Disaster Housing Recovery Update, Monday, September 17, 2018


Multifamily Office Prepares for Hurricane Florence

HUD’s Office of Multifamily Housing Programs held a stakeholder conference call on September 13 in anticipation of damage to HUD-assisted homes due to Hurricane Florence. HUD estimates that there are 2,465 HUD-assisted properties in the path of the storm in North Carolina, South Carolina, and Virginia. These properties have a total of 189,497 units, 86,993 of which are assisted units. The properties include those that are HUD-insured, non-HUD-insured with Project-Based Section 8 contracts, Use-Agreement-only properties, HUD-held mortgages, and Direct Loan/Grant properties.

In a blog, NLIHC estimated that as of the hurricane’s path Wednesday afternoon, there were nearly 455,000 affordable rental homes for very low-income households in the potentially impacted areas of the hurricane and subsequent flooding. At the time of the estimate, there were nearly 87,000 federally assisted units in the potentially impacted area. NLIHC based its estimate on HUD data in the National Housing Preservation Database. Since the time HUD and NLIHC made their estimates, Hurricane Florence has taken a different path; we will revise and release new estimates this week.

During the stakeholder call, HUD encouraged owners on the call to have a plan for communicating with residents who evacuate, plan to contend with power outages, register with FEMA, and conduct property damage assessments as soon as possible.

HUD is urging Multifamily property owners with vacancies in Florida, Georgia, Kentucky, New Jersey, New York, and Tennessee to notify HUD. In addition, if they do have vacancies, HUD would like to know whether their properties have preferences for households displaced by a disaster.

NLIHC’s blog about the estimated number of low-income families threatened by Hurricane Florence is at: https://bit.ly/2NehNVT

The National Housing Preservation Database is at: https://bit.ly/2uzX5UW

HUD Notice Offers Rule Waivers for PHAs in 2018 Disaster Areas

HUD’s Office of Public and Indian Housing (PIH) published a Federal Register notice on September 12, informing public housing agencies (PHAs) about waivers of HUD requirements they may request in the aftermath of a presidentially declared Major Disaster Declaration (MDD) during calendar year 2018. PIH has issued similar waiver opportunities following Hurricanes Katrina, Rita, Wilma, Harvey, Irma, and Maria, as well as Superstorm Sandy. In order to obtain a waiver, a PHA in an MDD county must submit a request to HUD no later than four months after the disaster is declared.

The notice lists 21 potential waivers and invites PHAs to request waivers not included in the notice. Examples of waivers explicitly mentioned in the notice include:

  • Tenant Selection. A PHA’s public housing tenant selection policies or its Section 8 administrative plan for Housing Choice Vouchers may be temporarily revised without formal approval by its Board of Commissioners, provided the PHA documents Board support and it is not a significant amendment to the PHA Plan. The temporary tenant selection process may be in effect for no more than 12 months.


  • Opening the Waiting List. HUD will consider a request to waive the requirement that a PHA publish a notice in a newspaper of general circulation in order to open its voucher waiting list. A PHA may instead notify the public by posting a notice at any of its offices and/or placing a notice on its website and as a voice-mail message for up to 12 months from the date HUD approves such a waiver request. HUD reminds PHAs to consider the impact on people with disabilities who might have difficulty visiting a PHA office, and on people with hearing impairments or limited English proficiency regarding voice-mail messages.


  • Exception Payment Standard. HUD will consider a PHA request to use a voucher exception payment standard up to 150% of the Fair Market Rent in the absence of supporting data.


  • Occupancy Standard. For households displaced by a disaster, HUD will consider waiving the voucher rule limiting occupancy at an assisted unit to two persons per bedroom, provided the household consents in writing. If granted, the waiver will be in effect only for Housing Assistance Payment contracts entered into during the 12-month period following HUD approval. The waiver will be in effect for the household’s initial lease term.


  • Physical Inspections. A PHA may request a waiver of a physical inspection for the Public Housing Assessment System (PHAS) if its fiscal year-end date is within four months before and ten months after the disaster.


  • Operating Subsidy. For the purpose of calculating a PHA’s operating subsidy, a PHA may request public housing units vacant due to a disaster be considered “approved vacancies” for up to 12 months after HUD approval.


  • The notice states that HUD cannot grant waivers of unit Housing Quality Standard (HQS) inspections or income verification requirements. However, if sources of income are difficult to find, a PHA may use measures indicated in Notice PIH 2017-12, and HUD can consider variations to acceptability criteria to HQS.

The Federal Register notice is at: https://bit.ly/2MtMSPO

Notice PIH 2017-12 is at: https://bit.ly/2oZALRq

North Carolina


A Major Disaster Declaration (DR-4393) was declared by President Trump on September 14, for eight counties in North Carolina in the aftermath of Hurricane Florence: Beaufort, Brunswick, Carteret, Craven, New Hanover, Onslow, Pamlico, and Pender.

The MDD enables FEMA to provide Individual Assistance (IA), which can include grants for temporary housing and home repairs, low-cost loans to cover uninsured property losses, and other programs to help individuals and business owners recover from the effects of the disaster. FEMA explanations of Individual Assistance (IA) programs are at: HQ-18-127-FactSheet.

The MDD enables FEMA to provide Public Assistance (PA) to the state, tribal, and eligible local governments as well as certain nonprofits on a cost-sharing basis for emergency work in the eight counties. This assistance can be in the form of debris removal (Category A) and emergency protective measures (Category B), as well as direct federal assistance. FEMA explanations of Public Assistance (PA) programs are at: HQ-18-127-FactSheet.

In addition, the MDD allows FEMA to provide federal funding statewide for hazard mitigation measures on a cost-sharing basis. The Hazard Mitigation Grant Program provides assistance to state and local governments and certain nonprofits to prevent or reduce long-term risk to life and property from natural disasters.

Damage assessments are continuing in other areas of the state, therefore more counties and additional forms of assistance may be designated after the assessments are completed.

FEMA Administrator Brock Long named Albert Lewis as the Federal Coordinating Officer for federal recovery operations in the affected areas.

Survivors may register with FEMA after filing an insurance claim. If internet access is available, the best way to register is:

Survivors can call 800-621-3362 (FEMA). Applicants who use 711 or Video Relay Service may also call 800-621-3362. People who are deaf, hard of hearing or have a speech disability and use a TTY may call 800-462-7585.

The toll-free numbers are open from 7 a.m. to 10 p.m. ET, seven days a week. Multilingual operators are available.  Press 2 for Spanish and press 3 for other languages.

The Presidential Major Disaster Declaration is at: https://bit.ly/2NRkYlA

The FEMA page for North Carolina is at https://www.fema.gov/disaster/4393

State Government

The State of North Carolina’s Department of Public Safety has an Emergency Management webpage devoted to Hurricane Florence showing which counties have evacuation orders, disaster declarations, the locations of shelters, and other basic state information. The webpage is at: https://www.ncdps.gov/florence

Supplemental Nutrition Assistance Program [SNAP]

The Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA) announced two waivers for North Carolina participants in the Supplemental Nutrition Assistance Program (SNAP). Because many North Carolina residents evacuated to shelters and cannot store food and lack access to cooking facilities, the first waiver allows SNAP participants to buy hot foods with their benefits through October 31, 2018. Under normal circumstances, hot foods and foods ready for immediate consumption cannot be purchased using SNAP benefits.

Hot foods include items sold at authorized SNAP retailers that are hot at the point of sale. SNAP authorized retailers may need 24-36 hours to be ready to accept SNAP benefits for hot foods due to programming changes that may be required at their stores.

The second waiver provides extended time for SNAP participants to submit claims for food lost in the disaster. Affected households in North Carolina now have until October 15 to report food losses and request replacement benefits so they can purchase food to make up for what was lost in the storm.

The FNS disaster assistance webpage is at: https://www.fns.usda.gov/disaster/disaster-assistance

The media release announcing the two waivers is at: https://www.fns.usda.gov/newsroom

Ohio Housing Finance Agency Invokes IRS Revenue Procedure in Response to Hurricane Florence

The Ohio Housing Finance Agency sent an email reminding owners of properties assisted by the Low Income Housing Tax Credit that IRS Internal Revenue Procedure 2014-49 provides LIHTC owners temporary relief from income requirements for individuals displaced by a major disaster. Households are eligible for emergency housing in tax credit properties if their principal residence was located in an area eligible for individual assistance. Units leased as emergency housing are subject to the program rent limits. Internal Revenue Procedure 2014-49 allows units to be used on a transient basis and relieves the owner and household from providing evidence of income eligibility. The emergency relief period ends September 14, 2019. After this date, displaced households that cannot document eligibility for the housing tax credit program cannot occupy program units.

Owners who would like to provide emergency temporary housing must complete the Owner Request to Provide Emergency Housing form that is found on OHFA’s website. Questions are to be directed to Betsy Krieger.

After the 2017 hurricanes, many states reminded their LIHTC owners of this option. OFHA is likely to offer this as well to South Carolina now that a MDD has been declared for it too.

South Carolina


A Major Disaster Declaration (DR-4394) was declared by President Trump on September 16, for eight counties in South Carolina in the aftermath of Hurricane Florence: Berkeley, Charleston, Dorchester, Georgetown, Horry, Marion, Orangeburg, and Williamsburg.

The MDD does not provide for Individual Assistance (IA). It only indicates that Public Assistance (PA) is available to state, tribal, and eligible local governments as well as certain nonprofits on a cost-sharing basis for emergency protective measures in those counties. In addition, federal funding is available statewide for hazard mitigation measures on a cost-sharing basis. The Hazard Mitigation Grant Program provides assistance to state and local governments and certain nonprofits to prevent or reduce long-term risk to life and property from natural disasters.

Damage assessments are continuing in other areas of the state, and more counties and additional forms of assistance may be designated after the assessments are fully completed.

FEMA Administrator Brock Long named Elizabeth Turner as the Federal Coordinating Officer for federal recovery operations in the affected areas.

The Presidential Major Disaster Declaration is at: https://bit.ly/2NfMEkC

The FEMA page for South Carolina is at: https://bit.ly/2MHcWqP

State Government

  • The South Carolina Emergency Management Division has a webpage devoted to Hurricane Florence. It has updates on which evacuation orders have been lifted, a list of shelters, updates on road conditions, and other important information. The webpage is at: https://www.scemd.org


  • South Carolina Housing, the state’s housing finance agency (HFA) is asking federally assisted property owners to keep SC Housing informed of any storm-related damage to any Project-Based Section 8, Housing Tax Credits (LIHTC), Tax Exempt Bond, HOME, Neighborhood Stabilization Program (NSP) or Housing Trust Fund (HTF) properties for which SC Housing has either Project-Based Contract Administration or Compliance Monitoring oversight.


SC Housing would like to know about properties that have sustained any significant damage and/or have displaced families. SC Housing would also like to know about impacts on staff. For displaced families, SC Housing wants to know the number of units/families, type of damage, and whether the families will be rehoused quickly or staying in a shelter.


SC Housing is asking for the name of a point of contact, their email address, and telephone number.

Storm updates concerning Project-Based Section 8 properties should be provided to Carl Bowen, Director of Rental Assistance and Compliance,Carl.Bowen@SCHousing.com,     803-896-8670.


Updates concerning LIHTC, Tax Exempt Bond, HOME, NSP or HTF properties should be provided to Laura Tanner, Director of Compliance Monitoring, Laura.Tanner@SCHousing.com, 803-896-8762.



A Major Disaster Declaration has not been made for Virginia. An Emergency Declaration (EM-3403) was declared on September 11 in anticipation of Hurricane Florence. This has the possibility of providing Public Assistance to any county in the state to help the state, local, and tribal governments and certain nonprofits for emergency work and the repair or replacement of disaster-damaged facilities.

The Virginia EM-3403 FEMA page is at: https://www.fema.gov//disaster/3403

Read previous Disaster Housing Recovery updates at http://nlihc.org/issues/disaster

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