General Land Office Publishes Action Plan for Harvey Disaster Recovery

On April 11, the General Land Office (GLO) published its 128-page Action Plan related to the Hurricane Harvey disaster recovery program. The Plan is now open for public comment on an expedited two-week schedule with comments due by April 26.

The U.S. Department of Housing and Urban Development (HUD) has allocated $5.024 billion in Community Development Block Grant Disaster Recovery (CDBG-DR) funds to the state of Texas in response to Hurricane Harvey.

The GLO has been designated by the governor to administer CDBG-DR funds on behalf of the state of Texas.

COGS

There are 24 regional councils, also known as councils of governments (COGs) located within the State. The COGs are comprised of city, county and special district members working together to implement cost-effective, results-oriented strategies that address statewide and local needs on a regional scale.

The 49 CDBG-DR counties are located within nine COGs: Alamo Area Council of Governments (AACOG); Brazos Valley Council of Governments (BVCOG): Capital Area Council of Governments (CAPCOG); Coastal Bend Council of Governments (CBCOG); Central Texas Council of Governments (CTCOG); Deep East Texas Council of Governments (DETCOG); Golden Crescent Regional Planning Commission (GCRPC); Houston-Galveston Area Council (HGAC); and South East Texas Regional Planning Commission (SETRPC).

The GLO will administer the state-run program in partnership with the impacted COG regions. 

There will be coordination, but also deference given to the local communities, just as the GLO has done with the temporary housing assistance programs.  The GLO views the local communities as having, “direct knowledge of the needs in their areas.”  As such, the, “COGs will be consulted on the development of all the needs assessments and housing guidelines.”

City of Houston and Harris County

The City of Houston and Harris County have elected to develop their own local recovery programs. For Houston and Harris County they will each develop their own local action plans, and will be separate from the efforts administered through the GLO.

The allocation from HUD to Houston and Harris County is approximately $2.27 billion.

Homeowner Assistance Program

The Homeowner Assistance Program is the component of the overall recovery Plan that will have the greatest impact on individual homeowners (see page 75).  Therefore, this program will be the main area where there could be a role for both manufactured and modular housing in the coming recovery efforts.

The Homeowner Assistance allocation of funds for the nine COGs totals approximately $1.048 billion.

While there certainly is a component of rehabilitation as it relates to existing manufactured and modular homeowners, based on past disaster recovery experience, new factory built constructed homes are used for reconstruction. 

The Plan sets the criteria to determine the maximum amount awarded for reconstruction based on, “local composite builder bid amount based on procured builders and the builder’s house plans based on household size.”  Early calculations from HUD, depending on severity of the destruction, place unmet need costs for moderate to severely damaged homeowners (or complete home loss) in the range of $73,000 - $102,000.

At least 70 percent of the CDBG-DR program funds must be used to support activities that benefit low- and moderate-income persons.

The Plan’s appendix outlines a timeline for this program where the applicant portal through the GLO will be completed late-May with the program starting once the portal is complete.

The Plan calls for the first $2 million to be allocated by the fourth quarter of 2018.  The funding flow is expected to continue through 2024, with the largest awards being distributed the second- and third-quarters of 2020 ($130 million and $135million respectively).

Manufactured and Modular Housing

Manufactured home rebuilding and replacement are both eligible items for disaster funding (see page 76).  Use of factory built housing solutions should also be included in the broader category of, “Single family owner-occupied rehabilitation, reconstruction, and/or new construction.”

However, it will be critical to engage at the local levels with the above-mentioned COGS, as well as the City of Houston and Harris County, as they draft their Methods of Distribution (MODs).  The MODs need to include manufactured and modular homes as eligible recipients of disaster funding.

Our industry’s core competencies align better than any other single-family home provider when it comes to reconstruction of predominantly affordable, resilient homes focused on middle to lower income Texans. 

In addition, we have advantages in replacing one-off homes in nearly any location throughout the state.  Our construction costs per square foot can outcompete any other alternative.  And over the timeline being proposed well through 2024, our current production capacity issues will be resolved, meaning we will be the fastest home reconstruction option available.

In short, we can build our homes better, faster, larger per price point than any other option, and we can put them nearly anywhere (including 2 feet above the base floodplain elevation). We simply need to be given the chance to present our homes as an option to reconstruction recipients and empower them to make the decision that best fits their housing need.

As an industry we need to use these recovery efforts to proudly advocate but also demonstrate our modern homes, and our capabilities.  If the construction requirements are the same for all housing options, then we can compete on size, amenities, and even exterior elevations of roof pitch, attached garages, integrated porches, seamless ground set or skirting, and energy efficiency.  But to get our message out so we secure our chance to participate, we need everyone to get involved.

Housing Guidelines

The GLO and its subrecipients (i.e. COGs) will develop, “minimum housing guidelines that provide operational details on the eligibility requirements, housing assistance caps, construction standards, reporting requirements, and other program requirements. Subrecipients will produce their own guidelines. Housing guidelines will be posted for public comment before use. The GLO must approve all guidelines.”

Again, it will be critical at all levels of government to advocate for recipients of complete home reconstruction awards to have the choice to select either manufactured or modular homes alongside the other available site-built options. 

TMHA is aware of efforts at the federal level directly engaging with HUD to help ensure we are included in the recovery process. 

In addition, TMHA will advocate at the state level directly with the GLO and state level leaders for our inclusion in reconstruction home options. 

TMHA already met with the GLO back in October 2017 to discuss the role our industry could play in both temporary, but also reconstruction efforts.  TMHA will be submitting a public comment letter in response to this Plan, again calling for complete inclusion.

However, the third, and perhaps most critical, advocacy piece will come at the local level.  Just as TMHA originally reported, it is imperative that our local members get involved with their COGs.  In prior disaster recovery efforts, it is the last step in the process when local COGs draft their MODs where we have seen prohibitions on certain housing types - including prohibitions again manufactured and modular homes. 

Overcoming these local misperceptions and unfair exclusion is no small task, but one that must primarily include local involvement by TMHA members who live in the impacted areas.