General executive Summary




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AHFA Response: An owner is not prohibited from performing a Wetlands Determination on a site to determine if wetlands are present. They may carve the wetland area off of the site prior to submitting the application. Because this is not a common occurrence and due to the additional cost of the study, this should not be added as a requirement for all applicants.


Comment: Make an exception for the requirement of having a “clean” Phase I or II in applications that meet the following conditions:

  • The site that is the subject of the application has been officially designated a “Brownfield” site under ADEM guidelines.

  • The site has been reenrolled in the ADEM voluntary Cleanup Program and specific steps have been identified by ADEM that if taken would qualify the site for a Letter of Concurrence.

  • The Development Budget specifically identifies the costs of taking the identified steps.


Comment: Specifically detail the language to be included in the report from the independent third-party environmental analyst that demonstrates clearance of all environmental issues and satisfies the AHFA requirement to “indicate all environmental issues have been cleared.”


Comment: Specifically detail the language to be included in the report from the independent third party environmental analyst that demonstrates clearance of all environmental issues. The following is recommended:

“If the Phase I Environmental Site Assessment (ESA) identifies Recognized Environmental Conditions (RECs), then a Phase II ESA must be conducted that appropriately resolves the RECs indicating all issues have been cleared, and/or an appropriate resolution of the environmental concerns must be documented by an Alabama-registered Professional Geologist. Site (NAME) Phase II has been conducted per ASTM standard E1903-97 and there are no adverse conditions found to prevent the construction of multi-family units.”


Comment: Have a remediation plan be acknowledged by the environmental engineer which will act as a “clear” Environmental Site Assessment PHASE II.


Comment: Create alternative standards for preservation and new construction proposals when considering environmental sustainability.


AHFA Response: HOME sites must have no contamination on site. Housing Credit sites where a Phase I recommends that a Phase II be conducted, the applicant must submit a Phase II at the time of application. All items must be cleared or a plan in place and acceptable to AHFA concerning all contaminants before construction can begin. AHFA will not consider any sites designated a “Superfund Site”.


Flood Certification (Page 10)

Comment: Allow sites that are in flood plains to be acceptable as long as flood mitigation is planned and acceptable to FEMA.


AHFA Response: Flood mitigation will not be allowed.


Site Location (Page 10 & 11)

Comment: Differentiation should be made between MSA and non-MSA counties relative to the threshold requirement of two miles distance between projects. Larger population markets can absorb more units and a one- mile distance is and adequate distinctive difference between known submarkets.


Comment: The distance requirement should be made to read “complete and 90% occupied” versus “placed in service and 90% occupied”. This should serve to clarify that it is very possible for a property to have achieved stabilized occupancy but not have met the technical “placed-in-service” threshold established through the 8609 process.


Comment: The current Plan provides “Applications that contain financing through HUD’s HOPE VI, Choice Neighborhood, Replacement Housing Factor funds, Capital Fund Program funds, and Promise Neighborhood development will not be subject to the 2-mile radius requirement.” A caveat should be added “provided any other PHA sponsored project within the two-mile radius is both complete and 90% occupied.


Comment: Multi-phased projects that receive a Housing Credit award should not be eligible for an award in the following year.


Comment: Reduce the threshold requirements within MSA’s from two miles to one mile.


Comment: Projects located in the tornado damaged areas of Alabama should be exempt from the 2-mile radius requirement.


Comment: The 2-mile exemption should be eliminated only for Public Housing Authority applications that include bond financing.


AHFA Response: The two-mile radius requirement currently prevents an owner from developing another property within two-miles until the prior funded project is placed-in-service and 90% occupied. There are exceptions to the two-mile radius requirement for applications with financing from HUD’s HOPE VI, Choice Neighborhood, Replacement Housing Factor Funds, Capital Fund Program funds and Promise Neighborhood developments. Due to tight expenditure deadlines, properties that are awarded these funds from HUD must build more than one phase at a time. The two-mile radius requirement should be waived for Jefferson and Tuscaloosa counties due to the recent disasters.


Financial Feasibility (Page 13)

Comment: Underwriting should take into account projects that meet green building requirements to obtain soft funds such as Earthcraft with the Affordable Housing program.


Comment: Construction in hurricane or tornado damaged areas may have additional costs to meet more stringent local codes and to lower prohibitive insurance premiums so the project will be feasible.


AHFA Response: These factors are taken into consideration when underwriting the projects.


Developer and Builder Fees (Page 14)

Comment: Foster Alabama-based non-profit corporations by establishing threshold requirements for the allocation of profits and losses as well as developer fees when a project is being submitted as part of the CHDO and/or non-profit set-aside. Mandate that a minimum of 40% or 50% of the profits/fees to be allocated to the non-profit general partner in these set-asides. This would help ensure that non-profit are being appropriately compensated for their experience, knowledge of the local community and value they bring to the development.


AHFA Response: Payment of profits, fees, and losses should be negotiated by the partners involved in the project and not mandated and enforced by AHFA.


Point Scoring System (Page 20)

Comment: Consider revising the definition of rehabilitation to include properties with less than 50% occupancy.


AHFA Response: The definition of rehabilitation includes properties with less than 50% occupancy. The occupancy is used solely for determining whether more than one project should be funded per county without targeting a different tenant population. For clarification purposes, the sentence will be revised to read as follows: “AHFA has separated rehabilitation into two types of projects for selection and funding purposes.”


Housing Credit Selection Procedures (Page 21- 22)

Comment: Use a set-aside or other method to permit more than one project in Tuscaloosa and Jefferson counties. Due to the population concentrations, the impact in terms of damaged and destroyed housing was much higher in these two counties.


Comment: Allow more than one project in Alabama’s most populous counties.


Comment: Modify the plan to create two pools of funds-one for the four most populous counties (Jefferson, Mobile, Madison, Montgomery) and other for the 63 less populous counties. Credits for each pool should be allocated based on the percentage of low-income people in each county, which would result in about one-third of the credits going to the urban pool and two-thirds going to the balance of the state pool.


Comment: Differentiate between family and senior in MSA’s allowing both within the threshold if a market survey supports it.


Comment: PHA sponsored projects should follow the same rules as other developments within the existing two-mile radius.


Comment: The one-application per county rules should be waived where there’s a higher scoring non-CHDO application and the two projects are not too close to each other or serve two different markets.


Comment: Tornado-damaged counties should be exempt from the one per county rule allowing a higher scoring application in a tornado damaged county to be funded over a lower scoring application in another county.


Comment: Due to the new steel mill in Mt. Vernon and service jobs due to the copper facility, Clarke County should not be restricted from additional housing.


AHFA Response: The one-project-per-county should be waived for Tuscaloosa and Jefferson counties in Tier 1 due to the damage caused by the tornadoes and storms. Tuscaloosa and Jefferson counties should be exempt from targeting a different tenant (elderly vs. family) population in Tier 2.


The housing restrictions for Clarke, Baldwin County, Robertsdale, Bay Minette, Daphne, Spanish Fort, and Fairhope should be removed from the Plans.


Type of Construction (Page 24)

Comment: The points for 50% brick buildings should allow for vinyl siding on the other 50% except for entry ways and below the bottom sill of the first window of a two-story building.


AHFA Response: The 50% brick requirement is optional for points and should remain unchanged.


Rent Affordability (Pages 26)

Comment: Many of the subsidies provided by Public Housing Authorities are funds that will be spent on housing in Alabama regardless of the allocation of Housing Credits. Therefore, such funds are not actual “multipliers” that increase the amount of affordable housing built in Alabama and should not be given any type of point advantages.


Comment: A maximum of 4 points should be given to projects which have commitments for any additional subsidies federal, state, local, public, or private that result in at least 50% of the units being set-aside for 50% AMI households. The additional subsidies may be in the form of below market interest rate loans or grants only. The commitment must be a fully executed firm commitment from the applicable entity that will be providing the funding for the project.

4 points - $15,000 per unit

3 points – $10,000 per unit

2 points - $5,000 per unit


Comment: Projects that have long-term project-based subsidies (over 15 years remaining on the HAP contract, ACC contract and RAP contract) from the date of application should receive 3 points. This will ensure the lower income bands projects which are in the most need of preservation begin to see funding.


Comment: Four points should be awarded for projects with over 15 years left on a project based Section 8 Housing Assistance Program (HAP) contract.


Comment: Affordable housing projects with project-based subsidies should receive three or more points. The additional points will allow projects, whose population consists of very low income households, the necessary bridge funding from the Housing Credit program.


Comment: A few of these programs are only available to Public Housing Authorities. This allows them to have up to 4 more points than others; furthermore, they do not have to meet the two-mile threshold rules. Consider taking away all preference points for Public Housing Authorities.


Comment: Eliminate points for additional subsidies if those additional subsidies are not available to all applicants.


Comment: Allow any existing subordinate soft financing on an existing Housing Credit project to count towards the point allocation for subsidized financing.


Comment: Proceeds from insurance settlements for damaged or destroyed housing in counties designated by FEMA as being impacted by the April tornadoes should be treated the same as CDBG, HOME, and Affordable Housing Program grants, etc.


Comment: Provide points for projects that utilize insurance proceeds from housing that was damaged or destroyed by the April tornado outbreak. Such insurance proceeds should be treated the same as other soft funding such as CDBG, HOME, Affordable Housing Program grants, etc.


Comment: Points should be provided for projects utilizing proceeds of municipal bond issues that include affordable housing as a permissible use.


Comment: Points for rent affordability should be removed.


Comment: The definition of additional subsidies should be expanded to include:

  • Project Based Section 8 subsidies allocated from a local PHA for a minimum of twenty-five percent of the affordable units of a property.

  • Long term commitment (i.e., 15-year term) of existing project-based Section 8 Housing Assistance Payment Contracts.

  • All other municipal and non-profit grants, awards and contributions that contribute to the benefit, improvement or construction and/or preservation of affordable units.


Comment: The definition of additional subsidies should be expanded to include:

  • Project Based Section 8 subsidies allocated from a local PHA for a minimum of twenty five percent of the affordable units of property.

  • Project Based Section 8 HAP or RAP contracts for at least twenty five percent of the units.

  • Loans from affordable housing nonprofits for greater than 5% of the total development cost.

Comment: Award points if the proposed property will be subsidized from a nonprofit fund established for relief from the April 27, 2011 tornadoes. Award 1 point per $1,000 per unit subsidy ($5,000 per unit would be 5 points).


Comment: Allow up to 10 points for projects that can demonstrate commitments of soft funding such as HOPE VI funds, CHOICE Neighborhood, Replacement Housing Factor (RHF) funds, Capital Funds, HOME funds, or CDBG or to the funds administered by Public Housing Authorities, because they purposefully address the creation of affordable housing the transformation of neighborhoods, directly benefiting the State of Alabama.

Comment: Return to the tiered subsidy commitment point structure of 2010, allowing up to 10 points for projects with more than $1.5 million in additional commitments.


Comment: Allow 10 points to projects with subsidized rents for more than 30% of its units over the entire 15-year compliance period.


Comment: Allow at least 5 points for all HOPE VI, CHOICE Neighborhood, Replacement Housing Factor (RHF) funds, Capital Funds and other funds administered by PHAs.


Comment: Points should be awarded for projects that provide deep rent subsidies. It should be limited to Rural Development rental assistance and existing Section 8 project-based HAP contracts. The project-based assistance should be in existence for longer than 10 years.


AHFA Response: There should be no revisions to this section.


Tenant Needs (Page 26)

Comment: Award points for an annual project contribution to the ALCARH’s Scholarship Fund of at least $500 per year.


AHFA Response: This is a good marketing plan and should be voluntary.


Comment: Add to the tenant services qualifying points, Ascendant Education’s web-based Supportive Service or the equivalent type of service.


Comment: Include high end temperature limiting technology (Safe-T-element) in the Plan.


AHFA Response: These services should be marketed directly to the potential applicants.


Comment: Amend this section as follows: Three points will be given to projects targeting low-income families (individuals with children) with a minimum of 5% of the units having three or more bedrooms or developments from the United States Department of Housing and Urban Development or the United States Department of Agriculture Rural Development that are already designated “family” by either of those agencies.


AHFA Response: The three-bedroom election is optional for points. Exceptions should not be made for family developments financed with HUD or RD funds.

Readiness Issues (Page 27)

Comment: One point should be given if the applicant is a member in good standing with the Alabama Council of Affordable and Rural Housing (ALCARH) and has attended the most recent ALCARH Annual Conference. Attendant must be a member of the development team.


AHFA Response: This should be strictly voluntary.


Comment: The utility availability points section should be achievable for rehabilitation projects through the submission of recent utility bills instead of letters from providers.

AHFA Response: Existing rental properties must provide documentation that the development is currently being serviced by all required utilities. Existing projects may submit utility bills in lieu of letters from the utility providers.


Project Type (Page 28)


Comment: Preservation projects built prior to 1990 should receive 3 points. This would allow preservation deals to compete with deals that receive 3 points for “15% of the units having three or more bedrooms” which is typically only seen in new construction.


Comment: Preservation project should receive 3 or more points. The additional points will allow preservation projects to compete with newer larger unit-sized projects that have 3 to 4 bedroom units.


Comment: Award points for the rehabilitation of existing Housing Credit properties.


Comment: Allocate points for existing Housing Credit properties located in Qualified Census Tracts or Difficult Development Areas.


Comment: “Preservation” should be distinguished from “Acquisition/Rehab”. Preservation should be defined as retaining properties as affordable units that might, but for the reinvestment of Housing Credits, be lost to the affordable portfolio. A set aside of at least 20% of the Housing Credit allocation should go to the preservation of properties that have received a prior allocation of Housing Credits or HOME funds from AHFA. USDA-financed projects and public housing authorities could compete outside this set aside as “Acquisition/Rehab” applicants.


Comment: In order to promote the preservation of the existing affordable housing stock and, given the high costs of converting existing unit mixes to 15% three bedroom units, the provisions of this section should allow for the automatic award of three points to preservation projects.

Comment: Allow an automatic award of three points to preservation projects constructed prior to 1990 (prior enactment of ADA of 1990).


Comment: Allow 10 additional points for public housing revitalization or PHA-related developments that serve the lowest-income families of Alabama.


Comment: Reinstate the points previously given for acquisition/rehabilitation of USDA RD and HUD properties. Consider limiting all acquisition/rehabilitation points to federally subsidized properties with 50% or more project-based rental assistance or tax credit properties, unless located in a metropolitan area of high incomes or population greater than 50,000.


Comment: Grant 3 point to RD and HUD rehabs, bringing them even with new family construction projects that have 3-bedroom units.


Comment: Maintain or expand the points awarded to proposals involving preservation.


Comment: Award more selection points for preservation projects and projects in danger of losing federal subsidies.


AHFA Response: Three points should be awarded for rehabilitation of existing multifamily residential rental housing.

Comment: Given the state and federal priority for redevelopment of “Brownfield” sites and the funding that is available for remediation, tax abatements, and incentives, 3 points should be awarded for proposed projects located on federally designated “Brownfield” sites.


AHFA Response: Preferences should not be given for Brownfield sites.


Location (Page 28)

Comment: Take into account the damage done by the tornados and the resultant needs by prioritizing areas (both rural and urban) that have lost significant numbers of affordable housing units in the last two to three year period by prioritizing assistance for areas with relatively high number of damaged or destroyed units (regardless of what factors lead to their destruction).


AHFA Response: Preference points should be awarded in the following disaster counties that have a relatively high number of destroyed or uninhabitable units due to the tornados and storms.


4 points – Jefferson and Tuscaloosa

3 points – DeKalb, Franklin, Limestone, Marion, St. Clair

2 points – Lawrence, Madison

1 point – Calhoun, Cullman, Marshall, Walker


Applications located in the city of Anniston, city of Huntsville, Jefferson County, and Tuscaloosa should not have to obtain a commitment for local HOME funds from the participating jurisdiction, equal to ½ of the HOME funds requested from AHFA.


Neighborhood Characteristics (Page 28)

Comment: Increase the distance for the services from 2 miles to 3 miles in the disaster counties.


Comment: It would be difficult and not practical to expand the distance from 2 to 3 miles on a county-wide basis for all counties affected or on the disaster listing.


Comment: Service points for preservation deals should be suspended. If a property is 85% or more occupied, we believe that the location, and proximity to services, is not a factor in the marketability of the property. By giving priority to preservation projects that are 85% or more occupied, the most viable projects are being preserved.


Comment: In order to allow some “point” separation among applications proposing new construction, we suggest that site amenities should be scored as follows:

Maximum Points 25

ONE MILE 4 points each

Grocery

Doctor/Hospital

Pharmacy

Bank


TWO MILES 3 points each

Grocery

Doctor/Hospital

Pharmacy

Bank

Post Office

Schools

Employment Centers


THREE MILES 2 points each

Grocery

Doctor/Hospital

Pharmacy

Bank

Post Office

Schools

Employment Centers

(Determined at the discretion of AHFA and identified as having more than 100 employees)


Comment: Provide direct incentives for projects located in close proximity to transit.


AHFA Response: The distance to services should be increased from 2 to 3 miles for all counties in the state. This should help increase the availability of quality sites.


Negative Neighborhood Services (Page 28 - 29)

Comment: Eliminate the negative points for an existing property or allow the applicant an exception to the negative points if they can demonstrate these conditions have never had a negative, unhealthy, unsafe, or otherwise detrimental effect on the property.


Comment: Rehabilitation of older Historic properties is a priority of many cities and towns and rightfully receives precedence under federal law as well as under the Allocation Plan. Historic properties applying for Housing Credits should be exempted from the 5 point deduction for being located adjacent to a railroad.


Comment: Remove liquor stores from the list or allow State ABC stores. They are regulated, operated by uniformed employees, enforce strict store hours, and do not allow loitering, etc.


Comment: Rehabilitation/preservation projects should be exempt from the deduction of points for adjacent Negative Neighborhood Services.


Comment: Exempt Public Housing Authorities from negative neighborhood services. The location of existing public housing sites are often fixed as a result of a Restricted Declaration of Trust.


Comment: Allow sites that have HUD Declarations of Trust and are being redeveloped to be exempt from negative points.


AHFA Response: Acquisition/rehabilitation and Public Housing Authority properties earn points in other sections of the Plan that should off-set any point deductions for detrimental site characteristics. State run ABC stores should not be considered a detrimental site characteristic.


Applicant Characteristics (Pages 29 - 30)

Comment: A maximum of 1 point should be given to applicants that have donated a minimum of $1,000 to the ALCARH Scholarship Fund for each application submitted. Verification from ALCARH should be submitted with the application.


AHFA Response: This should be strictly voluntary.


Comment: The current system of evaluating experience doesn’t take into consideration the unique difficulties a qualified non-profit corporation might have in accumulating 10 projects or 1,000 units. Consider different experience criteria for projects with 100% ownership by an Alabama-based non-profit that would allow AHFA to be comfortable that the non-profit has the requisite experience and capacity to complete the project.

Comment: Allow an experienced HUD program developer, that partners with a Public Housing Authority for a mixed finance project, to be able to compete based on their experience in other states alone and allow the Public Housing Authority to obtain the 3 points for AHFA experience with an exemption.


Comment: If the procurement has not yet been formalized for one of the Public Housing Authorities, then that PHA may have to choose a less experienced developer in order to compete. To alleviate this, allow a partnership to submit with either owner but also allow experience to come from either partner. This would allow a PHA to put an application in on behalf of itself but the developer partner could provide the experience.


AHFA Response: The experience of all individual and ownership entities is counted for the experience points. Non-profits are encouraged to joint-venture with experienced developers.


Design Quality Standards

Comment: Permit through-wall HVAC units in community spaces such as offices, laundry areas, sitting areas, maintenance rooms, elevator equipment rooms, electrical equipment rooms, and other community support spaces, or state that through-wall units are not permitted in residential units except for efficiency units.


Comment: Allow MiraTec treated exterior composite trim to be used as an alternative material for cementitious trim material as noted in Exterior Finishing Materials.


Comment: In order to strike a balance between promoting green practices in new construction and green preservation, the design standards should be revised to provide separate scoring criteria for significant energy conservation improvements in rehabilitation and new construction properties.


AHFA Response: Through-wall HVAC should be permitted in the common areas and efficiencies, but not in other residential units. MiraTec treated exterior composite trim is an acceptable product. The Design Quality Standards should not be revised to provide separate scoring for new construction and rehabilitation energy efficiency and green preservation.


Miscellaneous

Comment: The Qualified Allocation Plan should not have any dramatic change at this late date.


Comment: Making major changes in the competitive process is ill-advised at this time. The Alabama Housing Credit program has been working well in the past few years and AHFA should not make experimental changes that could damage the efficiency and reputation of the Housing Credit.


AHFA Response: AHFA will consider all public comments submitted in making revisions to the final plans.


Comment: Consider taking away all preference points to a Public Housing Authority. Under rent affordability, a few of these programs are only available to Public Housing Authorities. This allows them to have up to 4 more points than the others. Furthermore, they can break the two-mile radius threshold rules.


Comment: Public Housing Authorities should not have a preference in awarding an allocation of Housing Credits. They already have an advantage by getting points for HOPE VI funds, Neighborhood Stabilization funds, Capital Fund Program Grants and Replacement Housing factor Grants, which only Public Housing Authorities can receive.


Comment: Public Housing Authorities are not increasing housing stock to working families of Alabama and typically decrease living units. They have other subsidies and grant programs that the rest of the industry cannot receive. Public Housing Authorities should compete fairly on an even playing field to put resources in the best project.

Comment: Public Housing Authorities have many opportunities for obtaining funding other than through Housing Credits. Housing Credit supported projects are often the sole available affordable housing for working families, especially in rural areas where Public Housing Authority and other HUD funding (HOME, CDBG, Vouchers) are minimal to non-existent.


Comment: The Housing Credit was created to develop work-force and elderly housing for low and moderate income families and seniors. Targeting Housing Credit projects to housing authority tenants, most of who have incomes below 50% (or even below 30%) AMI is a misallocation of resources which is inconsistent with the purpose of the program. In the current political environment, these types of developments can easily be seen as “wasting” federal funds by over-subsidization.


Comment: Many Public Housing Authority funds are subject to annual appropriations. The loss of any of these funding sources could damage the long-term viability of a tax credit project.


Comment: The real benefit for affording any special treatment to Public Housing Authorities flows not to the Public Housing Authority or, arguably their tenant, but rather to the private developer who they hire. These hired private developers are no different than the other developers who are participating in the Housing Credit application process and, therefore, there is no reason to give them special consideration.


Comment: The bulk of units in Public Housing Authority projects using Housing Credits remain public housing units, often merely replacing existing stock. This creates no new net affordable units and does not provide housing for any new participants. In fact, one of the purposes of HOPE VI and Choice Neighborhood funding is to decrease housing density. Now is not the time for AHFA to spend its precious resources in order to simply maintain, or actually LESSEN, the overall number of available affordable units in the state.


Comment: Maintain the PHA provision in substantially the same form as the draft to ensure these popular public/private partnerships receive priority consistent with the broad support in local communities.


Comment: Public Housing Authorities should be required to apply for tax-exempt financing for the first two years as they do in other states.


Comment: There should be a limit on the amount of tax credits that can be applied for by Public Housing Authorities to $850,000.


AHFA Response: No additional incentives should be added for Public Housing Authorities.

Comment: Award 1 point per 250 residential units destroyed by the April 27, 2011 tornadoes. Points should be awarded based on rounding, up or down, to the nearest 250 units. Award 5 points if the proposed property is located within 15 miles of the path of the tornado. The cap on the number of new properties located in a single county (Tier 1 Funding Selection) should be waived for properties receiving points under the foregoing categories. Waive the 2-mile requirement for properties receiving points under any of the foregoing categories.


AHFA Response: Preferences have been made to the Plans for the disaster counties.


Comment: Direct the basis boost towards the preservation of vital at-risk affordable rental properties located in neighborhoods most affected by the current foreclosure crisis or unable to move forward due to the current volatility in the tax credit market.


AHFA Response: Applicants may request up to a 30% increase in basis if it is needed to make the project financially feasible.

Comment: Set-aside a certain portion of the funding for rehabilitations.


Comment: Create a tax credit set-aside for proposals involving the preservation and rehabilitation of existing multifamily rental housing.


AHFA Response: All applicants should be required to compete on an equal and fair basis. The only set-asides should be the 10% non-profit set-aside and 15% CHDO set-aside, which are federally mandated.


Comment: Decouple Alabama HOME funds from the Low-Income Housing Tax Credit Program. There are non-profit service providers throughout the state that would like to access HOME funds but are unable to do so because they want to develop smaller properties that better serve their clientele.


Comment: Utilize Alabama HOME funds for activities other than new construction. Using HOME funds for new construction of rental properties only excludes many organizations that promote homeownership and rehabilitation activities from applying for funding.


Comment: Consider allowing the City of Tuscaloosa to be eligible to compete for State of Alabama HOME funds.


Comment: Allow a modest allocation of state HOME or other funds that come available for acquisition/rehab projects, such as $200,000, so that the projects will be feasible.

AHFA Response: HOME funds should continue to be leveraged with Housing Credits to develop new construction. Special exceptions and preference points have been added to the Plans for disaster areas and acquisition/rehabilitation developments.


Institutional Structure


  1. Describe actions that will take place during the next year to develop institutional structure.


Program Year 3 Action Plan Institutional Structure response:


The four program administrator groups communicate as needed to coordinate strategies to the greatest extent possible. The creation and coordination of the statewide homeless coalition as well as the continuum of care efforts have aided the State’s ability to provide services in a coordinated manner. Every reasonable effort will be made to pursue the "consolidated" concept and to attempt to make it work in Alabama. In most cases, the four programs serve different clientele. The needs in Alabama are so great that the State’s strategy has been to let each program work to serve one set of needs. There is absolutely no duplication of effort.


Alabama relies heavily on the numerous housing and social service providers in the state to assist in the provision of services. Units of local government, program directors, and others involved in the implementation of housing and social services are consulted on a regular basis to determine the greatest needs and the best way to address them. ADECA will work with all local homeless coalitions, the Domestic Violence Council, the Continuums of Care, Community Action Agencies, the Alabama Alliance to End Homelessness and all other groups to assess and address the needs of homeless persons. ADECA, AHFA, and the Governor’s Office have successfully identified the parties interested in the implementation of the housing and non-housing programs addressed in this plan. Further, ADECA, AHFA, and the Governor’s office have developed productive communication channels with these groups. Alabama intends to continue this course in order to maximize the effectiveness of the programs.


In regard to HOPWA services, ADECA will continue to work with AIDS Alabama, the State’s most experienced HIV housing provider. AIDS Alabama has administered the statewide HOPWA program for more than seventeen years. During its last fiscal year, AIDS Alabama provided more than 56,700 nights of safe, decent, and affordable HIV housing throughout the State and prevented an additional 269 HIV-positive individuals and affected family members from becoming homeless through its statewide rental assistance programs. In addition to properties owned and managed by AIDS Alabama, the organization works with eight partnering AIDS Service Organizations to ensure that HOPWA resources are available in all 67 counties of the state.

The partners are:

  • AIDS Action Coalition – Huntsville;

  • Birmingham AIDS Outreach – Birmingham;

  • Unity Wellness Center of East Alabama Medical Center – Auburn;

  • Health Services Center – Anniston;

  • South Alabama CARES – Mobile;

  • Montgomery AIDS Outreach – Montgomery;

  • West Alabama AIDS Outreach – Tuscaloosa; and

  • Selma AIDS Information and Referral – Selma.


Through this network of experienced providers, HOPWA services are available throughout the entire state; every county is covered by at least one of the AIDS Service Organizations. These agencies maximize HOPWA dollars by coordinating delivery of services with each other and with other funding streams, such as Ryan White, Veterans Administration, McKinney-Vento homeless programs, and other federal and local programs. The greatest gaps faced by these organizations is not the delivery of HOPWA services, but the lack of additional resources to expand housing stock and supportive services available to HIV-positive persons. Extreme poverty and need, inadequate or non-existent transportation systems, and the continuing stigma associated with persons living with HIV serve to increase the challenge of identifying and stabilizing these individuals and families.


As to the strengths and gaps in the delivery system of these programs, the State’s greatest strength is the experience of the entities who administer the Consolidated Plan programs. Both ADECA and AHFA have competent and responsible staffs to carry out the necessary details of the programs. In addition, the capacity to reach more interested parties, including non-profit groups and other community-based organizations, has increased dramatically over the last few years with technical assistance workshops, training sessions, etc. Other strengths include the ability to layer different sources of subsidy to maximize eligible activities. The combination of city funds and state funds or the layering of HOME dollars and Low Income Housing Tax Credits are examples of this strength. Among the gaps encountered are the myriad of regulations and red tape inherent with federal programs. The largest gap thus far has been the lack of financial resources to carry out each program to its full potential.


As discussed previously, the primary obstacle to service delivery in Alabama is the sheer volume of need. Alabama has some of the poorest counties in the nation. Alabama has incredible employment, medical, educational, and housing needs in the Black Belt counties. However, the Delta Region and the Appalachian Region also have severe needs. Alabama will continue to coordinate efforts between state agencies and individual service providers to ensure the most efficient use of limited federal dollars. When possible, multiple funding sources will be utilized to maximize the impact of individual projects or initiatives. However, Alabama’s current priority is to prevent the duplication of efforts so as to spread resources among the areas with the greatest needs.


Continued review of the competitive rating systems of some of the State’s grant funds will also help to ensure the equitable and efficient distribution of funds. Annual reviews of the CDBG grant process have been effective in improving service delivery.

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