[FoCHAT] Friends-of-CHAT Message: Information that may be helpful in understanding elevation allowances from Road Home

[Melanie Ehrlich]

Dear Concerned Citizen, 
   
  For information about the elevation allowances programs  from the Road Home, go to:
   
                road2la.org   Click on first new update. 
   
  Also, you should be receiving a letter in the mail from Road Home very soon if Road Home considered you eligible for an elevation allowance.
   
  Many of you have expressed confusion about the HMGP elevation award and the March 16 date. The following might help you.
   
   
  From that update at the road2la.org it states:
   
  ·                                 “What if I have completed elevation, am I still eligible?
You are eligible for the Road Home Elevation Award as long as you meet the eligibility requirements of the program.

For the State HMGP Award, you are eligible if you started construction prior to March 16, 2008. (Documentation is required). After March 16th, you must receive written authorization from the State in order to be eligible. Without the written authorization you may be ineligible.”
   
   
  My notes from a phone call with a FEMA Official in Wash. DC
   
  A FEMA official to whom I was referred by an official in the Office of the Federal Coordinator for Gulf Coast Rebuilding explained to me on the phone today (Mar. 13, 2008) the following.
   
  The March 16 deadline referred to above for Hazard Mitigation FEMA program (HMGP) for elevation allowances will mean only a rather short delay for the vast majority of Road Home (RH) applicants eligible for this Hazard Mitigation Funding if the State processes HMGP eligibility applications speedily and if applicants follow the instructions below.
   
  Here’s how it works as it was explained to me. I have tried to carefully check all these details, many of them with several different officials in different governmental offices, but can only relate what was told to me and so am not, of course, an authority on this.
   
  If you have evidence of having started physical work on elevation by Mar. 16, then FEMA in Jan. granted an exception to its rule that you cannot get Hazard Mitigation (HMGP) funding after starting the work and before approval by FEMA to do the work.
   
              A statement or invoice from a contractor showing that part of the elevation work was done —possibly including demolition- will be satisfactory evidence.
   
  That means if you have proof of starting elevation work from the day of the hurricane up to Mar. 16, you are eligible by FEMA’s rules for this HMGP funding. Still you will have to fill in the HMGP award form sent to you from Road Home this week or next and send it right back to them.
   
  If you do not have this evidence, for most applicants, it won’t be a major hurdle, just a minor one if FEMA keeps to its time projection and the State efficiently turns over to FEMA eligibility requests and if you follow the instruction about not starting elevation work (or probably not signing the contract for this work) until you do the following. 
   
  The hurdle is this. You will have to have the State (via the Road Home Program or another State Program called GOSEP) submit to FEMA a request for approval of your eligibility for the HMGP elevation program. 
   
  According to the FEMA official, from the time that the State hands the list to FEMA, for all but a small percent of special historical or environmental issue cases, it will take FEMA only 2-4 weeks to give approval of eligibility. This is revolutionarily fast for FEMA partly because they have already started investigating the approval issues, especially cost-benefit analysis, for RH applicants in a batchwise method. 
   
  From the time that FEMA gives its approval (which the State will have to tell you about, we hope quickly), you may sign the elevation work contract and then be eligible for HMGP elevation funding.
   
  If you started elevation work some time after Mar. 15 and before this approval from FEMA, you cannot get an HMGP elevation grant although you may well be eligible for the Road Home Elevation Incentive. In any case, it may be in your best interests to fill out both the HMGP Award Form and the Elevation Incentive Form that eligible Road Home applicants are receiving from Road Home.
   
   
   
  Bottom line and deadlines for HMGP elevation funding
   
  All State-approved elevation applications that are to use HMGP elevation funds, will have to have this FEMA approval, which will normally be 2-4 weeks from when the State hands your name to FEMA.
   
  If you already started elevation work before Mar. 16 and have paperwork to prove it, just keep doing it. 
   
  If you did not yet sign a contract for elevation work and you want to be eligible for the HMGP elevation funding, fill out the HMGP portion of your RH elevation form as soon as it comes in the mail and send it back. 
   
  You can fill out the forms for both the Road Home Elevation Incentive and the HMGP elevation award grant if you like. Which one you get and whether you get both remains to be seen. 
   
  Covered expenses for elevation might include anything that is directly related to raising a pre-existing repaired house or building a new elevated one as far as FEMA is concerned, possibly including a new slab needed for elevation or crane rental needed for lifting up an elevated modular home. We have to await further definitions of what is covered from the State.
   
  The best time projections assume that RH or GOSEP quickly sets up a process for sending lists of applicants who have filled out the HMGP request form for eligibility for HMGP to FEMA and then quickly informs you once the State receives the FEMA acceptance, so that you can sign a contract to start elevation work and be eligible for HMGP elevation money.
   
   
   
  More Information From My Talk With Federal Officials
   
  It is up to the State to determine the amount of money per elevation grant even though the money comes from federal sources. The State set the cap of total funding at $150,000 per applicant including Road Home Elevation Incentive (which comes from the Road Home applicants’ HUD funding plus $1 billion of state funds).
   
  The State could spare Road Home grant funding money and give grants of, say, up to $60,000 per applicant from HMGP money even on top of the $150,000 cap for Road Home grant money if it wanted to although the State’s current rules do not allow that.
   
  The State could declare eligible for Elevation Incentives and/or HMGP elevation awards people who bought an Option 1 property with assumption of the RH covenant and want to elevate. However, the State’s current recently released rules do not allow that.
   
  Road Home grant money (that $11.5 billion of mostly HUD money) can only be spent on Road Home applicants.
   
  HMGP money (that $1.2 billion left over from an initial $1.47 billion) can be spent anywhere in the state on a wide variety of projects.
   
   
   
  My Own Observations
   
  The State has about $1.2 billion in this HMGP fund. If it gives out most of the elevation money from the Road Home grant funds, it will thereby save money from this HMGP fund. This will be especially true if the State continues with its plan to only start the HMGP elevation grant mechanism this summer. 
   
  That HMGP money came to Louisiana as an automatically transmitted percentage of FEMA money spent on immediate disaster relief in the wake of Hurricanes Katrina and Rita hitting South Louisiana.
   
  The State had informed the public on many occasions that it intended to use for elevation allowances the HMGP money but it was waiting for it to become available through FEMA approval and speeded-up FEMA rules.
   
  Those accommodations were made in January and yet the State is choosing to give out HMGP money for elevation grants only on a delayed schedule with Road Home grant funds as the primary source of elevation grants.
   
  This saving up HMGP money by mostly using Road Home money for elevation allowances could permit the State to spend more HMGP money in parts of the state untouched by the hurricanes and flooding. 
   
  This use of Road Home grant money as the primary source of elevation grants, unlike the original plan to depend on HMGP money, will prevent the best use of Road Home grant money for fairer grants to applicants in great distress because of these hurricanes that devastated their homes.
   
  Melanie Ehrlich
  Founder, CHAT
  Member, LRA Housing Task Force
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