North Carolina Annual Action Plan
2012
Presented to the U. S. Department of Housing and Urban Development
Developed By:
North Carolina Department of Commerce – Community Development and Assistance
North Carolina Housing Finance Agency
North Carolina Department of Health and Human Services
North Carolina Office of Economic Opportunity
North Carolina 2012 Annual Action Plan 2 November 15, 2011
Table of Contents
Executive Summary ...................................................................................................................................... 3
State Objectives ........................................................................................................................................................ 3
Evaluation of Past Performance ............................................................................................................................... 4
Expected Outcomes .................................................................................................................................................. 4
Process Management .................................................................................................................................. 4
Interagency Coordination and Collaboration ............................................................................................................ 7
Summary of Citizen Participation and Consultation Process ........................................................................ 8
Citizen Participation ................................................................................................................................................. 8
Consultation Process .............................................................................................................................................. 10
Sources of Funds ........................................................................................................................................ 10
North Carolina’s Housing Resources....................................................................................................................... 10
Matching Requirements ......................................................................................................................................... 11
Additional Funding Resources ................................................................................................................................ 12
Monitoring ................................................................................................................................................. 13
Lead-Based Paint ........................................................................................................................................ 14
Statement of Specific Objectives and Affordable Housing ......................................................................... 15
One-Year Specific Housing Goals and Objectives .................................................................................................... 15
Outcome Measures ................................................................................................................................................ 17
Allocation Priorities ................................................................................................................................................ 17
Homeless and Other Special Needs ......................................................................................................................... 18
Barriers to Affordable Housing ............................................................................................................................... 18
Anti-Poverty Strategies ........................................................................................................................................... 19
Public Housing Initiatives........................................................................................................................................ 20
Low-Income Housing Tax Credits (LIHTCs)............................................................................................................... 20
Program Reports ........................................................................................................................................ 21
Community Development Block Grant (CDBG) Program (91.320 k(1)) ........................................................................... 21
HOME Investment Partners (HOME) Program (91.320 k(2)) .......................................................................................... 26
Emergency Solutions Grants (ESG) Program (91.320 k(3)) ............................................................................................. 28
Housing Opportunities for People with AIDS (HOPWA) Program (91.320 k(4)) ............................................................. 29
Public Participation .................................................................................................................................... 31
Translations of this Document .................................................................................................................... 47
Certifications .............................................................................................................................................. 47
North Carolina 2012 Annual Action Plan Page 3 November 15, 2011
EXECUTIVE SUMMARY
(Citation: 24CFR91.320(b))
For the 2012 Program Year, the state estimates it will receive federal resources from the U.S Department of Housing and Urban Development (HUD) equal to the funding amount for 2011, or approximately $70 million. The four programs covered by this Action Plan are as follows (in alphabetical order): Community Development Block Grant (CDBG), Emergency Solutions Grant (ESG), HOME Investment Partnership (HOME) and Housing Opportunities for Persons with AIDS (HOPWA). Funds for these programs have been significantly reduced over the past several years, and as resources have decreased, needs have been prioritized and investments have been targeted to achieve the greatest impact on the goals and objectives indentified in the state’s Consolidated Plan.
State Objectives
The state realizes it cannot meet all of the housing need, but it can strategically invest its limited resources to alleviate important housing problems for North Carolina’s households.
The state has three (3) basic goals:
1. To provide decent and affordable housing
2. To provide a suitable living environment
3. To expand economic opportunity
The primary means through which these goals are achieved is the provision of affordable housing. Each agency operates programs that help to fulfill these goals, while meeting housing and service-related needs statewide.
This document, the 2012 Consolidated Annual Action Plan of the State of North Carolina, serves as the annual application to the U.S. Department of Housing and Urban Development (HUD) for funding for the following housing-related projects:
 $45 million in Community Development Block Grant (CDBG) funds, to be administered by the Department of Commerce, Community Investment and Assistance (CI);
 $20 million in HOME Investment Partnership Program (HOME) funds, and additional HOME match dollars to be administered by the North Carolina Housing Finance Agency;
 $2.6 million in Emergency Solutions Grant (ESG) funds, to be administered by the Department of Health and Human Services, Office of Economic Opportunity; and
 $2.4 million in Housing Opportunities for Persons with AIDS (HOPWA) funds, to be administered by the Department of Health and Human Services, AIDS Care Unit.
For information regarding specific programs, please visit the organization websites:
 Department of Commerce, Community Investment and Assistance - www.nccommerce.com North Carolina 2012 Annual Action Plan Page 4 November 15, 2011
 North Carolina Housing Finance Agency - www.nchfa.com
 AIDS Care Unit – www.epi.state.nc.us/epi/hiv/aidscare2.html
 Office of Economic Opportunity - www.ncdhhs.state.nc.us/oeo/
Evaluation of Past Performance
The state of North Carolina evaluates its performance annually on meeting the goals of the strategic plan and the action plan. The North Carolina Consolidated Annual Performance & Evaluation Report (CAPER) is submitted to HUD on March 31 of each year, 90 days after the close of the Consolidated Plan program year. The most recent past performance and evaluation reports can be downloaded from the DCA website at http://www.nccommerce.com/cd/investment-assistance/consolidated-plan.
Expected Outcomes
Of the total funding for housing activities to be undertaken in 2012, 39.3% of the funding is targeted to the high priority needs, 38.7% is targeted to the medium priority needs, and 22% is targeted to the low priority needs. The anticipated distribution of funding by agency and by priority need category is shown in the chart under the section One-Year Specific Housing Goals and Objectives.
PROCESS MANAGEMENT
The agencies responsible for managing these grant funds are as follows:
Grant Program Responsible Agency
Community Development Block Grant (CDBG)
NC Department of Commerce – Community Development and Assistance*
HOME Investment Partnership Program (HOME)
NC Housing Finance Agency
Emergency Solutions Grant (ESG)
NC Department of Health and Human Services, Office of Economic Opportunity
Housing Opportunities for Persons with AIDS (HOPWA)
NC Department of Health and Human Services, AIDS Care Unit
* Lead agency responsible for submitting action plan.
To ensure timeliness and accuracy in meeting HUD guidelines for submitting this action plan, a timeline was developed that showed key milestones such as meeting with partner agencies to public hearing notices. A copy of the timeline is given below. North Carolina 2012 Annual Action Plan Page 5 November 15, 2011
North Carolina 2012 Annual Action Plan Page 6 November 15, 2011
North Carolina 2012 Annual Action Plan Page 7 November 15, 2011
Interagency Coordination and Collaboration
Community Investment and Assistance
 CI will continue to work with other governmental and non-governmental groups such as the North Carolina Department of Labor, the North Carolina Housing Finance Agency, and the North Carolina IDA and Asset Building Collaborative to support and fund IDA and other savings programs in the state.
 CI will continue to engage other state agencies and federal allies in funding priority projects in 21st Century Communities. Counties selected in the most recent round will continue to receive priority status in 2010.
 CI will continue to serve on statewide housing policy boards such as the Housing Coordination and Policy Council.
 CI will continue to collaborate with state and local agencies such as the North Carolina Redevelopment Center and local emergency management and housing agencies on disaster relief projects as they arise.
 CI will continue to review plans submitted by housing agencies and public housing authorities in order to certify consistency with the Consolidated Plan.
North Carolina Housing Finance Agency
 The Agency is partnering with the U.S. Treasury Department, state Employment Security Commission, Commissioner of Banks and local housing counseling affiliates in the NC Foreclosure Prevention Fund, with funding from the Housing for Hardest Hit States Initiative and the state’s foreclosure filing fees.
 The Agency has partnered with the Advanced Energy Corporation (AEC) of Raleigh, North Carolina for over 10 years and will continue this partnership, to train and assist local partners under three home ownership programs. AEC’s services will include providing low-income homebuyers with guarantees that their heating and cooling costs with not exceed a very low, set level (as low as $18/month). This broadens the window of affordability and enhances marketing effectiveness.
 The Agency will continue as a member of the Interagency Coordinating Council for Homeless Programs (ICCHP).
 The State will continue its collaborative relationship with the Department of Labor by providing matching funds and second mortgages for participants in the Department of Labor’s IDA program. It will also broaden its support of IDA programs by developing partnerships statewide with other IDA programs.
 The Agency plans to continue its collaboration with Habitat for Humanity, in its operation of the Self Help Loan Pool (SHLP). In the SHLP collaboration, the NCHFA and Habitat for Humanity jointly provide a primary mortgage to low-income homebuyers of Habitat for Humanity homes. North Carolina 2012 Annual Action Plan Page 8 November 15, 2011
 The Agency will continue its collaboration with Duke Energy, by facilitating energy-related home improvements for homeowners in the Duke Energy Service Area, using money provided to the Agency by Duke Energy.
 The Agency will continue its partnership with the North Carolina Home Builders Association (NCHBA), wherein it provides funding (along with local governments) to enable the NCHBA to offer construction training for a small number of underemployed residents in 3 cities.
 The Agency will continue to fund the Displacement Prevention Partnership, which allows the Independent Living Program and the Lead Hazard Control Branch to assist households facing displacement due to mobility limitations or lead-paint poisoning, respectively. This Partnership will operate as a standalone program, separate from the Urgent Repair Program.
 The Agency works in close partnership with the state Department of Health and Human Services (DHHS) to administer the Key Program, providing operating subsidies so that persons with disabilities on Supplemental Security Income can have access to affordable housing.
 The Agency works with the state Office of State Budget and Management (OSBM) and DHHS to administer the Homeless Prevention and Rapid Re-Housing Program. The state of North Carolina was awarded $22 million to prevent homelessness and rapidly move homeless persons into housing.
Office of Economic Opportunity
 The Office of Economic Opportunity is a member of the Inter-Agency Council on Coordinating Homeless Programs and Housing Coordination and Policy Council.
AIDS Care Unit
 The Unit will continue as an active participant on the Housing Coordination and Policy Council as well as the Inter-agency Council on Coordinating Homeless Programs.
 The Unit will seek out opportunities to work with nonprofit organizations to provide services for those who are triply diagnosed (HIV/AIDS, mental illness and substance abuse issues).
 The Unit will continue to collaborate with the other NC entitlement cities to ensure consistency among administration of the HOPWA Program.
SUMMARY OF CITIZEN PARTICIPATION AND CONSULTATION PROCESS
(Citation: 24CFR91.200 and 91.220(b))
Citizen Participation
The state of North Carolina has developed a North Carolina Consolidated Plan Citizen Participation Plan. This plan is a guidance document to ensure and encourage public participation throughout the Consolidated Planning Process. It sets forth the state’s policies and procedures for citizen participation. The plan can be downloaded from the CI website at www.nccommerce.com.
North Carolina 2012 Annual Action Plan Page 9 November 15, 2011
The state of North Carolina encourages citizens to participate in the planning, implementation, and assessment of the Consolidated Plan for HUD Community Planning and Development programs. This plan describes how this participation is encouraged.
Citizens may make comments or request information regarding the Consolidated Plan by telephone, mail, or facsimile transmission to the Consolidated Planning Coordinator, Community Development and Assistance, 4313 Mail Service Center, Raleigh, North Carolina 27699-4313; Tel. (919) 571-4900; TDD 1-800-735-2962; Fax (919) 571-4951. The state will respond in the Consolidated Plan or performance report, as appropriate, to written comments received.
During the development of the plan, during the development of any substantial amendments, and prior to submission of the annual performance report to HUD, the state will solicit the views and proposals of citizens at a public hearing.
Notices for public hearing shall include:
1) The subject of the meeting;
2) Amount of funds anticipated to be available and range of eligible activities;
3) Estimated benefit to low and moderate income persons;
4) Information needed by citizens to make informed comments, or in the case where extensive information will be the subject of comment, where the information is available for inspection;
5) Time and location of the meeting;
6) The address and telephone number where special populations (persons with disabilities or non-English speaking persons) may request auxiliary aids or assistance;
7) The address where written comments may be submitted, and the time frame of the comment period for the subject of the meeting; and
8) The telephone number where persons may request additional information.
Notices: Adequate advance notice of meetings will be given. Notices will be published in newspapers of general circulation no less than ten days and no more than twenty-five days prior to the beginning of any series of hearings or meetings. Notices will also be mailed to local governments, advocacy groups, nonprofit housing organizations, housing-related service providers, for-profit developers, professional organizations, other known constituency groups, and citizens who have requested notification of any meetings.
Format: Meetings will be designed to allow the most opportunity and encouragement for citizens to express their views. At least one meeting will follow the format of a formal public hearing, while the state is identifying its housing and community development needs prior to writing the consolidated plan.
Accessibility: Meetings will be held at times and locations convenient to potential and actual beneficiaries. All meeting places will be handicapped accessible. Auxiliary aids, such as a sign-language North Carolina 2012 Annual Action Plan Page 10 November 15, 2011
interpreter, will be provided upon request. An interpreter will be provided at meetings where a significant number of non-English speaking persons can be reasonably expected to attend.
Action Plan: The state will develop an action plan annually for the use of its funds, and submit this plan with certifications. The state will receive comments from citizens and units of general local government on the proposed action plan for a period of not less than 30 days from the date when the draft is available to the public. The comment period will be publicized in the notices published in the newspaper and mailed to interested parties. Any comments received in writing or orally at the public hearings will be considered in preparing the final submission. The final action plan will include a summary of these comments or views and the reasons for not accepting any comments received. Public comment for this plan began on October 7, 2011 and ended on November 8, 2011.
Consultation Process
The state of North Carolina has developed a North Carolina Consolidated Plan Consultation Plan. This plan is a guidance document describing our state process for consulting with other public and private agencies that provide assisted housing, health services, and social and fair housing services. Input from these consultations is incorporated into our consolidated planning process.
SOURCES OF FUNDS
(Citation: 24CFR91.220(c)(1)) and (c)(2))
North Carolina’s Housing Resources
In 2012, the state proposes to assist over 53,000 households/persons and more than 43,000 homeless individuals and families through the four Department of Housing and Urban Development programs that fund the construction/rehabilitation of housing units, home buyer assistance for existing housing, rental assistance and some housing-related services. These four programs are listed below:
 The Small Cities Community Development Block Grant Program (CDBG)
The state expects to issue grants totaling approximately $32.7 million in CDBG funds for housing related activities in 2012.
 The HOME Investment Partnerships Program (HOME)
The state expects to receive $20 million in HOME funds in 2012.
 The Emergency Solutions Grants Program (ESG)
The state expects to receive $2.6 million in ESG funds during 2012.
 Housing Opportunities for Persons With AIDS Program (HOPWA)
The state expects to receive $2.4 million in HOPWA funds during 2012.
To conduct housing-related activities, the state uses non-federal as well as federal funds. The available funding sources can be categorized as shown below:
North Carolina 2012 Annual Action Plan Page 11 November 15, 2011
Federal
State
Other Resources
 Community Development Block Grant Program (CDBG)
 Emergency Solutions Grants Program (ESG)
 HOME Investment Partnership Program (HOME)
 Homeless Prevention and Rapid Re-housing Program (HPRP)
 Housing for Hardest Hit Funds
 Housing Opportunities for Persons with AIDS Program (HOPWA)
 Neighborhood Stabilization Program (NSP1 and NSP3)
 American Recovery and Reinvestment Act Funds
 Tax Credit Assistance Program ( TCAP)
 The Exchange Program
 Community Development Block Grant Recovery (CDBG-R)
 North Carolina Housing Trust Fund (HTF) and HOME Match funds appropriated by the General Assembly
 HPP – Housing Protection Program appropriated by the General Assembly
 State Tax Credits
 Housing Credits
 Mortgage Credit Certificates
 Mortgage Revenue Bonds
 National Foreclosure Mitigations Counseling Grant
North Carolina rarely funds 100% of any development. Rather, it attempts whenever possible to leverage investment from local governments, nonprofit organizations, for profit developers, and private investors.
Matching Requirements
The table below lists the federal and/or state matching funds requirements for each of the programs.
Program Federal Matching Requirement State Matching Requirement
CDBG
The state is required to provide an annual 1:1 match for federal administrative funds. The requirement is met by the state paying non-CDBG staff salaries.
Community Revitalization applications are rated for local commitment, though no local match is required for funding. In the Economic Development Program, all local governments except Tier 1 counties are required to provide a 25% match for the grant. A 5% match is required for Infrastructure grants, though that is waived for 21st Century Communities.
ESG
The state is required to match Emergency Solutions Grant funding received annually with an equal amount of funding from other sources. This requirement is passed to state grant recipients as allowed by ESG program regulations.
Each grantee must match the funding provided by the state with an equal amount of funds or voluntary efforts. North Carolina 2012 Annual Action Plan Page 12 November 15, 2011
HOME
25% match required. This is a requirement of the state as a Participating Jurisdiction but it is not passed on to recipients under the state programs that are funded with HOME. Some of the state’s required match is appropriated by the General Assembly. The NCHFA provides the rest of the match.
There is no match requirement imposed by the state.
HOPWA
There are neither federal nor state match requirements for this program.
Additional Funding Resources
The state was allocated funding under the following Congressional Acts for various agencies:
 Housing and Economic Recovery Act of 2008 (HERA)
 American Recovery and Reinvestment Act of 2009 (ARRA)
 2010 Wall Street Reform and Consumer Protection Act (Dodd-Frank)
Community Investment and Assistance
 Neighborhood Stabilization Program – The North Carolina Department of Commerce, Community Investment and Assistance (CI) was awarded $52.3 million and $5 million in Neighborhood Stabilization Program funds in the first round (NSP1) and third round (NSP3) of funding, respectively. The purpose of NSP funding is to stabilize neighborhoods whose viability has been, and continues to be, damaged by the economic effects of properties that have been foreclosed upon and abandoned. These targeted funds will be used to purchase foreclosed homes at a discount and to rehabilitate or redevelop them in order to respond to rising foreclosures and falling home values. NSP1 funds were originally authorized under Section 2301(b) of HERA, as amended, and an additional allocation of funds for NSP3 provided under Section 1497 of Dodd-Frank Act. CI awarded nineteen (19) grants under NSP1 and five (5) grants under NSP3.
 Community Development Block Grant – Recovery (CDBG-R) – The CDBG-R program was created to help communities and families that have experienced the brunt of the recent economic downturn. Resources will be used to stabilize and revive local neighborhoods and housing markets with heavy concentrations of foreclosed properties. Funds will also assist the vulnerable families and individuals who are on the brink of homelessness or have recently become homeless. CI was awarded $12.1 million in CDBG-R that were provided through ARRA. CDBG-R funds for small cities and other eligible local governments were awarded through a competitive process for “shovel ready” projects. CI awarded 27 projects under CDBG-R throughout the state.
North Carolina 2012 Annual Action Plan Page 13 November 15, 2011
North Carolina Housing Finance Agency
 Tax Credit Assistance Program (TCAP) - North Carolina received $52,152,687 from the Tax Credit Assistance Program (TCAP), which was included in the American Recovery and Reinvestment Act of 2009 (ARRA). TCAP provides funding for capital investment in Low-Income Housing Tax Credit properties. State housing finance agencies distributed these TCAP funds competitively and according to the Qualified Allocation Plan (QAP). Projects awarded Housing Credits in 2009 were eligible for funding, and priority was based on the Final TCAP criteria. Ten of the 2009 projects received TCAP awards. There are no administration funds associated with TCAP.
 The Exchange Program - Section 1602 of ARRA created the Exchange Program, through the Treasury Department, which allowed housing finance agencies to elect to receive cash in exchange for a certain portion of the state’s tax credit ceiling. Agencies used the funds to make sub-awards to finance the acquisition or construction of qualified properties, subject to the same requirements as the Low Income Housing Tax Credits program. NCHFA used this program for 2007 and 2008 projects and received approximately $135 million from Treasury.
 Homeless Prevention and Rapid Re-housing Program (HPRP) - The state of North Carolina received a direct allocation of $22 million for this program. The Office of Economic Recovery and Investment administers the program for the state with assistance from the Department of Health and Human Services and NCHFA. HPRP provides funds that can be used for temporary financial assistance, housing relocation, and housing stabilization services for persons who are homeless or at risk of homelessness. A total of $18 million will be used for program activity and $4 million for support services. The program began October 1, 2009 and is scheduled to end August 31, 2012. There are 20 service organizations that administer the program in 54 counties around the state.
MONITORING
The state will continue to monitor housing and community development activities of its subrecipients to ensure long term compliance with program requirements and comprehensive planning requirements. Program requirements include appropriate regulations and statutes of the programs involved, including steps being taken to review affordable housing activities, ensure timeliness of expenditures, and on-site inspections to determine compliance with applicable housing codes.
Each of the Consolidated Plan Partners has plans for monitoring and ensuring compliance in their own programs. These plans may include elements such as site-visits, file reviews, interviews with residents, and reviews for compliance with federal and state regulations (such as Davis-Bacon, Section 3, Fair Housing. Language Access, Equal Opportunity and Procurement, requirements). The monitoring plans vary by program and funding source. Consolidated Plan partners are subject to both federal regulations and established regulations as set forth in the State of North Carolina Administrative code. Although all various HUD programs are subject to various federal regulations and separate state regulations, there North Carolina 2012 Annual Action Plan Page 14 November 15, 2011
are some common monitoring requirements with the monitoring of the HUD programs. All partners as required certify the United States Department of Housing and Urban Development that each program will comply with all applicable laws and regulations.
All consolidated plan partners are prohibited by State administrative code from entering into a new grant agreement with any agency, local government, and or organization that has been identified by the State Office of Budget and Management on the State Do Not Fund List.
LEAD-BASED PAINT
Community Investment and Assistance
CI will continue to encourage local units of government to be involved with lead-based paint removal programs. Furthermore, CI will encourage local governments to work with agencies that are established primarily to mitigate lead-based paint conditions and provide for its removal, as well as address other environmental concerns.
North Carolina Housing Finance Agency
All HOME-funded programs will continue to be in compliance with U.S. Department of Housing and Urban Development lead regulations (24 CFR Part 35).
The Agency will continue to participate quarterly in an ad hoc lead hazards advisory group made up of concerned individuals from the public health, environmental protection, affordable housing, and occupational safety sectors.
Using Housing Trust Fund funding set-aside through the “Displacement Prevention Partnership Program”, the Agency will offer funding for lead referrals whose situation may be more appropriately handled through Department of Environment and Natural Resources’ (DENR’s) Preventative Maintenance Program. Funds are provided as grants to the homeowners to pay for cleanup and stabilization activities as prescribed by DENR’s regional lead specialists. “Households with a child under the age of six whose health is threatened by the presence of lead hazards” are also an eligible special needs category for SFRLP.
AIDS Care Unit
Project Sponsors are required to document that all clients receiving housing assistance are made aware of the danger of lead-based paint. Project Sponsors distribute a lead-based paint fact sheet to clients receiving HOPWA services.
North Carolina 2012 Annual Action Plan Page 15 November 15, 2011
STATEMENT OF SPECIFIC OBJECTIVES AND AFFORDABLE HOUSING
(Citation: 24CFR91.320(c) and (g))
One-Year Specific Housing Goals and Objectives
The three tables shown below highlight how the four core programs will continue to have an impact on the needs of the state. The tables provide the anticipated households assisted and funding amounts (in thousands of dollars) allocated for each activity type; need type; and priority category. In reviewing the tables, it is important to recognize that the state considered strategic investments of its limited resources through its programs, as well as the appropriateness of the resources available to address the priority need categories.
North Carolina 2012 Annual Action Plan Page 16 November 15, 2011
One-Year Affordable Housing Goals & Objectives Goals by Activity Type - §91.320(g)
Activity Type
Anticipated Households Assisted*
Anticipated Funding ($000s)
Rental Assistance
1,722
$1,850
Production of New Units
1,171
$16,496
Rehabilitation of Existing Units
381
$14,552
Acquisition of Existing Units
170
$1,952
Other Activities Not Specified Above
50,321
$22,612
Total
53,765
$57,462
Goals by Special Needs - §91.320(g)
Need Type
Anticipated Households Assisted*
Anticipated Funding ($000s)
Homeless
43,509
$2,855
Non-Homeless
5,201
$38,456
Special Needs
5,054
$16,151
Total
53,765
$57,462
Annual Objective by Priority - §91.320(c)(3) & §91.320(d)
Priority
Anticipated Households Assisted*
Anticipated Funding ($000s) High Priority
Homeless Families and Individuals
43,509
$2,855
Non-homeless Persons with Special Needs**
5,054
$17,593
Households between 0-30% AMI
312
$2,136 Medium Priority
Households between 31-60% AMI
3,069
$22,235 Lower Priority
Households between 61-80% AMI
1,820
$12,644
Total
53,765
$57,462
*’Households’ is defined as households, individuals or units assisted.
**'Special Needs' is defined as persons with disabilities, low-income elderly persons, and persons with HIV/AIDS. North Carolina 2012 Annual Action Plan Page 17 November 15, 2011
Outcome Measures
Uniform performance measures have been developed by HUD. The Consolidated Plan Partners have
chosen appropriate performance measures for their specific programs. The following are the
performance measures for North Carolina HUD-funded programs by Agency, category, objective, and
outcome.
Outcome -->
Availability/
Accessibility
Affordability Sustainability
Suitable Living Environment
Decent Housing
Creating Economic Opportunities
Objective -->
CDBG objectives and outcomes are specific to each program category. The category with corresponding
objective and outcome are provided here.
Categories Objective Outcome
Small Business & Entrepreneurial
Assistance
Creating Economic Opportunities Availability
NC Catalyst Program Create Suitable Living Environment Sustainability
Scattered Site Housing Providing Decent Housing Sustainability
Infrastructure Hook-Ups Creating Suitable Living Environment Sustainability
Infrastructure Creating Suitable Living Environment Sustainability
Economic Development Creating Economic Opportunities Availability
For all HOME-funded activity, the objective category is “decent affordable housing” and the outcome
category is “affordability”.
ESG objectives and outcomes are to ensure the provision of emergency and/or transitional housing,
essential services, and or/homeless prevention services.
The outcome and objective for the HOPWA Program is to provide decent, safe and affordable housing
for persons living with HIV/AIDS and their families.
Allocation Priorities
Funds will be made available through both competitive and open funding cycles. Funds will be allocated
statewide based on housing needs, as documented in the North Carolina Housing Market Analysis &
North Carolina 2012 Annual Action Plan Page 18 November 15, 2011
Needs Assessment in the 2011-2015 Strategic Consolidated Plan, as well as on the service-provision infrastructure in the state. See the “One-Year Affordable Housing Goals & Objectives” tables for the allocation priorities and proposed distribution of funds to address those needs.
Geographic Distribution - Each program has a unique method of geographic distribution. The funding for the Community Development Block Grant Program is directed to non-entitlement communities across the state. The program funding through the Emergency Solutions Grants Program, the HOME Program, and the HOPWA Program is distributed statewide. The HOPWA Program is directed to non-entitlement communities across the state.
Homeless and Other Special Needs
(Citation: 24CFR91.320(e))
The state addresses the needs of the homeless and other special needs persons through administration and funding of numerous programs. The state addresses emergency shelter and transitional housing needs of homeless individuals and families to prevent them from becoming homeless with the Emergency Solutions Grants Program (ESG), the Supportive Housing Development Program (funded in part with HOME), and the Key Program (funded in part with HOME Match) through the provision of grants and loans to develop and operate emergency, transitional or supportive housing and permanent housing. ESG also helps to combat chronic homelessness through the provision of preventive programs and activities. The state addresses the needs of those who are not homeless through the Supportive Housing Development Program (SHDP), Key Program, and Housing Opportunities for Persons with AIDS Program (HOPWA). SHDP helps partners develop permanent and transitional housing for persons with disabilities, Key provides operating subsidies for housing for persons with disabilities, and HOPWA provides tenant based rental assistance, short-term mortgage and utility assistance, housing information, supportive services and resource identification to persons with HIV/AIDS.
Barriers to Affordable Housing
The Analysis of Impediments to Fair Housing Choice, completed in 2010, summarizes barriers to affordable housing and is available to the public. The Housing Coordination and Partnership Council advises the Governor and General Assembly on barriers to affordable housing in North Carolina, and the Housing Partnership, the oversight board of the state’s Housing Trust Fund, considers barriers to housing in the allocation of state resources. In carrying out their regular programs and funding cycles, the Consolidated Plan Partners continue to promote the removal of barriers to affordable housing. The Consolidated Plan partners will take efforts to address those impediments through individual agency efforts as well as a collaborative effort as partners.
One Year Goals to Address Impediments to Fair Housing Choice Partners for 2011
Below is a table describing each agency specific activities that each agency will undertake to address the identified impediments in the 2011-2015 Analysis to impediments to Fair Housing Choice Study.
North Carolina 2012 Annual Action Plan Page 19 November 15, 2011
Impediment
Goal
Implementation
Agency Lead
Year Performed
#1
#1
Consolidated Plan Fair Housing Workshop
CI
2012
#1b
Developing a FHIP
CI
2012
#1c
Fair Housing Task Force
ESG/HOPWA
2012
#2
#2
Outreach and Education to rental housing providers/landlords
NCHFA/CI
2012
#3
#3
Constraints in lending markets
NCHFA
2012
#4
#4
Land Use Practices
CI
2012
#2
#2
Offer Fair Housing Workshop at state ESG Conference
ESG
2012
#2
#2
Disseminate via electronic mail information regarding fair housing and training opportunities
ESG
2012
Anti-Poverty Strategies
Community Investment and Assistance (CI)
CI believes that the true eradication of poverty means providing a holistic approach to community development. The CDBG eligible activities are designed within the framework that allows grantees to address housing, infrastructure, economic, human capital and all other community development needs. CI in concurrence with the Consolidated Plan partners also believes that eradication of poverty mean providing residents with tools to help themselves improve financial stability.
In addition, CI also believes in the importance of the prevention of poverty and will continue to operate the Individual Development Account category which provides down payment assistance, credit and housing counseling, financial literacy, and homeowner education to prospective first time homebuyers. By assisting low income residents to acquire wealth, the Division has programs in place that will help provide those residents a “step up” out of poverty as well as build wealth and skills so that residents can remove themselves from the debt cycle that plagues many low income families.
As a method to ensure that funds are directed to areas of high poverty across the state, many CBDG categories reserve their grant funds for Tier I and Tier 2 counties and state development loans. The Tier system is based on North Carolina Williams S. Lee Quality Jobs and Business Expansion Act, which divides counties into tiers based upon their relative economic development needs. Tier 1 and Tier 2 counties are seen as having a more dire need for economic and community development services. Grant categories such as Revitalization Strategies are set aside for those counties. State Development Zones are particular areas of counties or municipalities that through census and other quantitative data, demonstrate high levels of poverty and other characteristics of high levels of economic and community North Carolina 2012 Annual Action Plan Page 20 November 15, 2011
development need. Neighborhoods in the State Development Zone (but not in entitlement cities) are also entitled to the same preferences as Tier 1 & 2 counties.
North Carolina Housing Finance Agency
Many of the activities NCHFA plans to undertake or continue in the 2012 period are anti-poverty activities:
 Financing of supportive rental housing;
 Providing funding for qualified low, very low, and extremely low income home buyers through individual development accounts;
 Financing of transitional and permanent housing for homeless and disabled persons;
 Operating and promoting programs that prevent foreclosure;
 Providing rent assistant for homeless and/or disabled households through the Key Program; and
 Administering HUD rent assistance contracts for 24,000 privately owned apartments.
Office of Economic Opportunity
The Emergency Shelter Grants Program annually allocates approximately 2.5 million to local units of government and non-profit agencies. These funds are provided for operation expenses, supportive services, and prevention activities – all of which are anti-poverty activities that benefit low income persons.
AIDS Care Unit
The HOPWA program in concurrence with the Consolidated Plan partners also believes that eradication of poverty means providing residents with tools to help themselves improve financial stability. By providing HOPWA funding to facilitate the assurance of stable housing for persons living with HIV/AIDS (PLWHA), impacted individuals will be more likely to access medical care, which in turn will result in enhanced ability to access resources that will reduce the likelihood of poverty.
Public Housing Initiatives
The public housing authorities (PHA) are components in the statewide system for the delivery of affordable housing. Local housing authorities are established through the auspices of local government, subject to state enabling legislation. Neither the state nor CI specifically have direct oversight for local PHA, however we may partner with these entities through a grantee or project sponsor relationship to complete local projects or activities. CI does certify local plan’s or project’s consistency with the state program’s Consolidated Plan for PHAs with a troubled or standard performing assessment issued by HUD.
Low-Income Housing Tax Credits (LIHTCs)
The North Carolina Housing Finance Agency (NCHFA) administers the Low Income Housing Tax Credit (LIHTC) program in North Carolina. The LIHTC program produces and rehabilitates approximately 2,000 units of affordable rental housing units each year for low-income households. The distribution of this North Carolina 2012 Annual Action Plan Page 21 November 15, 2011
resource is governed by the state’s annual Qualified Allocation Plan (QAP). Under IRS Code Section 42 (m)(1)(B)(ii), QAPs must give preference to projects which:
 Serve the lowest income tenants,
 Are obligated to serve qualified tenants for the longest periods, and
 Are located in qualified census tracts and the development of which contributes to a concerted community revitalization plan.
The QAP is generally compatible with the goals of the Consolidated Plan because the LIHTC program produces multifamily housing units affordable to persons at or below 60% AMI. The North Carolina Department of Commerce – Community Investment and Assistance (CI) collaborates with NCHFA on some LIHTC projects by providing qualified projects with Community Development Block Grant funds.
PROGRAM REPORTS
Community Development Block Grant (CDBG) Program (91.320 k(1))
Administered by the North Carolina Department of Commerce, Community Investment and Assistance, the CDBG Program provides grants to non-entitlement local governments for projects that enhance the viability of communities by providing decent housing and suitable living environments and by expanding economic opportunities, principally for persons of low- and moderate-income.
North Carolina expects to receive approximately $45 million in CDBG funds. Of this amount, $39.3 million will be made available for the following housing-related programs: NC Catalyst, Scattered Site Housing, Infrastructure, Economic Development and Small Business & Entrepreneurial Assistance (SBEA). In addition, other funds may become available as a result of additional HUD allocations, recapture, reversion, or carry-over of prior year funds and program income. The state makes these funds available through grants to non-entitlement governments statewide.
North Carolina 2012 Annual Action Plan Page 22 November 15, 2011
Investment Plan – 2012 Distribution
Small Business and Entrepreneurial Assistance
$3,000,000
Scattered Site
$8,000,000
Infrastructure
$19,740,000
Economic Development
$7,210,000
NC Catalyst
$5,000,000
Capacity Building
$600,000
Administration
$1,000,000
Technical Assistance
$450,000
2012 HUD Grant to State
$45,000,000
Method of Distribution
The purpose of this section is to describe the method of distributing CDBG fund categories. CDBG projects will be awarded from several funding sources:
 New 2012 funds according to the investment plan above;
 Funds from earlier disbursements recaptured or de-obligated from prior Community Revitalization, Infrastructure, and Scattered Site, demonstration category grants, funds recaptured from Economic Development projects and funds not otherwise distributed from the above categories may be awarded to qualifying applications in NC Catalyst Program;
 Any Scattered Site funds not awarded may be awarded to qualifying applications in the NC Catalyst Program or as supplemental Scattered Site Housing funds to previous qualified applicants;
 Any non-revolving loan Economic Development funds from previous disbursements and Economic Development funds not awarded may be distributed to projects with qualifying applications in either NC Catalyst, Scattered Site, SBEA, or Capacity Building programs; and
 Program income received in prior years will be available for the Capacity Building category on an as available basis. Any unused program income may be awarded to qualifying applications in either in NC Catalyst or Infrastructure.
Threshold Requirements and Selection Criteria by Program Category
The grant size limits, threshold requirements, selection criteria, and selection process, when applicable, are summarized here for each CDBG program. A more detailed description of requirements and criteria is provided in the application guidelines for each CDBG program category.
Competitive categories usually prescribe selection criteria and selection processes for each program, whereas non-competitive categories prescribe specific review criteria.
All categories except Capacity Building, Small Business Entrepreneurial Assistance and Scattered Site Housing must meet some type of threshold requirements. All except the above exempt categories plus North Carolina 2012 Annual Action Plan Page 23 November 15, 2011
any demonstration projects may not receive awards or have applications under consideration for more than a total of $1,250,000 from a fiscal year’s allocation to the state.
Small Business & Entrepreneurial Assistance (SBEA) grants help develop a coordinated effort for assisting the existing small business/ entrepreneurial sector. SBEA projects will be selected on a competitive basis for a 24-30 month funding cycle. About twelve to twenty grants of $150,000 to $250,000 from the $3 million total funding will be awarded to the state’s most distressed local governments (i.e., applicants must be Tier 1 and/or 21st Century Communities). Application are rated and ranked using the selection criteria as follows. Further explanation is available in the application guidelines and on the website of CI.
Selection Criteria
Score
Appropriateness and Feasibility of Business Activities
300
Appropriateness of Plan for Creating an Entrepreneurial Environment
300
Local Commitment and Community Partnerships
200
Timely and Effective Public Participation
100
Grant Administration Capacity and Past Performance
100
Tier 1 and 21st Century Communities
50
Total Points
1000/1050
Scattered Site Housing (SSH) grants will be made to local county governments on a rotating basis to address housing needs of very low income families throughout the county. County governments can receive an average of $250,000 every 3 years with funds targeted to very low-income homeowners for rehabilitation or replacement purposes. Counties submit a detailed plan that includes all interested municipalities within the county describing how funds will be distributed to meet housing needs. Scattered Site Housing applicants may request that up to ten percent of funds be set aside for local option to undertake emergency repairs or repair/replace on-site well and/or septic systems.
Those counties that accomplish their goals and exhaust funds within two years are eligible to receive up to an additional $100,000 to continue activities allowed in the SSH category subject to funding availability.
Selection Criteria for Scattered Site Housing awards include: community need; community impact; project design; financial feasibility; distribution plan: and participation process.
An estimated total of $19.7 million will be available in the Infrastructure (IF) category per Special Provision language as directed by the N.C. General Assembly. Eligible local governments may obtain grants of up to $750,000 to provide new infrastructure (public water and/or public sewer) and to make improvements to water or sewer treatments plants that have specific problems such as being under moratoriums or special orders of consent. In an effort to address needs in 21st Centuries Communities, North Carolina 2012 Annual Action Plan Page 24 November 15, 2011
half of the total IF funds will be available to local governments in the 21st Century Communities on an open-ended basis. The other half of the funds will be available to all eligible local governments.
Applicants with one or more current grants in any category except economic development must meet financial or closeout requirements as specified in the grantee’s performance based contract and in the closeout schedule for each grant fiscal year. Problems with previous grants must be resolved.
Criteria for IF awards include: severity of needs; benefit to low and moderate income persons; local commitment; treatment of needs; and appropriateness and feasibility.
Capacity Building (CB) grants of up to $75,000 will be made available to local governments to assist established non-profit organizations with steady and reliable income streams develop appropriate and competitive CDBG projects and gain functional capacity in a new and different role. Funds are available on a first-come-first-serve basis with priority going to local governments from 21st Century Communities, Tier 1 Counties, and UP or AG Zones. A Capacity Building grant is expected to result in a future application in one of the CDBG categories.
Selection Criteria include previous CDBG experience, feasibility of the project to result in a future CDBG application, and financial feasibility of the non-profit to carry out the project and any future products. Capacity Building will be managed by the Office of Rural Development.
CI will give priority for funding to projects as listed below:
21st Century Communities Pool
Priority will be given first to water projects and second to projects that propose a regional solution providing all eligibility and benefit requirements are met. Identified 21st century communities map is attached in the appendix. 21st Century counties for round 6 include Cleveland, Jones, Pamlico and Stokes.
Regular Pool
Funding priorities will be given first to regional balance, second to water projects and third to projects that propose a regional solution providing all eligibility and benefit requirements are met. In addition, local governments will be required to display a high state of readiness in the application for IF funds. Projects should be ready to begin as soon as possible after receiving CDBG funds.
The Economic Development (ED) category will continue the policy of providing higher levels of funding to the most economically distressed areas of the state. The following considerations will be included for job creation and retention projects during the 2012 program year: 60% of the jobs created or retained in a project must benefit persons qualifying as prior low and moderate income (LMI). Funding for Economic Development projects is based on the number of jobs to be created or retained and the level of distress in the community applying for the funds. Areas with higher distress rankings, based on the North Carolina Tier rating system, are eligible for more funds per job created. North Carolina 2012 Annual Action Plan Page 25 November 15, 2011
CDBG funds are granted to local governments for various types of infrastructure improvements to assist business expansion or retention. A local funding match of at least one dollar for every three CDBG dollars is required except for the 25 most distressed counties as ranked for the Article 3J Tax Credits legislation. In a secondary priority to infrastructure projects and at the discretion of the Secretary of Commerce, direct financial assistance to private companies is available as loans to be negotiated by the local government applicant and a participating North Carolina commercial bank at a level not to exceed 50% of the bank loan. Repayment of the loan by the private company becomes program income to the state and is deposited into a CDBG economic development revolving loan fund (RLF). Funding from the RLF is available only as loans.
Loans for industrial shell buildings are available from the RLF based on the projected number of jobs to be created and the level of distress in the community. These loans will be at a 2% interest rate with a maximum term of 5 years. Principle payments are deferred for the first two years of the loan. A dollar for dollar match is required by the local government applicant for an industrial shell building. Also, up to $500,000 will be set aside in the RLF for counties in Tiers 1-3 as loans to assist with the costs associated with certifying industrial sites. These loans are repaid after the certified site is sold or within five years of award.
Funds are granted to local governments that propose a project in conjunction with a private for profit business that proposes to restore a vacant building to economic use resulting in the creation or retention of permanent, full-time jobs by the project company. To be eligible, documentation must be provided showing the building has been vacant thirty (30) consecutive days or more. CDBG funds for this category are limited to a maximum of $750,000 per unit of government per program year. The grant amount is calculated based on $20,000 per job for 3J Tax Credit eligible businesses (see chart) and $12,000 per job for businesses not eligible for tax credits. CDBG funds provided to the company by the local unit of government will be in the form of a forgiven loan. The loan has a term of five years with no principal or interest payments. If the project company retains the jobs pledged in the loan agreement for the five year term, the entire amount is forgiven.
Certain threshold requirements apply, including: $1.25 million cap for the yearly funding cycle; expenditure levels of open grants; and proper closeout of previous grants.
The NC Catalyst Program is a new program that consolidates program activities from several existing programs such as Community Revitalization, Housing Development, Individual Development Accounts, and Capacity Building. The NC Catalyst Program will also incorporate de-obligated funds to further address more focused/critical unmet needs. Examples include, but are not limited to, addressing severe water-related needs; targeting very low-income households, special populations such as the elderly and disabled; increasing economic opportunities; responding to severe economic crisis; and focusing on sustainable communities efforts.
North Carolina 2012 Annual Action Plan Page 26 November 15, 2011
Technical Assistance
Technical Assistance (TA) funds are used to develop the professional skills and capabilities of local community development grant administrators. Each year, DCA and the University of North Carolina at Chapel Hill’s Institute of Government present a 5-day Community Development Academy for grant administrators. Participants that complete the course and pass an exam receive a certificate of completion, indicating knowledge of community development topics. In addition, funds are used to hold a variety of workshops and seminars throughout the year, taught by DCA staff and others.
HOME Investment Partners (HOME) Program (91.320 k(2))
Administered by the North Carolina Housing Finance Agency, the HOME Program will provide financing to nonprofit housing organizations, for-profit developers, lead regional organizations and local governments to increase the availability of standard, affordable housing in North Carolina.
i. In addition to administering the $20 million allocation of HOME, NC Housing Finance Agency also administers the state’s Housing Trust Fund, Low Income Housing Tax Credits, State Tax Credits, Home Protection Program, Mortgage Credit Certificates and Mortgage Revenue Bonds. NCHFA also administers the National Foreclosure Mitigation Counseling Grant, the Neighborhood Stabilization Program, Housing for Hardest Hit funds, Homeless Prevention and Rapid Re-housing Program and two programs funded through the American Recovery and Reinvestment Act: Tax Credit Assistance Program and the Exchange Program.
ii. Resale/Recapture Provisions
Housing rehabilitation loans under the Single Family Rehabilitation Program will be provided as deferred and forgivable, forgiven at $3,000 per year over the life of the loan.
Home buyer loan subsidies available under the New Homes Loan Pool, IDA Loan Pool and Downpayment Assistance Program will be provided as subordinate deferred-payment loans that are not forgiven. Home buyer loans under the Self-Help Loan Pool will be provided as principal-only amortizing loans. Loans under all home buyer programs will be due and payable (1) when the property is sold, (2) when the property is no longer the home buyer's principal residence, (3) at the end of the loan term, or (4) when the first mortgage is refinanced. If the net proceeds of the sale of the property are insufficient to repay the home buyer loans in full, the Agency will accept its pro rata share of the net proceeds in full satisfaction of the loan.
iii. HOME funds are not used for refinancing of existing debt, even in developments rehabilitated with HOME funds.
North Carolina 2012 Annual Action Plan Page 27 November 15, 2011
iv. ADDI Program
At this time, the Agency does not expect to receive an ADDI allocation for the period of the 2012 Action Plan.
v. Additional information not required by 24 CFR 91
Consortia
The North Carolina Housing Finance Agency will not approve additional HOME Consortia, if doing so will result in a net loss of HOME funds to the state.
Tenant Based Rental Assistance
Starting in 2002, NCHFA partnered with the NC Department of Health and Human Services (DHHS) to facilitate the inclusion of persons with disabilities and the homeless within LIHTC properties. As part of this partnership, LIHTC applicants commit to targeting 10% of the units in their developments to persons with disabilities. To support this commitment, developers partner with local lead agencies in the preparation and implementation of Targeting Plans. These plans outline how the property will work with the agencies to make these units available.
In order to make the targeted units affordable, NCHFA and DHHS expanded their partnership in 2004 to create the Key Program. This program provides a bridge subsidy for households on disability income who have not yet received a Section 8 Housing Choice Voucher. Through this award-winning program, the Agency is able to assist in providing stable and affordable housing for these high priority populations. This program will continue to be funded in part by HOME Match funds in 2012.
Affirmative Marketing
The state has adopted procedures consistent with the requirements of affirmative marketing under 24 CFR Part 92.351(a) and (b). Recipients and subrecipients of HOME funding must certify that they have developed and adopted affirmative marketing procedures for HOME-assisted housing containing five or more units. In both rental and home ownership situations, the Agency works to address impediments to administering the HOME Program. In addition, the Agency reviews marketing plans as part of its application review process and provides training to rental property managers on a regular basis.
Minority Outreach
NCHFA has conducted outreach to both recipients of HOME awards and businesses contracted by those recipients. Language encouraging the use of minority- and women-owned businesses is included in either the commitment letter or program guidelines of HOME-funded programs involving contractors. Further, the NC Office for Historically Underutilized Businesses maintains a website of minority- and women-owned businesses, services, and suppliers, and provides comprehensive and continuing assistance to support them. The Agency encouraged HOME recipients in construction programs to utilize the Department of Administration’s online search North Carolina 2012 Annual Action Plan Page 28 November 15, 2011
tool to find contractors. In addition, the Agency contacted the contractors and subcontractors of which it is aware and encouraged them to list their businesses on this search tool.
Emergency Solutions Grants (ESG) Program (91.320 k(3))
North Carolina’s process for distributing ESG funding is currently non-competitive. Pre-applications for funding are distributed to previous ESG contractors, county managers, community action agencies, and other interested agencies, organizations, and individuals in December of 2011.
Pre-applications are used to determine an applicant’s eligibility for ESG funding according to set criteria. An eligible applicant must:
 Document its process for verifying that clients served meet the HUD definition of “homeless”
 Operate the emergency and/or transitional shelter facility for which funding is requested for at least one year prior to the date of application (for the purposes of this program, the term “shelter” excludes substance abuse rehabilitation centers (10A NCAC 97F) ;
 Operate the emergency and/or transitional shelter facility for which funding is requested for at least one year prior to the date of application;
 Operate the emergency and/or transitional facility for which funds are requested for a minimum of six full months out of the year;
 Operate a safe and sanitary facility (if a shelter is a 24 hour or night only facility which:
- if a 24 hour or Night Only facility, has an average daily occupancy (ADO) of at least six homeless persons nightly; or
- if a Day Only facility, has an APSD (average number of person served daily) of at least 30 persons per day; and provides one or more of the essential services defined by the U.S. Department of Housing and Urban Development.
 Have an established accounting system that provides for maintenance of ESG funds in accordance with OMB Circulars A-110 and A-122;
 Have at least one person on the board of directors that is homeless or formally homeless; and
 Have the ability to expend ESG funds budgeted for Operations and/or Services within 365 days and ESG funds budgeted for Homeless Prevention within 180 days;
 Have acceptable resources to match the ESG funding received;
 Involve to the maximum extent possible homeless person in maintaining and operating facilities assisted under the ESG Program; and
 In the case of private, non-profit organization, have the endorsement of the unit of local government in the community in which the emergency or transitional shelter is located.
Program staff review Pre-applications in February of 2012 and notify potential contractors to submit an application in March 2012. The ESG program does not fund substance abuse shelters. In addition all funding and definitions outlined in both the application and the North Carolina Administrative rules for North Carolina 2012 Annual Action Plan Page 29 November 15, 2011
ESG will be followed. Once applications are approved and the agreement between the NC Department of Health and Human Services and the US Department of Housing and Urban Development is in place, contracts are executed.
Program Evaluation and Monitoring
All FY 2012 ESG contractors will be subject to on-going monitoring throughout the term of the grant. The primary methods of monitoring will include:
 Review of mid-year and end of year contractor performance reports
 Review of contractor monthly financial status reports
 Review of monthly Average Daily Occupancy (ADO) and Unduplicated Occupancy
 Periodic on-site monitoring, including review of randomly selected case files; and
 On-going telephone contact with contractor staff.
Housing Opportunities for People with AIDS (HOPWA) Program (91.320 k(4))
The HOPWA program is administered by the AIDS Care Unit in the Division of Public Health, North Carolina Department of Health and Human Services. HOPWA funds housing and housing-related supportive services for low-income persons with HIV/AIDS and their families. The HOPWA allocation is based upon the number of reported AIDS cases. Eligible HOPWA activities include:
 Short Term Rent, Mortgage and Utility Assistance
 Tenant Based Rental Assistance
 Operating Costs for facilities dedicated to housing persons living with HIV/AIDS
 Supportive Services
 Housing Information
 Resource Identification
 Administration
All HOPWA Sponsors are required to provide Tenant Based Rental Assistance and Short-Term Rent, Mortgage and Utility Assistance. The other eligible activities are optional, based on regional need and resources.
For 2012, funds were awarded based on a review of continuation HOPWA Sponsor budgets. The AIDS Care Unit reviewed the proposed HOPWA plans from Networks of Care Sponsors to fund and support eligible HOPWA activities under HUD’s 24 Code of Federal Regulations Part 574. The eligible activities reflect the critical issues addressed in the 2009 Ryan White Part B Statewide Coordinated Statement of Need and Comprehensive Plan and are consistent with 2010 needs assessment conducted by the regional Networks The availability of resources to fund programs for each eligible activity was also considered. This funding represents portions of the 2nd and 3rd years of a three year funding cycle based on the 2010 competitive allocation process. North Carolina 2012 Annual Action Plan Page 30 November 15, 2011
The following overarching expectations apply to all HOPWA funded applicants:
1. Funds should support both urban and rural areas within the 88 counties served by the state HOPWA Program.
2. HOPWA-funded programs should be client centered.
3. Networks of Care must develop protocols to ensure confidentiality.
4. Networks of Care must indicate their willingness to actively collaborate with community-based organizations, AIDS service organizations and other community organizations and agencies to establish a referral network.
5. Networks of Care must ensure that clients receiving HOPWA funds have access to a case manager.
6. Networks of Care must ensure that clients receiving HOPWA funds have a housing care plan.
7. Networks of Care must demonstrate their ability to meet HUD and local housing quality standards relating to habitability and access.
8. Networks of Care must have the financial and programmatic capabilities to manage a housing program per federal and state regulations, policy and guidance.
9. Networks of Care must serve clients at or below 80% of median family income level.
The AIDS Care Unit is required by the Division of Public Health to monitor the programmatic and fiscal responsibilities of all Sponsors contracted to provide HOPWA services.
The AIDS Care Unit will conduct ongoing review of Sponsor’s HOPWA budgets, budget justification narratives, service delivery plans, experience in providing HOPWA service, etc.
The AIDS Care Unit will review monthly detailed expenditure reports along with back up documentation submitted by the Sponsors. Additional performance monitoring includes review of quarterly programmatic reports submitted by each Network, and at minimum two site visits conducted to review fiscal, programmatic and client records. Performance monitoring is documented for each funded Network of Care in writing and maintained in an agency file.
Based on the contractual agreement, the scope of work for each Network of Care’s contract outlines the performance monitoring measures for HOPWA services. This includes the following:
 Submission of monthly detailed expenditure reports with back-up documentation, and quarterly reports to the AIDS Care Unit detailing qualitative and quantitative activities.
 Attendance at mandatory meetings sponsored by the AIDS Care Unit.
 Submission of the Consolidated Annual Performance and Evaluation Report (CAPER) to include Demographic Charts. This information must be submitted to the HOPWA Administrator as part of the state’s HOPWA Integrated Disbursement Information System (IDIS) reporting requirements.
 Preparation for on-site visits at minimum twice during each contract period.
North Carolina 2012 Annual Action Plan Page 31 November 15, 2011
PUBLIC PARTICIPATION
Public Hearing Meeting Minutes for the Public Hearing on the
2012 NC Annual Action Plan
November 1, 2011
On November 1, 2011, Community Development Division-Community Investment and Assistance held a Public Hearing at the Raleigh Convention Center in Raleigh, North Carolina, to receive comments associated with the North Carolina Consolidated Annual Action Plan for 2012.
Public Hearing Opened at 8:01 AM
Iris Payne, Community Investment and Assistance, Program and Compliance Section Chief, facilitated the Public Hearing.
Attendees included: Shea Berry Budy, Northeastern CDC; Diane Evans, North Carolina Housing Foundation; Wendy Hutchins, North Carolina Housing Foundation; Garry L. Merritt, North Carolina Housing Foundation; Michael Leach, North Carolina Office of Economic Opportunity; Michael McLaurin, Town of Waxhaw; Paul Kennedy, Carolina Bank; John Nichols, North Carolina Housing Foundation; Jack Holtzman, Fair Housing Project Legal Aid of North Carolina; Carolyn Anderson, North Eastern CDC; Chris Estes, North Carolina Coalition; Scott Dedman, Mountain Housing Coalition; Sylvia Ray, CEED; Richard Fuqua, Community Investment and Assistance; Deborah McCrae, Community Investment and Assistance; Iris Payne, Community Investment and Assistance; Nancy Bloebaum, North Carolina Housing Finance Agency; and Mary Ann Chap, Division of Health and Human Services.
Iris Payne - discussed the purpose of the Public Hearing: The 2012 Consolidated Annual Action plan of the State of North Carolina serves as the annual application for the four North Carolina Agencies, each of whom receives a formula grant from the United States Department of Housing and Urban Development (HUD).
The four agencies are:
 North Carolina Department of Commerce, Community Investment and Assistance
 North Carolina Housing Finance Agency
 North Carolina Department of Health and Human Services, Office of Economic Opportunity
 North Carolina Department of Health and Human Services, AIDS Care Unit.
The agency goals are:
 Provision of decent and affordable housing;
 Provision of a suitable living environment; and
 Expansion of economic opportunity North Carolina 2012 Annual Action Plan Page 32 November 15, 2011
Purpose of the Public Hearing
 For the state to pursue a consolidated planning process that addresses the major housing and community development needs affecting North Carolina communities, to determine priorities for addressing those needs, and lay out a strategy for using the resources available.
 To pursuant the provisions of 24 CFR, Housing and Urban Development, Part 91, Purpose, the State develops and submits a consolidated annual plan from which HUD will evaluate the State’s progress.
 The State will conduct at least one hearing on the performance report as required by the North Carolina Citizen Participation Plan.
Iris Payne discussed the 2012 CDBG Grant Categories:
 Scattered Site Housing
 Infrastructure
 Economic Development
 Small Business and Entrepreneurial Assistance
 Capacity Building/Talent Enhancement Demonstration
 North Carolina Catalyst
CDBG Distribution of Funding
 $45 million was committed to the State of North Carolina CDBG program.
 $3 million was allocated statewide for eligible activities that support job creation and stimulation.
 $32.7 million was allocated for statewide direct housing purposes.
 $9.3 million was designated for capacity building economic development, infrastructure, administrative support, and other non-housing related activities.
Ben Strickland discussed the North Carolina Housing Finance Agency Action Plan:
 NCHFA will receive $20 million in HOME in 2012 and approximately $1.6 million in state appropriated HOME match funds.
 NCHFA plans to assist 1,155 households with HOME funds in 2012.
 NCHFA will use HOME in the following activities in 2012:
 Homebuyer assistance
 Supportive housing
 Rental housing preservation
 Owner-occupied rehabilitation
 Rental production
NCHFA Distribution of Funding
 Homebuyer assistance-44% of units placed in service in 2012 or 506 households.
 Rental unit production and rehabilitation-42% of units or 489 households.
 Owner-occupied rehabilitation-13% of units or 149 households.
 Supportive housing-1% of units or 11 households. North Carolina 2012 Annual Action Plan Page 33 November 15, 2011
NCHFA Priorities Served
 NCHFA used HOME funds to serve the 2011-2015 Consolidated Plan priorities.
 22.7% of the units placed in service in 2012 will assist high priority populations.
 47.1% of the units will assist medium priority populations
 30.1% of the units will assist low priority populations.
Michael Leach discussed the Emergency Shelter Grant Program
 The program helps local government and non-profits support emergency and transitional housing for the homeless.
 The program was allocated $2,579,547 in FY 2012.
 95% of ESG funds will be made available to grantees ($2,450,570)
 5% of ESG funds was made available of administration ($128,977)
ESG Proposed Impact
 30,036 single adults
 491 single children
 4,236 homeless families comprised of 4,773 adults and 8,206 children=12,979
 43,506 homeless persons served
Mary Ann Chap discussed the HOPWA Program
 The primary goal of the HOPWA Program is to provide housing and housing-related services to persons/families living with HIV infection in the 88 North Carolina counties covered by the State HOPWA Program.
 The State HOPWA grant is administered by the North Carolina Department of Health and Human Services, AIDS Care Unit.
 HOPWA 2012 Expected Allocation is $2,397,730
 97% will be awarded to 11 project sponsors across the state to serve 2,700 + households.
 3% will be set aside for grantee administration
HOPWA will provide the following services in 2012:
 Tenant-Based Rental Assistance-350 Households ($1,418,423)
 Short-Term Rent, Mortgage and Utility Assistance-1,370 households ($431,183)
 Supportive Services-713 individuals ($71,006)
 Operating Costs For Dedicated Facilities-55 residents ($216,034)
 Identification of Housing Resources and Provision of Housing Information to individuals/families and service providers-272 households ($85,079)
 Project Sponsor Administration (maximum 7% of HOPWA Allocation, $100,859)
North Carolina 2012 Annual Action Plan Page 34 November 15, 2011
Comments made on the Consolidated Annual Action Plan:
Jack Holtzman, Project Director, Fair Housing Project Legal Aid of NC
It is proposed that the State’s draft Annual Action Plan for 2012 (“the draft Plan”) take more specific and aggressive steps to address the impediments to fair housing choice noted in the State’s most recent Analysis of Impediments. Good work has been carried out in the past, but much more needs to be done in 2012.
The 2010 Consolidated Annual Performance and Evaluation Report (CAPER) summarizes the State’s accomplishments for the previous year, and how HUD funds were used by the State’s program partners. According to CAPER, pp. 15-20, it appears that the main (and possibly only) fair housing action taken by some State agencies themselves was to require their grantees to conduct fair housing education and outreach (E/O) activities.
The CAPER review noted that such E/O activities consisted mainly of the distribution of pamphlets and newspaper advertisements, and concluded, that such efforts, “while valid activities, dominate the public outreach and education processes for grantees to affirmatively further fair housing.” NCHFA should be commended for itself distributing brochures and providing fair housing training, as well as requiring fund recipients to develop Affirmative Fair Housing Marketing Plans, together with other training efforts and distribution of other related brochures.
The goals and steps noted in the implementation table on p. 18 of the draft Plan do not adequately address the various impediments to fair housing that exist in North Carolina. Specifically, the Consolidated Plan Partners are encouraged to take the following additional actions in furtherance of fair housing in 2012:
1) Provide additional fair housing training opportunities for their own staff (and officials) as well as subgrantees, and document the agenda and attendees at each such training.
2) In any scored application process for subgrantees, positive “points” should be provided to those entities that have documented participation during the prior funding cycle in such fair housing trainings, with negative “points” included in the scoring process as well for any failure to participate in such fair housing training, as well as any administrative or judicial finding of “cause” that a fair housing violation has occurred.
3) Require subgrantees to list, as part of any 2012 application process, the meaningful fair housing activities they have each conducted and/or participated in during the prior funding cycle, as well as whether or not they have been a respondent or defendant in any administrative or judicial fair housing action.
North Carolina 2012 Annual Action Plan Page 35 November 15, 2011
4) Contract with fair housing testers to assist in targeted fair housing enforcement in rental and lending markets in North Carolina. Two FHIP’s (the Fair Housing Project of Legal Aid of NC, and the Community Reinvestment Assn of NC) already exist. The award of HUD funding in 2011 for the Fair Housing Project occurred in part thanks to the support of the Department of Commerce. The two already existing FHIPS will be conducting both educational and enforcement activities in 2012. Goal #1b of the draft Plan (“Developing a FHIP”) should therefore be replaced with providing material support for the use of fair housing testers in the rental and lending markets. This is in accord with the State’s 2011-2015 Consolidated Plan’s planned response over the next five years, pp. 25-27, to address fair housing barriers and impediments.
Conclusion
The draft 2012 Action Plan should establish more specific efforts to be taken to overcome the effects of impediments to fair housing choice within the State.
More fair housing training and targeted testing should be supported and promoted by the State. In addition, both incentives (adding positive scoring factors for participation in fair housing training related activities) and negative consequences (including negative scoring factors in funding applications regarding instances where a subgrantee has failed to participate in any fair housing training or is found in any administrative or judicial action to have violated fair housing laws) should be included in the scoring process for awarding HUD funds to subgrantees.
RESPONSE :
“Thank you for your comments. We will consider incorporating and/or implementing them based on guidance from HUD as well as General Assembly regulations and guidelines. A formal response will be forwarded to you within thirty (30) days of the date you submitted your comments.”
Scott Dedman, Executive Director, Mountain Housing Opportunities
He proposed to the North Carolina Department of Commerce, Community Investment and Assistance:
 That any and all Community Development Block Grant (CDBG) funds currently available for comprehensive housing rehabilitation by North Carolina counties be made available for Emergency Home Repair, at the option of each County.
 That Counties be allowed to proceed without pre-qualifying residents before funds are released; provided, of course, that all federal CDBG laws and regulations will be followed.
Features of the Emergency Home Repair (EHR) model:
 Helps 5-10 times as many households and helps them faster. Improves Spend Rate for CDBG funds. Use $200,000 in one year to help 30-60 homeowner households, rather than $400,000 over three years to help 6-8 homeowner households. North Carolina 2012 Annual Action Plan Page 36 November 15, 2011
 Follows current NC Consolidated Plan, which gives high priority to Urgent Repairs for Very Low Income households.
 A proven model-Mountain Housing Opportunities now provides over 150 Emergency Home Repairs per year in Asheville and Buncombe County (over 3,000 since 1988).
 Meets all CDBG regulations-For Example, procurement with MHO’s Unit Bid system.
 Targets funds to imminent safety threats, saving homes and lives.
 Preserves the tax base by saving existing homes and keeping them occupied.
 Reduces cost to government by keeping elderly and disabled homeowners safe in their homes, rather than being displaced into institutionalized care.
 Fewer complaints to county and state government. Homeowner expectations are narrowed to 1-3 unsafe home systems repaired.
 Removes barriers to service-Eliminates pre-qualifying clients in groups; qualifies individual homeowners at time of need.
 Preserves local county option-Counties may still opt to use part or all of funds for comprehensive rehabilitation of homes.
 Creates jobs-MHO’s 150 Emergency Home Repairs per year provides income for over 50 people working in contract and subcontract trades in Buncombe County.
 Provides a model program for other counties-MHO is willing and available to consult with North Carolina and other counties regarding our Emergency Home Repair model.
RESPONSE:
“Thank you for your comments. We will consider incorporating and/or implementing them based on guidance from HUD as well as General Assembly regulations and guidelines. A formal response will be forwarded to you within thirty (30) days of the date you submitted your comments.”
Public Hearing closed at 8:30 AM
North Carolina 2012 Annual Action Plan Page 37 November 15, 2011
NOTICE OF PUBLIC HEARING
AGENCIES: North Carolina Department of Commerce, Community Investment and Assistance
North Carolina Housing Finance Agency (NCHFA)
North Carolina Department of Health and Human Services, Office of Economic Opportunity
North Carolina Department of Health and Human Services, AIDS Care Unit
ACTION: Notice is hereby given that the 2012 Consolidated Annual Action Plan for housing and community development programs will be published October 7, 2011 and available for public review and comment.
SUMMARY: The N.C. Consolidated Plan addresses housing and community development needs across the state and sets priorities for meeting those needs. The 2012 Consolidated Annual Action Plan details the state’s plans for housing and community development programs and spending for 2012. The state’s Consolidated Annual Action Plan includes the following programs funded by the U.S. Department of Housing and Urban Development (HUD): Small Cities Community Development Block Grant program (CDBG), HOME Investment Partnership (HOME), Emergency Shelter Grants (ESG) and Housing Opportunities for Persons with AIDS (HOPWA).
AVAILABILITY OF REVIEW MATERIALS: Copies of the 2012 Consolidated Annual Action Plan outline will be available on the web sites of the North Carolina Department of Commerce (www.nccommerce.com) and the North Carolina Housing Finance Agency (www.nchfa.com). Copies are also available by request from the North Carolina Department of Commerce, Community Investment and Assistance and will be distributed to all of the regional offices; contact Iris Payne at (919) 571-4900 to receive a copy.
PUBLIC HEARING: A public hearing will be held on November 1, 2011 at 8:00 a.m. – 9:00 a.m. at the Raleigh Convention Center, 500 South Salisbury Street, Raleigh, North Carolina, 27601. Persons wanting additional information on the public hearing may contact Iris Payne by phone at (919) 571-4900 ext 249 or via email at ipayne@nccommerce.com. Persons with disabilities or who otherwise need assistance should contact Ella Limehouse at (919) 571-4900 in advance of the hearing. Accommodations will be made for all who request assistance with participating in the public hearing by Thursday, September 29, 2011.
COMMENT PERIOD: Comments concerning the 2012 Consolidated Annual Action Plans may be made at the public hearing. Written comments will be accepted until 5:00 p.m. Tuesday, November 8, 2011, and may be made via email (ipayne@nccommerce.com), fax (919) 571-4900, or mailed to Iris Payne, Community Investment and Assistance, 4313 Mail Service Center, Raleigh, NC 27699-4313. North Carolina 2012 Annual Action Plan Page 38 November 15, 2011
North Carolina 2012 Annual Action Plan Page 39 November 15, 2011
Copy of Posting in The Carolinian
North Carolina 2012 Annual Action Plan Page 40 November 15, 2011
North Carolina 2012 Annual Action Plan Page 41 November 15, 2011
Public Hearing
North Carolina Consolidated Annual Action Plan for 2012
November 1, 2011
8:00a – 9:00a
Agenda
Opening Comments and Introductions Iris Payne
Community Investment and Assistance
Purpose of this Public Hearing Iris Payne
Summary of State CDBG Program Iris Payne
Summary of HOME Program Ben Strickling
N.C. Housing Finance Agency
Summary of ESG Program Michael Leach
N.C. Office of Economic Opportunity
Summary of State HOPWA Program Mary Ann Chap
N.C. Department of Health and Human Services
Opening of Public Comment Period Iris Payne
Closing of Public Comment Period Iris Payne
Other Ways to Make Public Comments Iris Payne
Concluding Comments Iris Payne
North Carolina 2012 Annual Action Plan Page 42 November 15, 2011
Other Public Comments Submitted
Harold Hunter, Community Service Network, Inc.
Please consider under HOPWA: Assistant with Deposits, application fees, credit and background checks, to help homeless individuals to obtain housing and Utilities. Many cases and the individual do not have this available in order to obtain housing.
Please consider: Time Limits to individuals on the Tenant Based Rental Assistance – eliminate application waiting lists; help more people. Time Limits of Three (3) years on the program.
RESPONSE: (by Mary Ann Chap, Department of Health and Human Services):
Mr. Hunter,
Thank you very much for sharing your comments. The State HOPWA Program acknowledges the challenges related to locating resources to provide assistance with deposits, application fees and credit/background checks as well as the limits on the resources available for tenant-based rental assistance. The HOPWA program will research these questions and discuss possible resources and options with HOPWA Sponsors across the State.
William A. McNeil, AICP, Program Consultant, Piedmont Triad Regional Council
Paul Kron, ASLA, ACIP, Regional Planning Director, Piedmont Triad Regional Council
Rebecca Kassner, Housing Program Director, Piedmont Triad Regional Council
Dear Ms. Payne:
Thank you for accepting and considering these comments on the 2012 Annual Action Plan. They are written from our experience with housing, community development and planning programs in the Piedmont Triad region and our involvement in the Piedmont Triad Sustainable Communities Project.
Last year, those of us working to make our communities and regions more vibrant, equitable and sustainable were encouraged by pledges in the state’s Consolidated Plan for 2011-2015 to incorporate HUD’s Livability Principles into every HUD-funded program. We were further encouraged when the Commerce Department set a tangible example with a downpayment on this pledge, allocating 2011 CDBG funds to the North Carolina Tomorrow program. With this as a backdrop, we offer the following comments concerning the 2012 Annual Action Plan:
1. Looking first at the CDBG program, the NC Catalyst program contains the only explicit mention of how funding will support sustainable communities. This is a good step, but the department should show how every funding category squares with the Livability Principles in practice. Without a deliberate examination, some categories may even contribute to sprawl.
2. As it is described, the NC Catalyst program sounds very broad, allowing for a wide range of activities, including, among others, ‘sustainable communities efforts’. While this flexibility will North Carolina 2012 Annual Action Plan Page 43 November 15, 2011
appeal to many potential applicants, I ask you to provide a set-aside for a specific sustainable communities effort, focusing on attracting investment in housing and mixed-use ventures in redevelopment areas. Giving priority to proposals that demonstrate how they will advance sustainability could be an alternative, but a set-aside would be far better.
3. Our Piedmont Triad region has numerous small towns that have low and moderate income areas that are ripe for redevelopment. Many of them have abandoned mills and plants which present potential investment opportunities for reuse, and adjacent residential areas in need of reinvestment. The larger cities in the region have used HUD’s Neighborhood Revitalization Strategy Area designation in their Consolidated Plans. The Commerce Department should allow smaller towns a similar opportunity by adding Community Revitalization Strategy Areas to the CDBG toolkit. If necessary, you could test the concept in regions like ours with HUD Sustainable Communities planning efforts under way.
4. Commerce and NCHFA programs and funds should explicitly target downtown areas and nearby neighborhoods for infill housing and job-creating investment. If carefully designed, this would reinforce existing communities, support infill, and provide people with job and housing choices close to services.
5. CDBG funds should help communities leverage other resources, specifically Low Income Housing Tax Credits through NCHFA, Historic Mill Tax Credits and New Market Tax Credits. NC Catalyst and other programs can help attract other funds, especially important now as federal and state budgets are being cut. This is best done in towns that have strategies for revitalizing their downtowns and their economies, i.e. through the Main Street Program, Small Town Main Street Program and the Rural Center’s STEP program. As an example, NC Catalyst funds could be used for high-impact, eligible proposals from communities that apply for the Main Street Solutions program. NC Catalyst funds can make Low Income Housing Tax Credit projects more competitive and viable, along with locally funded improvements in target areas.
If you would like to talk with us about these ideas, please contact us at (336) 294-4950. Looking beyond the 2012 Action Plan, our colleagues in the Piedmont Triad and other regions engaged in Sustainable Communities planning efforts would welcome an opportunity to discuss these and other concepts as you prepare plans for future years.
RESPONSE:
“Thank you for your comments. We will consider incorporating and/or implementing them based on guidance from HUD as well as General Assembly regulations and guidelines. A formal response will be forwarded to you within thirty (30) days of the date you submitted your comments.”
North Carolina 2012 Annual Action Plan Page 44 November 15, 2011
Joseph Furman, AICP; Director, Watauga County
The Board of Commissioners of Watauga County adopted the attached resolution regarding funding for the CDBG Scattered Site Housing Program at their November 1, 2011 meeting. This has been a good and effective program for Watauga County; a 37.5% reduction in funding would severely hamper the program. If you need further information, please contact me. Thank you for your consideration.
North Carolina 2012 Annual Action Plan Page 45 November 15, 2011
North Carolina 2012 Annual Action Plan Page 46 November 15, 2011
RESPONSE:
Mr. Furman,
Thank you so much for your comments on the 2012 Consolidated Annual Action Plan. The allocation of CDBG funds was established by the General Assembly in its most recent session, including the $8,000,000 allocation to the Scattered Site Housing Program. Because of this, the total grant limits of each of our programs are based on these annual allocations.
Thank you, once again, and we look forward to our continuing relationship with you and Avery County.
Patricia Crissman, AICP, RLA; Director of Planning Department, The Wooten Company
Iris,
I am finally reading through the 2012 Action Plan. Just a couple of notes/comments:
You refer to the NSP and CDBG-R programs - is that because they are continuing into 2012/not yet closed out?
You also have a reference to the RS program which was closed several years ago?
Also noticed the use of both DCA and CI in the plan.
I know this was a huge undertaking for you. And I'm sure you're glad to be to this point!
See you in Greensboro.
RESPONSE:
“Thank you for your comments. We will consider incorporating and/or implementing them based on guidance from HUD as well as General Assembly regulations and guidelines (as appropriate). A formal response will be forwarded to you within thirty (30) days of the date you submitted your comments.”
North Carolina 2012 Annual Action Plan Page 47 November 15, 2011
TRANSLATIONS OF THIS DOCUMENT
This information is available in Spanish or any other language upon request. Please contact
Marcela Vargas at (919) 571-4900 ext 280 or at compliance@nccommerce.com or at 100 E. Six Forks Road, Raleigh, NC 27609 for accommodations for this request.
Esta información está disponible en español o en cualquier otro idioma bajo petición. Por favor, póngase en contacto con Marcela Vargas at (919) 571-4900 ext 280 o en compliance@nccommerce.com o en 100 E. Six Forks Road, Raleigh, NC de alojamiento para esta solicitud.
CERTIFICATIONS
Each Agency hereby submits signed certifications consistent with the certification requirements of HUD.