer is made aware of the need for clearance.
If the words reconstruction (demolition and rebuilding) or new construction appear in a project description, a full environmental clearance is necessary, and the property will not be receiving federal funds for at least three to four months after the date the environmental process begins.
Should you have any questions regarding the information provided above, please contact Ann Herring, Environmental Compliance Officer for OCD/DRU, Ann.Herring@la.gov, or at 225-219-9620.
Duplication of Benefits Policy
OCD-DRU has recently adopted a Duplication of Benefits (DOB) policy for our agency, which is here for your review.
Additionally, based on guidance from HUD, each of our grantees and direct sub-recipients must also adopt their own DOB policy and procedure. To help you formulate your policy, we are providing this Sample DOB Policy for your use. Each grantee and direct sub-recipient must adopt a DOB Policy and Procedure to be included with their Disaster Recovery CDBG files. Grantees that have provided Disaster CDBG funds to a sub-recipient should pass the Sample Policy to the sub-recipient for adoption for their project or program.
If you have questions or would like technical assistance in creating your DOB policy and what it is and why you need it, please contact your outreach representative.
September 24, 2014
Program Income Guidelines
For those CDBG disaster recovery grantees who have generated program income as a result of any disaster recovery CDBG-funded program, OCD-DRU has established guidelines to let you know appropriate uses for those funds, how to request the use of the program income and how to submit a draw request.
Should you have questions about program income in general or these guidelines, please ask your Outreach Representative.
September 17, 2014
Update: HUD has issued its Notice of Funding Availability for the Disaster Recovery Competition, along with two webinars. The information is now available on Grants.gov and the HUD Exchange page. Visit our Disaster Resilience Competition page for the NOFA and other links.
HUD's National Disaster Resilience Competition
OCD-DRU is notifying all 55 parishes impacted by disasters in 2011-2013 of an opportunity that will be coordinated by OCD-DRU at the state level. Your participation and input is solicited as follows:
As you may already know, the White House announced the availability of $1 billion in Community Development Block Grant disaster recovery (CDBG-DR) funds to be awarded through the U.S. Department of Housing and Urban Development (HUD) on a competitive basis in areas affected by presidentially-declared disasters in 2011, 2012 and 2013. This opportunity, known as the National Disaster Resilience Competition, is intended to promote community and regional resilience efforts, as well as risk assessment and planning initiatives, to better prepare communities for future storms and other extreme events.
Throughout our state’s history and particularly in the past decade, our state has come to know all too well the devastating effects of such extreme circumstances. In that same vein, communities across Louisiana have also become a source of strength and resilience, as homes that were destroyed have been rebuilt, economies that were ravaged have rebounded and infrastructure systems that were broken have been restored.
Through these experiences, the Office of Community Development-Disaster Recovery Unit (OCD-DRU) has worked hand-in-hand with local officials across the state to spearhead our collective recovery efforts. While we understand work remains to be done, we also know our accomplishments represent the inherent resilience of our citizens. Through this National Disaster Resilience Competition, we have a unique opportunity to present projects that will help strengthen our state in a way that helps all our constituents.
In the fact sheet about the National Disaster Resilience Competition, HUD notes “helping communities build toward a more resilient future requires innovation, broad commitment, and a multi-faceted approach.” I could not agree more, and I think our work together in past recovery efforts has demonstrated those qualities.
Additionally, OCD-DRU will represent the State of Louisiana at the upcoming “State Resilience and Economic Growth Summit” in October in Washington, D.C. You may want to view the agenda, which in turn, may elicit ideas and projects that you may want to recommend that OCD-DRU consider when developing the competitive application for these funds. The link is as follows: http://www.govinstitute.org/summit-registration/agenda/
Our past partnerships in recovery lead me to believe we can be more successful as a state in winning this competition if we work together again. The State of Louisiana is an eligible applicant, and through this correspondence we are soliciting input and participation from the 55 parishes that have been impacted by these disasters.
Please respond by providing the following:
- Please send in your insights, ideas and recommendations for developing a competitive grant proposal, based on your direct experiences in disaster recovery and taking steps to make your communities more resilient.
- Please indicate if your local jurisdiction (parish, municipality, township or village) is interested in being part of the consortium, either through (1) sending in a letter of support; (2) being a site or sub-recipient for implementing a resiliency project(s), if applicable, and if the state is awarded funding; and/or (3) serving on an oversight committee. At this time, OCD-DRU encourages grantees to express an interest in doing all three.
At your earliest convenience, contact Mathew Sanders, OCD-DRU’s policy advisor, via e-mail at Mathew.Sanders@la.gov with your response to the above. Mat will be responsible for compiling your ideas and maintaining a list of those jurisdictions that wish to participate.
In the very near future, it is the intent of this office to schedule a conference call with all interested parties to provide updates; discuss OCD-DRU’s approach for submitting a proposal on behalf of the State of Louisiana; and again solicit your input as we move forward.
Patrick W. Forbes,
OCD-DRU Executive Director
August 12, 2014
Certification Training in Economic Development
OCD-DRU is interested in hosting an Economic Development training and certification series for its staff, along with the staff of a limited number of grantees and sub-recipients, to build capacity in successfully analyzing and structuring economic development opportunities in our disaster-affected communities.
Training will include the basics of economic development financing, business credit analysis, loan packaging procedures, negotiating and problem solving skills, and deal structuring techniques.
It is anticipated that the series will involve approximately four (4) week-long courses spread out over several months, which will take place either in Baton Rouge or New Orleans. Since this is part of OCD-DRU’s technical assistance to grantees impacted by hurricanes Katrina/Rita, Gustav/Ike and Isaac, there will be minimal costs to the participants, other than personal travel and meal expenses. OCD-DRU will cover the cost of the instructor and all related materials.
Participants must agree to dedicate the entire work week to the course work. Daily attendance would be mandatory, in addition to after-hours homework and group case work. An exam will be given at the end of each course, and a certification will be awarded after successful completion of the series.
In an effort to gauge interest in attending the Economic Development training and certification series, we are requesting that grantees and sub-recipients submit the following information to Adrienne Celestine at email@example.com for each employee who is interested in attending:
- Job Title; and a
- Brief Description of relevance of training to job duties.
For other questions or additional information about the proposed training, please contact Adrienne Celestine at the above e-mail address.
July 22, 2014
Important Notice: Changes and Updates in the Submission of Construction Plans, Specifications, Cost Estimate and Change Orders
OCD-DRU is in the process of entering into a new contractual relationship for support and technical assistance services to be provided to disaster recovery CDBG grantees as projects are implemented. This correspondence details specific updates grantees need to make when submitting construction plans, specifications, cost estimates and change orders. New contact information is also provided. Please adjust your records accordingly and forward this information as appropriate to other staff to avoid any delays in getting these documents approved.
Documents previously submitted by grantees have been transferred to the new contractor as identified below. Please feel free to call or e-mail Ms. Gallagher to confirm your documents have been received and are under review.
One (1) hard copy and one (1) electronic copy of your construction plans, specifications and final cost estimate are to be submitted to the following for review and approval prior to advertising for bids. You must have OCD-DRU approval in writing prior to advertising for bids.
1717 Jackson Street
Alexandria, LA 71301
Please ensure that the most up-to-date documents are included in the specifications submitted for review and approval. Sample documents have been provided in Exhibit 6-2 of the Grantee Administrative Manual for your review. Some recent specifications submitted have been missing the current CDBG Compliance Provisions and Federal Labor Standards, wage decision and Section 3 forms.
Submission of Change Orders
Please be reminded that, per Section 2 of the Disaster Recovery Grantee Administrative Manual, if any of the following circumstances will be affected by a change order, it must be reviewed and approved by OCD-DRU prior to execution by the Grantee.
- The project’s eligibility;
- The scope of the project is outside the approved project application; or,
- The project’s environmental clearance.
For clarification, “changes to scope” are defined by OCD-DRU as any construction items added that were not discussed in the project description or cost estimate contained in the approved application.
If you are unsure about whether review and approval are required, OCD-DRU suggests that the change order be submitted and allow our staff to make the determination for you. This careful approach will ensure that all costs are eligible for reimbursement.
Drainage Projects Only (Gustav/Ike/Isaac Only)
If your project is for drainage improvements, you will also need to submit one (1) hard copy of your plans, specifications, final cost estimate and impact study to the State of Louisiana, Department of
Transportation and Development (DOTD) for review. The list of District Administrators to determine which office should perform the review, based on the location of the project, can be found at:
OCD-DRU must receive the review response from DOTD prior to authorizing advertising for bids.
If you have any questions, please feel free to contact your Outreach Representative.