Policy News field

HAC’s network supports improvements to USDA’s Rural Housing Service in letter to Congress

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With the help of our network of organizations working across the country in rural areas, more than 100 organizations signed on to support bipartisan, cross-Committee collaboration to consider improvements to USDA’s Rural Housing Service (RHS) programs as part of the larger Farm Bill. Historically, the RHS programs have not been included in the Rural Development Title of the Farm Bill because they fall within the jurisdiction of the Banking Committee. But in recent months there has been increased cross-Committee momentum to include some bipartisan RHS modernizations in the Farm Bill, and we want to encourage that momentum to keep building. Check out the letter below to learn more. Thanks to all the organizations who signed on in support!

HAC Rural Housing Farm Bill Sign-on 2023 FINAL
HAC in the News

Advocates eye farm bill to avert drop in affordable rural housing – CQ Roll Call

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By Caitlin Reilly

Posted April 11, 2023 at 5:00am

Housing advocates are turning to this year’s farm bill in an effort to steer rural communities away from an affordable housing cliff ahead.

Without action from Congress, rural communities stand to lose more than 100,000 affordable rental units in the next decade as federally subsidized loans used to build the apartments are paid off, ending landlords’ obligations to keep rents low. In a second blow for those renters, they will lose their eligibility for the Agriculture Department’s rental assistance.

“It’s a big problem, and it’s going to only get worse,” said Sarah Saadian, senior vice president of public policy at the National Low Income Housing Coalition.

“The heyday or the peak of rural housing was in the ’70s and ’80s, when their rental housing program was nearly a billion-dollar program, and it’s been cut really dramatically over the last several decades,” Saadian said in an interview. “All of those properties that were built at that time are now reaching the end of the maturity on their 515 mortgage, or the 515 loans that USDA provides in order to get those properties built.”

Advocates are pushing Congress to include provisions in the farm bill that would decouple the two programs, allowing the Agriculture Department to provide rental assistance even after a building’s owner has paid off the subsidized mortgage.

Read the full article

“The biggest issue in rural housing is the rapid loss of the 515 units due to mortgage maturity, prepayments, foreclosures. That is the 800-pound gorilla, or really the $31 billion gorilla over the next 30 years to preserve.”

Policy News from Congress

HAC’s Research Director Testifies to Senate Banking Committee on the State of Housing 2023

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HAC was deeply honored by an invitation to testify at the first hearing held in the new 118th Congress by the Senate Banking, Housing, and Urban Affairs Committee. Titled The State of Housing 2023, the session featured Lance George, HAC’s Director of Research and Information, as one of  three witnesses.

A wide range of topics was covered by the witnesses’ testimony and the Senators’ questions. Among the key areas of concern were the gap between housing supply and need, the high cost of both homeownership and rental housing, and what congressional actions could address these challenges. Committee Chair Sherrod Brown (D-Ohio) asked specifically about the loss of rentals financed by USDA’s Section 515 program, a serious concern addressed by HAC research in 2016 and 2022.

Key Takeaways

Lance’s statement made five key points about the state of rural housing in 2023:

  • The pandemic left its mark on rural America and housing markets remain uncertain.
  • Rural mortgage markets are being impacted by interest rates and prices too.
  • Affordability is the greatest housing challenge in rural America, by far.
  • Manufactured housing is an often overlooked but important source of housing – especially in rural America.
  • Race matters across the rural spectrum – especially in housing.

Key policy recommendations, based on HAC’s full set of policy priorities for 2023, included:

  • Increase rural communities’ access to credit and capital and strengthen USDA and HUD homeownership supports.
  • Improve opportunities and financing for preserving aging rental properties and protecting tenants.
  • Authorize the powerful Rural Community Development Initiative and a significant cross-sectoral, flexible capacity building rural investment initiative.

Read Lance’s Statement

Lance George

Lance George

HAC’s Director of Research & Information

Watch the Hearing


Policy News from Congress

Housing Assistance Council Statement on FY 2023 Omnibus Bill

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This bipartisan agreement maintains funding for USDA’s rural rental housing portfolio and makes a game-changing investment in manufactured housing.

The Housing Assistance Council appreciates Congress continuing to invest in rural communities through the latest omnibus spending bill and hopes that the next Congress will take further steps in 2023 to address the housing crisis in rural America.

The appropriations agreement reached this week makes significant contributions to affordable rural rental housing through the U.S. Department of Agriculture’s housing programs. It also provides $225 million in funding for a new manufactured housing financing and improvement program to be administered by the U.S. Department of Housing and Urban Development.

“This bipartisan agreement maintains funding for USDA’s rural rental housing portfolio and makes a game-changing investment in manufactured housing,” said HAC CEO David Lipsetz. “Rural communities will use this funding to preserve existing affordable housing, build more, and lay the foundation for a better future.”

More than half of all manufactured homes are in rural places. In May, HAC’s Director of Research and Information Lance George testified to Congress that manufactured housing “should continue to be a high-quality, affordable housing option” for rural America.  By creating the first dedicated funding stream targeted to this essential affordable housing stock, this omnibus spending bill takes a critical first step toward achieving just that.

HAC also appreciates the omnibus’s continued support of capacity building programs through USDA and HUD. Congress has long recognized that housing programs only work when there are local partners helping to build, manage, and maintain affordable homes. With a modest investment in the capacity of small towns’ local housing organizations, rural communities can navigate the complexities of federal programs and modern housing finance. As the only national intermediary dedicated solely to rural housing, HAC is gratified to see HUD’s Rural Capacity Building program receive its first increase in program history, from its founding in 2012 at $5 million to $6 million in FY 2023. This will enable HAC and other RCB grantees to provide training and technical assistance to community-based organizations across rural America.

Yet the omnibus leaves too many rural Americans’ housing problems unaddressed. Most of the housing programs at both USDA and HUD enter 2023 with about the same resources they had in 2022, even as mortgage and rent costs are increasing across the country, USDA-financed rental developments are losing their affordability, and homelessness is increasing in rural areas. HAC calls on the 118th Congress to be bolder – to increase support for proven solutions and to innovate. Both the annual appropriations process and the 2023 Farm Bill offer opportunities for action. HAC’s detailed suggestions can be found here and here.

Everyone deserves a safe, healthy, and affordable place to call home. Through the upcoming Farm Bill and the next appropriations cycle, the 118th Congress will have the opportunity to make even more transformative investments that could make that vision a reality.

Policy News from Congress

Final FY23 Spending Bill Boosts Some Rural Housing Programs

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Most USDA rural housing programs will see modest boosts or flat funding for fiscal year 2023 in the omnibus spending bill congressional leaders released on December 20, 2022, which is expected to be enacted later this week. Funding for the Section 514 farmworker housing program will drop, however, from $28 million in FY22 to $20 million this year. The Community Facilities grant account is hit even harder, falling from $40 million in FY22 to $25.3 million this year, although the bill does add $50 million for CF grants to disaster areas.

— HAC’s analysis of FY23 appropriations for HUD is available here.  —

The bill’s funding levels support rental preservation efforts, although the measure does not decouple (separate) Section 521 Rental Assistance from USDA Section 514 and 515 mortgages. It substantially increases USDA’s Section 538 rental housing loan guarantees, which are used for preservation as well as new construction, from $230 million in FY22 to $400 million in FY23. This program has been fully utilized in the past two years – an indication of strong demand – and the administration’s budget had requested the additional funds. Section 515 direct rental housing loans receive a smaller increase, from $50 million this year to $70 million next year.

The Section 514 farm labor housing loan program, however, is cut from $28 million to $20 million. Section 516 grants hold steady at $10 million.

The bill also supports USDA’s new initiative to improve homeownership opportunities for Native Americans, allocating $7.5 million for Native CDFIs to make Section 502 direct loans to Native Americans.

Emergency funding is provided for some of the rural housing programs, to be used in places where presidentially declared disasters occurred in FY22. The Rural Housing Assistance Grants account – which includes both Section 504 repair grants for low-income elderly homeowners and also Section 533 Housing Preservation Grants for owner-occupied or rental housing – receives $60 million. Community Facilities programs get $75.3 million, $50 of which is specifically for grants to repair essential community facilities. These CF grants can cover up to 75 percent of the cost of a repair.

The bill mandates smoke detectors in rental housing that is constructed, rehabilitated, or repaired with Section 515 or Section 514/516 funds, or funding from any of several HUD rental programs. The requirement will take effect in December 2024.

The table below shows the dollar amounts provided for USDA rural housing and community facilities programs.

USDA Rural Dev. Prog. (dollars in millions) FY22 Final Approp. FY23 Budget FY23 House Bill FY23 Senate Bill FY23 Final
502 Single Fam. Direct $1,250 $1,500 $1,500 $1,500 $1,250
Nat. Amer. Single Fam. Demo – 20.8 12 20.8 7.5
502 Single Family Guar. 30,000 30,000 30,000 30,000 30,000
504 VLI Repair Loans 28 50 28 30 28
504 VLI Repair Grants 32 45 32 32 32
515 Rental Hsg. Direct Lns. 50 200 150 100 70
514 Farm Labor Hsg. Lns. 28 50 30 35 20
516 Farm Labor Hsg. Grts. 10 18 16 14 10
521 Rental Assistance 1,450 1,564 1,494 1,488 1,488
523 Self-Help TA 32 40 33 32 32
533 Hsg. Prsrv. Grants 16 30 16 16 16
538 Rental Hsg. Guar. 250 400 300 400 400
Rental Prsrv. Demo. (MPR) 34 75 40 45 36
542 Rural Hsg. Vouchers 45 38 38 50 48
Rental Prsrv. TA 2 0 2 5 2
Community Facil. Loans 2,800 2,800 2,800 2,800 2,800
Community Facil. Grants 40 52 68.1 100 25.3
Rural Cmnty. Dev’t Init. 6 12 8 7 6
Tribal Colleges CF Grts 10 10 10 10 10
Cong. Directed Spending* 126.9 202.3 325.5
Community Facil. Guarantees 650 500 650 650 650

* Congressionally Directed Spending (earmarks) accounts for a large portion of the Community Facilities Grant spending in both the House and Senate bills, and in the final bill. Specific projects, which were listed in the House and Senate committee reports, are catalogued in the explanatory statement for the final bill.

Senate Proposes Rural Housing Funding Increases

The Senate Appropriations Committee proposes rural housing funding levels for the upcoming fiscal year much like those in the administration’s budget request and the bill passed by the House. On July 28, the committee released its version of all 12 appropriations bills for fiscal 2023, which begins on October 1, 2022.

The fate of these bills is unclear. The Senate has not scheduled action on any of them. The House has passed a “minibus” bill that combines appropriations measures for several agencies, including the U.S. Department of Agriculture (USDA) and the Department of Housing and Urban Development (HUD), but the fiscal year is expected to begin with a continuing resolution holding government spending at FY22 levels. Final appropriations are not likely to be completed until after the midterm elections in early November.

— HAC’s analysis of FY23 appropriations for HUD is available here.  —

Homeownership

The Senate committee’s USDA bill would keep most of the rural single-family housing programs at or near their current funding levels. It endorses the request in USDA’s budget to provide almost $21 million to expand the Native American relending pilot program, which enlists a Native Community Development Financial Institution to work with tribes and Native homebuyers.

Rental Housing

The Senate bill would provide $100 million for Section 515, twice as much as in FY22 but lower than the $200 million requested by the administration – which proposed to finance new Section 515 construction for the first time since fiscal year 2011 – and the $150 million in the House bill. Like the House, this bill also rejects USDA’s request for enough Section 521 Rental Assistance (RA) funding to renew the RA contracts created under the American Rescue Plan Act.

To support efforts to preserve existing USDA-financed rental housing, the bill would adopt legislative language proposed in USDA’s budget, allowing RA to be “decoupled” from the Section 515 and Section 514 mortgage programs. As a last resort, if there is no other way to preserve a property as affordable housing, RA could continue to be used even after the mortgage is paid off. The Senate bill would impose a limit on this tactic so that it could be used for no more than 15,000 units in FY23. That ceiling seems unlikely to pose a problem: HAC has reported that 21,693 units left the Section 515 portfolio over a five-year period from early 2016 to 2021, an average of fewer than 4,350 units per year.

In another preservation effort, the bill would more than double technical assistance funding to help nonprofits and public housing authorities purchase and preserve USDA-financed rental properties. The program, which received $2 million in FY22 and was not included in the administration’s budget, would get $5 million.

The explanatory statement released to accompany the bill – equivalent to a committee report for a bill passed by a congressional committee – criticizes USDA for not having developed a rental preservation plan.

Multifamily Technical Assistance Report.—The Committee reminds the Department that the fiscal year 2017 Appropriations Act required the Department to conduct research and identify policy, program reforms, and incentives for preserving rural rental housing and a report summarizing those findings to be submitted to the Committee 2 years later. The report is now 3 years overdue and the Committee directs the Department to submit the completed report within 30 days of enactment of this Act.

Capacity Building

The Senate bill would increase funding for the Rural Community Development Initiative (RCDI) from $6 million in FY22 to $7 million in FY23. The House-passed bill would provide $8 million for RCDI next year, and the administration’s budget requested $12 million.

The Senate bill includes $10 million for the Rural Partners Network. It would also provide $15 million for the Institute for Rural Partnerships, first funded in the FY22 USDA appropriations bill.

Community Facilities

The explanatory statement accompanying the Senate committee’s bill tells USDA to find ways to expand community eligibility for community facilities grants.

Community Facilities Eligibility.—The Committee is concerned by the ineligibility of projects under the Community Facilities Grant program located in significantly rural and low-income areas that are defined as distressed but do not qualify for grant funding under this program. The Department is required to evaluate the program’s income and service area-based eligibility standards and identify ways to approve community access to these grants, including whether basing eligibility on national rather than state median household income could benefit areas located in predominantly poor, rural States.

 

USDA Rural Dev. Prog. (dollars in millions) FY21 Final Approp. Amer. Rescue Plan Act FY22 Final Approp. FY23 Budget FY23 House Bill FY23 Senate Bill
502 Single Fam. Direct $1,000 $656.60 $1,250 $1,500 $1,500 $1,500
Nat. Amer. Single Fam. Demo – – – 20.8 12 20.8
502 Single Family Guar. 24,000 – 30,000 30,000 30,000 30,000
504 VLI Repair Loans 28 18.3 28 50 28 30
504 VLI Repair Grants 30 – 32 45 32 32
515 Rental Hsg. Direct Lns. 40 – 50 200 150 100
514 Farm Labor Hsg. Lns. 28 – 28 50 30 35
516 Farm Labor Hsg. Grts. 10 – 10 18 16 14
521 Rental Assistance 1,410 100 1,450 1,564 1,494 1,488
523 Self-Help TA 31 – 32 40 33 32
533 Hsg. Prsrv. Grants 15 – 16 30 16 16
538 Rental Hsg. Guar. 230 – 250 400 300 400
Rental Prsrv. Demo. (MPR) 28 – 34 75 40 45
542 Rural Hsg. Vouchers 40 – 45 38 38 50
Rental Prsrv. TA 2 – 2 0 2 5
Community Facil. Loans 2,800 2,800 2,800 2,800 2,800
Community Facil. Grants 32 40 52 68.1 100
Rural Cmnty. Dev’t Init. 6 – 6 12 8 7
Tribal Colleges CF Grts 5 10 10 10 10
Cong. Directed Spending* – – 126.9 202.3
Community Facil. Guarantees 500 650 500 650 650

* Congressionally Directed Spending (earmarks) accounts for a large portion of the proposed Community Facilities Grant spending in both the House and Senate bills. Specific projects are listed in the House and Senate committee reports.

House Passes USDA Funding Bill

July 20, 2022 – The full House of Representatives passed the USDA appropriations bill as part of a “minibus” that combines several funding bills, including those for USDA and HUD. The Senate has not yet begun actions on FY23 appropriations, and a continuing resolution is expected to be needed to begin the fiscal year on October 1, 2022.

House Funding Bill Includes Modest Increases for Some Rural Housing Programs, Though Less Than USDA Requested

On June 14, the House Agriculture Appropriations Subcommittee approved a funding bill for fiscal year 2023, which begins on October 1, 2022. The House bill proposes less funding for several rural housing programs than the administration’s budget did, while also rejecting the administration’s cut in Community Facilities guaranteed loans.

The full committee will consider the bill on June 23.

The House would increase the Section 515 rental housing program and the MPR rental preservation program above current levels, but not to the extent proposed by the administration. It would raise the Rural Community Development Initiative capacity building program from this year’s $6 million to $8 million in FY23 rather than the $12 million USDA requested. The rental preservation technical assistance program would receive $2 million again under the House bill, although USDA did not propose any funding for it.

It is not clear whether the bill is intended to fund renewals of the Section 521 Rental Assistance contracts added by the American Rescue Plan Act, but it proposes lower funding for Section 521 than the administration’s budget, which explicitly stated it did include the new contracts. Also, the House bill does not adopt USDA’s proposal to “decouple” the Section 521 Rental Assistance program from the Section 515 and 514/516 programs, which would allow properties to continue to receive Rental Assistance after their USDA mortgages end.

Like USDA’s budget, the House bill would expand USDA’s pilot program for Native American mortgage lending, which provides funds to Native CDFIs to be reloaned to homebuyers.

Budget Requests Increases in Most Rural Housing Programs

The Biden Administration’s budget for fiscal year 2023 proposes funding increases for almost every U.S. Department of Agriculture rural housing program, along with some important program changes for preservation of aging rental housing.

The March 28, 2022 budget release is only the first step in the process of developing federal appropriations for the fiscal year that begins on October 1, 2022. HAC held a webinar to review the budget’s contents and what to expect over the coming months; view the slides and recording here.

Rental Housing

The USDA budget proposes to quadruple Section 515 rental housing from $50 million in FY22 to $200 million in FY23, with the funds to be used for preserving existing Section 515 properties. The Multifamily Preservation and Revitalization program, which finances efforts to upgrade and maintain aging units constructed with Section 515 financing or the Section 514/516 farmworker housing program, would jump from $34 million this year to $75 million in FY23.

Farmworker housing loans and grants would almost double, with $6 million in Section 521 Rental Assistance set aside for new Section 514/516 units. The Section 538 loan guarantee program would see a large increase as well. (Details are provided in the table below.)

The $1.564 billion requested for Section 521 Rental Assistance renewals “will enable 272,000 existing contracts to be renewed, including making permanent the approximately 27,000 units that were brought into the program by the American Rescue Plan Act supplemental funding,” according to USDA’s budget explanation. The same document states, however, that RA assisted 284,194 tenant households in FY21.

The budget also asks Congress to “decouple” Rental Assistance from Section 515. Currently the programs are linked: RA cannot be made available to a property unless it has a USDA Section 515 or 514 loan. Separating them, so that RA could be offered after a property pays off its USDA mortgage, would help keep properties affordable for their tenants.

To protect tenants whose properties leave the USDA portfolio without decoupling, the administration proposes to provide $20 million in HUD Tenant Protection Vouchers. Based on the assumption that decoupling and the availability of HUD vouchers will eliminate the need for new USDA vouchers, the budget requests only enough Section 542 funding to renew existing assistance.

Homeownership

The budget proposes to increase funding for all USDA’s homeownership programs. It would also provide $20.8 million to expand the Native American Section 502 Relending pilot program. The pilot has enabled Native Community Development Financial Institutions to assist Native American homebuyers in tribal communities of South Dakota and North Dakota.

Rural Partnership Program

Pursuing an idea proposed in the Build Back Better Act, which has not been passed by Congress, the budget proposes $39 million for the Rural Partnership Program. In a statement about the budget, Agriculture Secretary Tom Vilsack described it as “a renewed and expanded initiative to leverage USDA’s extensive network of county-based offices to help people in high poverty counties, including energy communities.”

Placemaking

The budget would provide $3 million for the Rural Placemaking Innovation Challenge “to provide planning support, technical assistance, and training to foster placemaking activities in rural communities.” [NOTE: This sentence was corrected on March 29 to say $3 million. When this post was published, it stated incorrectly that the amount was $3 billion.]

Energy Efficiency and Climate Resilience

All USDA housing production would be required to “improve energy or water efficiency, indoor air quality, or sustainability improvements, implement low-emission technologies, materials, or processes, including zero-emission electricity generation, energy storage, building electrification, or electric car charging station installations; or address climate resilience of multifamily properties.”

 

Policy News field

HAC Comments on Community Investment Focus on Capacity Building and Capital Access

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Several federal government agencies recently formed an Interagency Community Investment Committee (ICIC), focused on the operations and execution of federal programs that facilitate the flow of capital and the provision of financial resources into historically underserved communities, including communities of color, rural communities, and Tribal nations. The ICIC requested public input on ways the agencies can promote economic conditions and systems that reduce racial disparities and produce stronger economic outcomes for all communities. According to the request for comment, responses may be used to inform ICIC’s future actions to improve the operations and delivery of federal community investment programs through stronger federal collaboration. The committee is composed of representatives from the Department of the Treasury, Small Business Administration, Department of Commerce, Department of Transportation, Department of Housing and Urban Development, and Department of Agriculture.

Key Takeaways

  1. Support capacity building for local organizations embedded in their communities.
  2. Provide equitable access to capital for rural America.
  3. Address rural needs, particularly in persistent poverty areas, directly.
  4. Accelerate interagency coordination and sharing of best practices.
  5. Improve data and information accuracy and availability.

Read HAC’s comments, submitted on December 19, 2022. Other comments are posted here.

HAC Comments on Community Investment Focus on Capacity Building and Capital Access
Policy News field

HAC’s Research Director Testifies on Persistent Poverty on Capitol Hill

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On Tuesday, November 15, 2022 at 10:00 am EST the Subcommittee on Housing, Community Development and Insurance convened a hybrid hearing entitled, “Persistent Poverty in America: Addressing Chronic Disinvestment in Colonias, the Southern Black Belt, and the U.S. Territories.” Lance George, HAC’s Director of Research and Information, provided testimony during the hearing.

Watch the Hearing

For more information on Persistent Poverty, read The Persistence of Poverty in Rural America.

Policy News town

Rural Setaside Included in Major New HUD Homeless Funding Initiative – UPDATED 9/19/22

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Webinar recording and slides posted

A webinar titled Funding Opportunities: Learn More About HUD’s Special NOFO to Address Rural Homelessness and New Stability Housing Voucher Program, cosponsored by HAC, the National Alliance to End Homelessness, and the National Association of Housing and Redevelopment Officials, was presented on September 15, 2022. The webinar recording and slide presentations are now available online.

Introduction

On June 22, 2022, HUD released a Notice of Funding Opportunity (NOFO) titled “Continuum of Care Supplemental to Address Unsheltered and Rural Homelessness.” A total of $322 million in recaptured Continuum of Care (CoC) funds is available, comprised of $267.5 million for an “Unsheltered Homelessness Set Aside” and $54.5 million for a “Rural Set Aside.”

Any CoC that registered for the FY 2022 CoC program competition may apply under this NOFO. Projects under the Unsheltered Homelessness Set Aside may serve any geographic area within the CoC. A CoC whose service area includes places that meet the rural definition (below) may apply for either the Unsheltered Homelessness Set Aside or the Rural Set Aside, or both.

Projects that will serve places where CoCs have not previously worked are targeted for special attention within the Rural Set Aside. When HUD scores applications, 10 points out of the total 100 available are specifically for “projects that serve individuals and families in geographic areas that have high levels of homelessness, housing distress, or poverty, and are located where CoC services have until now been entirely unavailable, such as, for example, Trust Lands and Reservations.”

This Competition

CoC applications are due to HUD on October 20, 2022. Each CoC must design its own “collaborative process” to develop its proposal, including a process for project applications. A local organizations or government entity must apply to its area CoC to be included in the CoC’s application to HUD.

This competition is separate from the FY 2022 CoC program competition, which has not yet opened. Applications and awards for this competition will not impact those for the FY 2022 competition.

Eligible Project Applicants

Nonprofit organizations, states, local governments, instrumentalities of state and local governments, Indian Tribes, TDHEs, and PHAs are eligible to apply for project funding under either set aside in this competition. For-profit entities are not eligible to apply or to be subrecipients of grant funds.

Rural Definition

Counties and county equivalents where the Rural Set Aside can be used are listed in the NOFO’s Appendix B.

The rural definition used for this competition was adopted in the HEARTH Act, which provides that a rural area is a county that meets one of three criteria:

  1. It is completely outside of OMB-designated standard metropolitan statistical areas (i.e., it is nonmetropolitan).
  2. It is in an OMB-designated metropolitan statistical area and at least 75% of its population lives in census blocks classified as non-urban.
  3. It is located in a state that has a population density of less than 30 persons per square mile (as reported in the most recent decennial census), and that has at least 1.25% of its total acreage under federal jurisdiction, provided that no metropolitan city in such state is the sole beneficiary of the grant amounts awarded under this NOFO.

Funds Available

The maximum amount that each CoC can request is listed in the NOFO’s Appendix A. These amounts are calculated differently for the two set asides. For the Unsheltered Set Aside, each CoC is eligible for its Preliminary Pro Rata Need (PPRN) for the FY 2022 CoC Program Competition or $60 million, whichever is less. For the Rural Set Aside, the maximum is set at 150% of the combined PPRNs for the FY 2022 CoC Program Competition of all of the CoC’s rural areas.

Grant Terms

Grants under this NOFO will be for three-year terms. Grants for hard costs are not renewable. HUD expects that others will be renewable under regular CoC competitions, though they caution that they cannot guarantee what will happen in the future.

Eligible Activities

The Rural Set Aside can be used to finance more activities than the Unsheltered Set Aside, as summarized in the table below.

 

 

Unsheltered Set Aside

  

Rural Set Aside
 

Eligible activities

  

Permanent housing

Supportive services only

HMIS

Joint transitional housing and permanent housing-rapid re-housing

Planning costs (capped at 3% of maximum award amount)

Unified Funding Agency costs (capped at 3% of maximum award amount)

  

Permanent housing

Supportive services only

HMIS

Joint transitional housing and permanent housing-rapid re-housing

Rent or utilities in some situations

Emergency shelter costs

Repairs to make housing habitable

Capacity building activities (capped at 20% of total funds a CoC requests)

Emergency food and clothing

Costs to use federal inventory property

Staff and overhead directly related to carrying out activities in this list
 

Ineligible activities

  

Acquisition

New construction

Rehabilitation

  

Planning costs

Unified Funding Agency costs

 

Eligible Participants/Definition of “Homeless”

Characteristics of people who will be eligible to participate in projects funded under each set aside in this NOFO – i.e., those who are considered to be “homeless” – are listed in the table below.

 

 

Unsheltered Set Aside

  

Rural Set Aside
 

Eligible participants

  

People who are literally homeless, “except that persons coming from transitional housing must have originally come from places not meant for human habitation, emergency shelters, safe havens, or institutions where they resided for 90 days or less and originally came from places not meant for human habitation, safe havens, or emergency shelters”

Domestic violence victims

  

People who are literally homeless

People who are precariously housed

Domestic violence victims

Youth or families considered homeless under other statutes, if CoC obtains HUD approval, limited to certain types of projects, and capped at 10% of award

 
 

Ineligible participants

  

People who are precariously housed

Youth or families considered homeless under other statutes

  

None

 

Plan for Severe Service Needs

Each CoC applying under this NOFO must develop a “Plan for Serving Individuals and Families Experiencing Homelessness with Severe Service Needs.” For both the Unsheltered and Rural Set Asides, large portions of the application and the potential scoring points are based on these plans.

The NOFO defines Severe Service Needs as

any combination of the following factors: facing significant challenges or functional impairments, including any physical, mental, developmental or behavioral health disabilities regardless of the type of disability, which require a significant level of support in order to maintain permanent housing (this factor focuses on the level of support needed and is not based on disability type); high utilization of crisis or emergency services to meet basic needs, including but not limited to emergency rooms, jails, and psychiatric facilities; currently living in an unsheltered situation or having a history of living in an unsheltered situation; experiencing a vulnerability to illness or death; having a risk of continued or repeated homelessness; and having a vulnerability to victimization, including physical assault, trafficking or sex work.

Most of the plans’ components must be provided in applications for either Unsheltered or Rural funds. The outline of plan contents is provided in the table below, along with indications of where the requirements differ for Rural Set Aside applications.

 

 

Plan Component

  

Required for Unsheltered Set Aside

  

Required for Rural Set Aside
a. Leveraging housing resources
1. Development of new units and creation of housing opportunities Y Y
2. Landlord recruitment Y Y
b. Leveraging healthcare resources Y Y
c. CoC’s current strategy to identify, shelter, and house individuals and families experiencing unsheltered homelessness
1. Current street outreach strategy Y Y
2. Current strategy to provide immediate access to low-barrier shelter and temporary housing for individuals and families experiencing unsheltered homelessness Y N
3. Current strategy to provide immediate access to low barrier permanent housing for individuals and families experiencing unsheltered homelessness Y Y
d. Updating the CoC’s strategy to identify, shelter, and house individuals experiencing unsheltered homelessness with data and performance Y N
e. Identify and prioritize households experiencing or with histories of unsheltered homelessness Y Y
f. Involving individuals with lived experience of homelessness in decision making Y Y
g. Supporting underserved communities and supporting equitable community development Y Y

A different section of the NOFO contains a paragraph – which also appears in the FY 2021 CoC program NOFO – requiring applicants to identify steps they “will take” to ensure that traditionally marginalized populations (such as racial and ethnic minorities and persons with disabilities) will be able to meaningfully participate in “the planning process.” It is not clear whether, or how, this requirement would apply to the process of developing the severe needs plan, since this plan must be completed in order to be included in the application along with the proposal for steps applicants “will take” in developing future plans.

Application Scoring

For the Unsheltered Set Aside, HUD will select CoCs for awards based on the CoCs’ scores. All projects of the selected CoCs will be funded, up to the funding cap for those CoCs. For the Rural Set Aside, however, HUD will score the individual projects included in each application and select the highest scoring projects, up to the CoC’s maximum funding amount.

HUD will score the rural projects on a 100-point scale. Up to 50 points will correspond to HUD’s score for the CoC’s overall Rural Set Aside application. Up to 40 points will be based on the CoC’s ranking of the project (CoCs are required to rank all project applications for either set aside). Finally, another 10 points may be awarded to “projects that serve individuals and families in geographic areas that have high levels of homelessness, housing distress, or poverty, and are located where CoC services have until now been entirely unavailable, such as, for example, Trust Lands and Reservations.”

HUD may adjust its final project selections to ensure that at least one CoC in each HUD region is funded and that not more than 10 CoCs from a single state are funded.

Links for Additional Information

HUD email address for questions: SpecialCoCNOFO@hud.gov

HUD page where all information and supporting resources for this competition will be posted: https://www.hud.gov/program_offices/comm_planning/coc/specialCoCNOFO

HUD Continuum of Care program page: https://www.hud.gov/program_offices/comm_planning/coc

HUD page to locate a CoC serving a particular area: https://www.hudexchange.info/grantees/find-a-grantee/

HUD standard funding opportunity page for this NOFO: https://www.hud.gov/program_offices/spm/gmomgmt/grantsinfo/fundingopps/fy21coc_urh

Official grants.gov page for this NOFO: https://www.grants.gov/web/grants/view-opportunity.html?oppId=341301

Site where CoC applications will be entered: https://esnaps.hud.gov/

 

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New HUD Rural Homelessness Initiative Announced

On June 22 HUD announced a $365 million Initiative for Unsheltered and Rural Homelessness that will be distributed through Continuums of Care (CoC) and public housing authorities (PHAs) by means of two Notices of Funding Opportunity. The application deadline for CoCs is October 20. HUD is using recaptured CoC and Housing Choice Voucher funding from prior fiscal years to support the initiative.

The initiative includes $322 million in CoC program grants to be distributed by HUD’s Community Planning and Development division:

  • $267.5 million to fund homeless outreach, permanent housing, supportive services, and other costs as part of a comprehensive community approach to solve unsheltered homelessness in 20-40 communities with high incidences of unsheltered homelessness; and
  • $54.5 million targeted to rural communities, prioritizing those with high need but a history of being unable to access CoC grants. HUD is utilizing congressionally granted authority to expand the eligible uses for these funds beyond normal restrictions to enable rural communities to apply for grants to support capacity-building, transportation, and other needs more acutely felt in rural areas.

The division of Public and Indian Housing will distribute $43 million — approximately 4,000 new incremental vouchers — which will be allocated to PHAs with a priority for those that are partners in comprehensive community approaches to solve homelessness.

Manufactured Housing in the United States Map, 2018

Housing Assistance Council Statement on Proposed $500 Million Investment in Manufactured Housing

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The Housing Assistance Council (HAC) applauds Chairman David Price (D-4th-NC) and Ranking Member Mario Diaz-Balart (R-25th-FL) of the Transportation, Housing and Urban Development (THUD) Appropriations Subcommittee for their bipartisan and transformational investment in the Manufactured Housing Improvement and Financing Program.  The fiscal year (FY) 2023 budget bill passed this week by both the Subcommittee and the full Appropriations Committee includes $500 million to preserve and revitalize manufactured homes and manufactured housing communities, a long-underappreciated source of affordable housing for millions of Americans.

“The scale and scope of this bipartisan proposal, if enacted in the final FY 2023 HUD budget, would be a game-changer for families in need, HAC and our partners in this space.” – David Lipsetz, HAC CEO

This new program provides grants for a broad range of activities, from building affordable housing to building the capacity of local affordable housing organizations. The program will improve infrastructure, planning, resident and community services (including relocation assistance and eviction prevention), resiliency activities, and land and site acquisition.  The Department of Housing and Urban Development (HUD) would distribute the funds competitively to non-profits, CDFIs, resident-owned manufactured housing communities, states, local governments, Tribes, and other eligible entities.

“Manufactured housing represents the nation’s largest supply of affordable housing. Until this program, the poor, largely-rural families living in these homes have been denied access to the public programs that preserve and maintain housing for those that need it most. Nor have the non-profit and public sector entities who work with manufactured housing received federal funding commensurate with the preservation and revitalization challenge they face for this vital affordable housing stock,” said HAC President & CEO David Lipsetz. “The scale and scope of this bipartisan proposal, if enacted in the final FY 2023 HUD budget, would be a game-changer for families in need, HAC and our partners in this space.”

HAC is the only national non-profit intermediary dedicated to affordable housing in rural America. With a mission-focus on the most rural and poorest places, HAC has long prioritized manufactured housing given its disproportionate share of the rural housing stock.  Nationwide, approximately 6.7 million households live in manufactured or mobile homes, which is six (6) percent of the nation’s housing stock. Yet over 50 percent of all manufactured homes are located in rural areas.  which comprises 14 percent of all occupied homes in rural communities – more than twice the national rate.

The proposed program from Chairman Price and Ranking Member Diaz-Balart builds on the Subcommittee’s May 26th hearing “Manufactured Housing: Supporting America’s Largest Unsubsidized Affordable Housing Stock,” in which HAC’s Director of Research and Information Lance George testified on the challenges facing those seeking to maintain the quality of this essential affordable housing.  His testimony established that many manufactured housing residents lease the land on which their homes sit, leaving them vulnerable to evictions and predatory lot rents. And about two-thirds of manufactured home loans are classified as high cost—five times the national average for all homes.  His testimony concluded “manufactured housing is already a significant source of affordable housing in rural places, and it should continue to be a high-quality, affordable housing option.”  HAC strongly believes the Manufactured Housing Improvement and Financing Program would be a major step toward achieving just that.

Policy News from the Administration

HAC CEO Statement on Biden-Harris Housing Supply Action Plan

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by David Lipsetz

The Biden-Harris Administration released a Housing Supply Action Plan on May 16 that can bring the cost of housing back in line with families’ incomes. This is particularly important in small towns where incomes remain stubbornly low, while the cost of buying or renting a place to live is soaring. The Housing Assistance Council (HAC) applauds the Administration for designing and including several provisions specifically with rural markets in mind.

The Plan includes administrative and legislative proposals to improve existing housing finance mechanisms. It establishes new housing production programs. It calls for changes to the Low-Income Housing Tax Credit that will attract private investment in affordable rental housing. It provides grants—such as the HOME Investment Partnerships Program—to states, cities and towns to do what locals know will be best for their local housing market.  It calls on Congress to establish a Housing Supply Fund and incentivize zoning reform to accelerate the building of more housing across the Nation.

Critically, the Administration proposes reforms that prioritize homeowners living in the homes that they own. This is a welcome change for rural Americans who need high-quality affordable homes in which to live far more than they need high-priced vacation homes. For rental housing, the Administration focuses investment on small-scale 2–4-unit buildings instead of high-rise apartment complexes. It calls for new rentals where few are being built and recognizes the urgency of preserving affordable rentals that already exist. And for the first time in decades, an Administration released a housing plan that calls for improved financing for manufactured housing, an important resource in rural places.

The shortage of affordable housing in rural America is a serious issue. Rental units are being lost at an alarming rate. Single-family homes are significantly older than elsewhere in the Nation. The Administration’s framework recognizes the unique need for affordable housing and proposes solutions built to work in small town and rural America.

Many of the Administration’s actions just announced reflect HAC’s policy priorities. But it remains critical that these actions be complemented by initiatives to address another essential factor in improving housing for rural Americans—building the capacity of local organizations to improve their own communities. Because rural places often have small and part-time local governments, they often find it particularly difficult to navigate the complexities of federal programs and modern housing finance, and to compete for government resources. Philanthropy has not stepped in to address this inequity built into our systems, instead concentrating its resources in already-prosperous high-cost regions. Targeted capacity building through federal investments in training and technical assistance is how most local organizations build skills, tap information, and gain the wherewithal to do what they know needs to be done.

Rural communities hold vast potential to drive economic growth and improve the quality of life for all Americans. Access to quality, affordable housing is key to jumpstarting that potential. Building and preserving homes creates jobs, improves education and health outcomes, and provides much-needed financial and physical stability to families in need. We look forward to working with the Biden-Harris Administration and Congress to ensure that these initiatives move us closer to the day when every American has access to a safe, decent, and affordable place to call home.

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