HUD’s Healthy Homes Production Grant Program (HHP) Notice of Funding Opportunity (NOFO) hit the street on Sept. 2, 2022, and it had a relatively short deadline of October 18. Grant writers needed to act fast. Unlike some recent HUD NOFOs, HHP had a true narrative section, and that narrative section was limited to 15 double-spaced pages. The grant writer for an HHP project should note that those pages were evaluated according to qualitative ratings that range from outstanding (at 100% of the points) to poor (at 25% of the points) to outright non-responsive (0% of the points). There were three Rating Factors for the 2022 HHP program, and a number of sub-factors for each overall Rating Factor. As any grant-writing professional knows, it’s usually harder to write shorter than longer. With a 15 double-spaced page maximum for the narrative, this was especially challenging, as responses to all the Rating Factors and sub-factors had to be included along with a readable, descending outline format.
Eligibility was fairly broad, with states, counties, cities or townships, Indian Tribes, and general purpose nonprofits being eligible; most interestingly, applicants didn’t have to be a public housing authority (PHA) unlike many HUD programs, including the precursor to HHP, the Lead-Based Paint Hazard Control Program (LBPHCP). We wrote many funded HUD LBPHCP grants back in the day and, for that program, only cities, counties, and PHAs were eligible applicants. For HHP, nonprofits that can rehab and remediate housing units can apply. HHP used to be called “Lead Hazard Control,” (different from the even older, and aforementioned, LBPHCP) but HUD decided to roll a variety of other housing-related activities into the HHP program and generalize its name and purpose. Lead remediation is still a major activity for HHP, which makes sense given how toxic and dangerous lead-based paint is, but other activities include remediating generic environmental health hazards, rehabbing housing units to make them more accessible to the elderly, providing education and outreach, weatherizing housing, improving energy efficiency, and the like. Grant writers should know or learn these details before working on a given narrative.
Perhaps the most interesting part of this NOFO was the section that could make HHP hard to operate in the real world: successful applicants will “Promote collaboration, data sharing, and targeting between health and housing departments.” Many low-income owners and tenants want to avoid excess attention and site from health departments and, even worse city inspectors; these public officials generally have a “plain sight mandate.” That means the inspector may be looking a lead paint issue, but if he spots, say, an electrical wiring violation, he could issue a citation or even “red tag” the house/unit, making it illegal to occupy altogether.
Attention from well-intentioned bureaucrats can bring unwanted sanctions and discoveries, so many low-income persons who might benefit from home remediation will refuse that remediation if it comes with a risk of discovering all sorts of things that may not be up to code or, possibly, strictly speaking, illegal. For that reason, it’s often easier to target these programs at rental housing units as those units turn over between tenants, but public and low-income owner-occupied housing stock rarely turns over, so getting enough units to rehab during turnover periods is also challenging. Temporary relocation can be paid for through the grant, but, in the real world, very few people want to be temporarily relocated, even to remediate housing hazards, unless those hazards are extreme and the person really “believes” them to be extreme.
So, while HHP applicant eligibility is broad, the number of applicants who really have the chops and experience to run the program is likely to be lower. Still, the amount of money available should entice applicants: $40 million for 20 awards with amounts ranging from $1 million to $2 million. And the NOFO specifies that 10% of the costs may be used for administrative costs, which is handy; the NOFO also says that at least 65% of the grant funds must be used directly on identification and remediation activities, not other activities. There is a requirement that at least 10% of the project costs be in-kind, so applicants must have at least $100,000 in matching funds.
If you’re reading this and realize that you’d like to make the proposal process easier, call us at 800.540.8906 ext. 1, or email us at seliger@seliger.com for a fast, free fee quote. Grant writing is challenging and effective grant writers rare. We can deal with the relatively short deadline and make the HHP application work. Although we never participate in RFP/RFQ processes for housing authorities, we do work under sole-source contracts, and we also work with a wide variety of nonprofit and public agencies. HHP is a promising opportunity for anyone in the fair and affordable housing games.
Overall, there’d be less need for this program if more municipalities reformed their zoning restrictions and simply let people replace older housing with newer housing, which won’t have lead paint in it (lead paint has been outlawed since about 1980), and which will also be much more Americans with Disabilities Act (ADA) accessible, but most municipalities won’t relax their zoning restrictions and thus inhibit the ability of residents to have better lives through lower housing costs. Optimal public policy is often not actual public policy, sadly, and HHP is part of the routing around this housing policy failure.
