Comments from the general public
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On September 21, 2018 began the public comment period (for 30 consecutive days, until October 21, 2018) with the objective that citizens actively participate sending comments and proposals to the Action Plan Amendment.

Within the public comment period, a series of public hearings were held from October 15 – 19, 2018, in the municipalities of Toa Baja, Guayama, Barranquitas, Manatí, Moca, Guánica and Fajardo.

All comments and proposals to the Action Plan Amendment received during the public comment period were answered and published in the draft Action Plan Amendment published on November 16, 2018.

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David Ortiz

My idea about the help for housing funds is that these funds are offered to all public employees, not only to teachers, but also to counselors, police officers, firefighters, school cafeteria employees who wish to buy their first home

David Ortiz

My idea about the federal funds to use is that the funds should be used for the public employees who are married and also the single ones for the purchase of their first home

Matt Tindall

In the Multi-Family Reconstruction, Repair & Resilience Program called for in the Substantial amendment, we request that the acquisition program and/or the existing buildings reference in the reconstruction/repair program clearly include adaptive reuse or conversion of existing space to provide multi-family housing.
On page 128 under Program Caps, you indicate that “The maximum award for housing rehabilitation in place is $60,000 in construction and/or hard costs per unit.” On Page 125 under Program Objective & Description, it states that “Homes become eligible for reconstruction when the property estimated cost of repair exceeds $60,000 or 50% of the current value132 – as confirmed through program inspection”.
i. Comment – what happens when a home’s value is determined to be $160,000 and the estimated cost of repair of the home is $65,000? In this case, if you repair the home, you exceed your rehab cap, but the home does not qualify for a reconstruction because the recon decision cap is 50% of the value of the home (or $75,000 in this case). Does the applicant not get served? This is another scenario that will likely be encountered throughout the recovery efforts that further supports having a hard dollar decision criteria to determine whether the home will be a rehabilitation or reconstruction.

Drustva Delgadillo

On behalf of KaBOOM!, a national non-profit dedicated to ensuring that all kids get the childhood filled with the balanced and active play needed to thrive, we would like to thank the Puerto Rico Department of Housing for the opportunity to provide comments in response to the Puerto Rico Disaster Recovery Action Plan (Amendment 1, Sept. 21, 2018).

As municipios, city planning agencies, NGOs and community stakeholders work together to rebuild Puerto Rico, we strongly encourage that rebuilding and resilience planning efforts – including those described under the Multi-sector initiatives, City Revitalization Program (pg. 186), and Community Resiliency Centers (pg. 182) – consider the inclusion of and equitable access to recreational and play spaces for children and youth.

The health benefits of play: At KaBOOM! we know how transformative – and magical – a playground can be for children, especially for children living in poverty. Without great places to play, children have less access to the wide-range of benefits play provides for cognitive, physical, social, and emotional health:
• Play is linked to healthy brain development during the early childhood years. [1]
• Children who take part in free play gain important social-emotional skills – such as confidence and resiliency – while improving their abilities to share, negotiate, communicate, and cooperate with their peers. [2] [3]
• Increased physical activity during play can also lead to decreased risk of obesity and diabetes and improved bone health. [4]
• Play provides parents an important opportunity to spend time with their children, which is conducive to maintaining strong parent-child relationships and social cohesion. [5]

City revitalization efforts that incorporate play spaces and multi-generational recreational areas have been proven to be powerful drivers for greater community cohesion and economic vitality. To this end, we encourage the Puerto Rico Department of Housing to place priority on city revitalization plans that include accessible and safe areas where children and youth can play, have fun, and regain their sense of normalcy.

Providing play opportunities following a disaster or crisis: Children are exceptionally vulnerable to experience significant stress and grief during and after a natural disaster or emergency. Research has shown that exposure to adversity – such as a severe disruption to their daily routine and sense of security following a crisis – can increase a child’s heart rate, blood pressure, and production of stress hormones, such as cortisol [6]. Children who experience frequent or prolonged levels of toxic stress can have lifelong health consequences that disrupt or impair healthy child development.

A child’s ability to respond during and after a disaster relies heavily on their home and community environment. When a child is surrounded by supportive and caring adults and mechanisms that provide buffers to their stress responses, children are able to “bounce back” emotionally and physiologically [7]. To this end, we encourage the Puerto Rico Department of Housing to require each community resiliency center to include resources and tools — such as mobile, safe playgrounds – to help restore children’s access to play and help bring normalcy back to their lives.

For additional information, please contact Drustva Delgadillo, Director of Strategic Partnerships at ddelgadillo [@] kaboom.org or 202-659-0215 or visit our website: https://www.kaboom.org.

References:
[1] Frost JL. Neuroscience, play and brain development. Paper presented at: IPA/USA Triennial National Conference; Longmont, CO; June 18–21, 1998. Available at: https://files.eric.ed.gov/fulltext/ED427845.pdf
[2] Hurwitz SC. To be successful: let them play! Child Education. 2002-2003;79 :101– 102. Available at: https://www.freepatentsonline.com/article/Childhood-Education/96193637.htm
[3] Erickson RJ. Play contributes to the full emotional development of the child. Education. 1985;105 :261– 263.
[4] Budd GM and Hayman LL. “Addressing the Childhood Obesity Crisis: A Call to Action.” MCN The American Journal of Maternal and Child Nursing, 33(2):111-118, 2008.
[5] Ginsburg, K. et al. The Importance of Play in Promoting Healthy Child Development and Maintaining Strong Parent-Child Bonds. Pediatrics. January 2007, Volume 119/Issue 1. Available at: https://pediatrics.aappublications.org/content/119/1/182#ref-6
[6] Center on the Developing Child (2007). The Impact of Early Adversity on Child Development (InBrief). Retrieved from https://www.developingchild.harvard.edu
[7] Ibid.

Samuel Gonzalez Cardona

United Way of Puerto Rico recommends that the federal government be asked to exempt the non-profit organizations of the rule for the reimbursement of the CDBG and other recovery funds and let them received the funds in advanced.

Therefore, UWPR recommend that the payments could be arranged as follows:
o Advance of 40% to start the projects
o Advance of 30% in a second payment with the submission of a partial report
o A refund of the remaining 30% with the submission of a final report

This support is request, because of the leading role taken by the non-profit sector, and they proved to be the first line of aid to the community during and after the crisis of Hurricane Maria. During the disaster the non-profit affiliated to United Way Puerto Rico performed invaluable work in our communities. Most of them served over 15,000,000 of prepared meals, more than 50 non-profit were disaster donations coordination center, provided over 29,000 case management sessions, provided over 43,600 mental health counseling sessions, offered over 26,300 nights emergency shelter, over 14,500 people received help to pay medical expenses, over 14,900 families were connected thru satellite communication. UWPR affiliated non-profit support over 2,400,000 people during the hurricane aftermath.

Hurricane Maria showed that the non-profit were a key in the emergency response and the recovery of the Island. However, they are facing economic challenges. One survey conducted by United Way of PR between November 2017-January 2018 shows that our organizations have an account receivable of $12,336,293 by different Puerto Rico’s Government Agencies. This is one of their major sources of funds, who represent 30% or more of their income for 33% of them according to a study conducted by United Way of PR on May 2015. During the performance evaluations carried out in March 2018, it was found that 72.1% of the affiliated non-profit have accounts receivable and a 18.5% of them have overdo accounts for more than 7 months. The evaluation also showed that 25.6% of the affiliated non-profit have credit lines and for 42% of them, it represents an economic burden. They had other loss of sources of funds like special events, individual investors and corporate gift. This situation impacts their capacity for provide programs and services to the community and reduction or even shutdown of services.

Puerto Rico Hospital Association

Abstract for Proposed Energy Independent Island Wide Emergency Response and Business Continuity Infrastructure Network

Puerto Rico Hospital Association Need and Proposed Solution:

First responders and Public Safety organizations such as the Puerto Rico Hospital Association (the Association) require a unified Land Mobile Radio (LMR) communications network that will allow all related organizations (e.g. Hospitals, Urgent Care Clinics, Dialysis Centers, Pharmacies, Ambulances, EMT’s, etc.) to communicate with each other, at all times, in a unified and efficient manner, and coordinate between the public and private sector quickly in responding to and recovering from a natural disaster.

The Association has made the decision to deploy an Energy Independent Island Wide Emergency Response and Business Continuity Infrastructure Network based on DMR technology. The Association has determined the network is a necessary expense related to disaster relief, long-term recovery, and restoration of infrastructure, housing and economic revitalization. Most importantly, it solves an unmet infrastructure need that will save lives. In addition, the network will ensure critical public safety supply chains supported by small, medium and large businesses operating in the US territory of Puerto Rico remain resilient and that lifelines remain open.

The goal of this initiative is to:
• Integrate with Local (Police, Fire & Rescue, EMT’s, etc.) and Federal authorities (FEMA, DHS, etc.) to facilitate communication and coordination during emergencies.
• Be energy independent and self-sufficient (no dependence on PREPA).
• Be designed with complete and total redundancy in order to ensure communication at all times before, during and after natural disasters.
• Facilitate both communication, data connectivity and site monitoring (e.g. security, generators, diesel fuel, battery backup, etc.) for Hospital Association members and PR healthcare stakeholders.

The Association, as a bona fide non-profit organization, is an eligible entity to receive CDBG-DR funding under section 105(a) (15) of the HCD Act, and is seeking grant funding as a subrecipient to PRDOH. It is eager to submit a grant to the appropriate counterparty and can deliver its solution within 90-120 days.

Due Diligence:
The Puerto Rico Hospital Association carefully reviewed the Federal Emergency Management Administration’s (FEMA) 2017 Hurricane Season FEMA After Action Report July 12, 2018 (FEMA Report), Governor Ricardo Rossello’s November 2017 Request for Federal Assistance for Disaster Recovery titled Build Back Better Puerto Rico, the Puerto Rico Department of Housing (PRDOH)’s June 14, 2018 First Action Plan submission to HUD on various ways to distribute $1,507,179,000 in CDBG-DR funds through HUD grant number B-17-DM-72- 0001, The Puerto Rico Central Recovery and Reconstruction Office (COR3) Transformation and Innovation Plan submitted to Congress August 8, 2018, The fiscal Plan for Puerto Rico as submitted to the Financial Oversight and management Board for Puerto Rico on August 20, 2018, PRDOH’s Second Action Plan posted for comment September 21, 2018, and relevant affiliated documents. In addition to these documents, the Association has culled data and feedback from the US Congress, its Association membership, key public safety stakeholders, the media, publicly available information, and federal and local government agencies in identifying this communications network solution.

Background, Challenges and Proposed Solution:
La Asociación de Hospitales de Puerto Rico (Puerto Rico Hospital Association, or Association), founded in 1942, and its membership bring together 67 of the 70 hospitals duly licensed in Puerto Rico. The Association represents other institutions, such as: Diagnosis and Treatment Centers, Independent Ambulatory Surgery Centers, Ambulatory Services Centers, Health Homes, and distinguished figures in the health care field among others. Its purpose and mission are to ensure excellent health quality standards for all communities in Puerto Rico.

As a result of the damage inflicted on Puerto Rico by Hurricanes Irma and Maria, the residents of Puerto Rico suffered tremendous losses of life due to a host of reasons, much of which was due to a lack of communications that permitted the different Public Safety organizations to work together. The failure of this lifeline infrastructure and the Association’s inability to communicate between public safety organizations, government (federal and local), first responders, medical institutions and private sector institutions delayed the recovery and more importantly affected the Puerto Rico government’s ability to attend the medical needs of American citizens residing in the Island. Such failure was noted in an August 29, 2018 study the government did in conjunction with the Milken Institute School of Public Health at The George Washington University.

The George Washington University study reports that Puerto Rico Government personnel and key leader interview respondents indicated that communication contingency plans were not in place to anticipate multiple cascading failures of critical infrastructure and key resource sectors. Consequently, the central government was not prepared to use alternative communication channels for health-related and mortality surveillance, public health information dissemination and coordination with communities, including radio and interpersonal communication. Further, an Urban Institute research report for the Puerto Rico Health Care Infrastructure Assessment stated that a shortage of medical professionals such as midlevel providers like physician assistants, nurse practitioners and specialists exacerbate the needed infrastructure reforms.

Understandably, without a functional telecommunication system, during and after a major storm or other natural disaster, the Association experienced a communication breakdown between its hospitals, doctors, and service providers. The Association faced severe complications in determining site status, where goods and services were most needed, and was unable to appropriately coordinate with FEMA and other federal agencies. Pharmacies struggled to stay open, access to patient therapies were unreliable / unavailable, and the important patient / doctor relationship compromised. Patients faced undue psychological consequences and hopelessness as they waited for support that was unable to respond, and sadly, the communications breakdown put the Association in a precarious position to deliver life-saving therapies.

The lack of reliable, fully operative telecommunication facilities not only impacted public safety on the island but it caused irreparable damage to Puerto Rico’s economy and has negatively impacted thousands of small businesses, the heart of the island’s private sector and its principal job creator. Businesses in Puerto Rico were unable to communicate effectively with their employees, suppliers, customers, banks, and health and security-related entities, among others, resulting in a supply chain failure, more closed businesses, loss of jobs, increased migration, and loss of revenue to a government currently faced with serious financial problems. These challenges unnecessarily increased the death toll on the island and made an already challenging recovery worse.
Disturbing factors that complicate the situation further and call for urgent corrective action to minimize the island’s telecommunication problems, is that Puerto Rico’s hurricane season extends from June 1 to November 30 and the island’s mountainous center, where many telecommunication towers are located, are always very adversely affected and take a longer time to repair.

It is important to remember the initial and sometimes prolonged human hardship caused by telecommunication problems on individuals and their families, such as: not being able to go to work or school; shop for food either because stores were closed because of damage or for lack of supplies or long lines (the same for gasoline); not having cash because most banks were closed and ATMs were not functioning; not being able to call for medical services or go to hospitals because many were closed or not offering all essential services; not being able to call police or the fire department in emergency situations; and not being able to communicate with relatives, on or off-island, who were very concerned with their well-being.

Currently, many emergency medical service (EMS) crews and their hospitals require two dispatchers to radio communicate with one another because EMS has its own Land Mobile Radio (LMR) system, while hospitals typically use the police LMR system and the two systems are not interoperable. Puerto Rico’s Federal, State and Local government agencies have never had a resilient, island-wide and truly interoperable communications system, and the private sector Telecommunications Providers Networks were not resilient enough to survive a major hurricane. The inability to communicate cost lives.

As a result of the lessons learned from the recovery after Hurricanes Irma and Maria and the Association’s extensive due diligence, it has made the decision to deploy an Energy Independent Island Wide Emergency Response and Business Continuity Infrastructure Network based on DMR technology. Network Integration will follow a two (2) phase approach. Initial phase will be integrated with all medical facilities in the Public and Private sector in order to concentrate on getting the network deployed, customers integrated and accustomed to utilizing the network. Then the network will enter into Phase 2 where the network will be integrated with Federal, State and municipal government agencies in order to better integrate Private Sector and Public Sector institutions that make up the backbone of Disaster Recovery.

The Association is ready to submit its grant, looks forward to opening a dialog on this important unmet infrastructure need that will save lives, and appreciates PRDOH’s consideration.

Marisol Jimenez

CONDADO LAGOON NEIGHBORS IN ACTION

October 20, 2018

Puerto Rico Department of Housing
Puerto Rico CDBG-DR Program (Secretary’s Office)
P.O. Box 21365
San Juan, PR 00928-1365

To Whom It May Concern:

Thank you for the opportunity to provide public comment related to the draft of the September 21, 2018 Substantial Amendment of the Action Plan for the Puerto Rico Community Development Block Grant Disaster Recovery. We have read through the entire document, including the section on Citizen Participation (pgs. 191- 196) and we found no evidence of your receipt of community’s original comments submitted in full compliance with the Puerto Rico Department of Housing’s Requirements on May 25, 2018.

We are therefore re-submitting our comments to the original plan and requesting that the Condado Lagoon Revitalization Project be adopted and added as a new program to the Action Plan. This high priority project addresses the long-term recovery, restoration of infrastructure and economic revitalization of a HUD designated “most impacted and distressed area” (MID) which is of significant importance for the Island’s economic development.

The Condado Lagoon Revitalization Project is a community led effort that seeks to leverage the natural beauty of one of the Island’s most strategically located natural estuaries to spark tourism and economic development by addressing the impact of flooding and hurricane related damages to critical infrastructure on the local people, businesses and environment. We envision that the Condado Lagoon Revitalization Project will directly impact the immediately surrounding Condado Tourist District, Convention Center District, Miramar Neighborhood and San Juan Harbor which are some of the Island’s top tourism assets.

Tourism is one of the Island’s top economic development strategies accounting for an estimated 8.4 percent of GDP in 2017 with the potential to grow to 10.7% by 2027 according to the World Travel & Tourism Council. The Condado Lagoon Revitalization Project is of key importance to protecting the current bed stays in this area and ensuring its growth.

About Us:
Condado Lagoon Neighbors in Action is a community group created in response to the severe damage caused by Hurricanes Irma and Maria as a way of finding solutions to the problems that have affected our quality of life, health and safety. We represent approximately 600 households and several hotels/small businesses located in the following streets:
– Aguadilla Street
– Barranquitas Street
– Clemenceau Street
– Delcasse Street
– Mariano Ramírez Bagés Street
– Marseilles Street
– Mayagüez Street
– Piccioni Street

Our group has already convened the residents of thirteen buildings including Laguna Terrace, Bristol, Ritz, Le Rivage, Condominio Marzelles, Condominio del Mar, Chateau Lagoon, Piccioni 1106, Condado Key, Vanderbuilt Lagoon, Condominio Barranquitas, 1104 Piccioni and 1127 Piccioni and business owners located in these streets including the Canario Inn by the Lagoon, Holiday Inn Express, Comfort Inn & O..live Boutique Hotel to understand the community’s needs priorities and establish this initiative.

We have also been in contact with the Environmental Protection Agency (EPA), U.S. Corp of Engineers, PR Power Authority (AEE), PR Senate, PR House of Representatives, PR Aqueduct Company (AAA) and Municipality of San Juan to develop plans focused on solving the identified problems.

Our community houses four hotels which directly serve over 150,000 tourists every year. However, economic impact of the of the Condado Lagoon Revitalization Project will directly impact the Condado Tourist District, Convention Center District, San Juan Bay and Miramar Community which are all directly bound to this waterway.

We are partnering with a non-profit organization called the San Juan Bay Estuary Program which has a long-standing track record of establishing high quality federally funded ecological programs as a fiscal conduit for this project.

Assessment of unmet needs
The Action Plan should be updated to incorporate the unmet need of our community, which has not been incorporated into the Summary of Impact/Support (pgs. 22-24). The impact of the 2017 Hurricanes should take into account the following criteria:

1. Severity of the damage to community infrastructure
2. Assessment of the economic impact of fixing the damage

Severity of damage to community infrastructure
Our community is located directly next to the Condado Lagoon. After the 2017 Hurricanes the storm surge that caused severe flooding on our streets. While the flooding has decreased, the levels of the water have never returned to their original level as can be evidenced in the attached pictures below.

After consulting with various engineers, it appears that storm surge shifted the sediments under the streets and caused severe blockages to the storm drains and even created back flow into the sewage system. These damages to the community’s infrastructure have created a vicious circle which causes continuous damages and ruptures to the streets. Even though the streets have been fixed various times since the Hurricanes, the insistent flooding continues to cause damages making the situation unsustainable and putting at risk the capacity to transit the entire area.

Assessment of the economic impact of fixing the damage
Our community is located directly at the center of the Condado Tourist District which is a strategic asset for Puerto Rico’s economic development. In addition to directly housing four hotels in the which provide occupancy for at least 150,000 tourists a year, the area is located within a mile radius of an additional four large hotels including the Vanderbilt Hotel, Condado Plaza Hotel, La Concha Hotel and Serafina Hotel. Our community also provides the only access point to for tourists and residents to the Condado Lagoon.
The streets of our community are also used as parking that for clients to the restaurants and businesses along Ashford Avenue. Frequent flooding and damages to the community infrastructure have disincentivized investment in this area and there are already blighted and abandoned buildings in the community.

As an area pivotal for economic development our community should be prioritized for need for the significant economic impact of fixing the damage.

Comments pertaining to the work that will be be funded with CDBG-DR grant money.

Planning Activities
The community is interested in carrying out a planning activities focused on:
○ Housing needs
○ Fitness and healthy lifestyles
○ Access to food
○ Infrastructure needs (roads, utilities, etc.)
○ Shelter/evacuation procedures
○ Emergency medical needs
○ Preventable health conditions (e.g., vectorborne diseases)
○ Economic vitality
○ Ecologic sustainability
○ Access to alternate/sustainable power sources
○ Plans for how local government agencies, local NGOs, national, and international aid organizations will communicate and collaborate to address needs
● Funding can also be invested in other types of planning, including plans for vehicular access to communities and economic revitalization plans.

Infrastructure Activities
The Condado Lagoon Revitalization Project would focus on:
• Urban interventions to enhance community cohesion including investments in sidewalks and common areas like parks and plazas
• Garbage management and disposal system
• Reconstruction of aqueducts/sewage/sanitary and storm drainage infrastructure
• Flood control to prevent contamination of the bodies of water through runoff, including the establishment of dikes and the installation of pumps
• Establishment of parking garages to increase parking spaces near businesses and tourism attractions
• The establishment of trails and other fitness circuits to promote community health
• Landscaping and irrigation systems
• Acquisition of solar/alternate power generation equipment
• Acquisition of illumination, high technology security equipment and closed circuit cameras to prevent crime and improve safety
• Establish a community police station
• Renovation of dilapidated infrastructure, including bridges and roads, that allow access to our communities

Economic Revitalization Activities
The Condado Lagoon Revitalization Project would focus on investment in enhancing the offering to services and public spaces to further attract tourists and taking advantage of the natural resources offered by the Condado Lagoon to establish sustainable eco-tourism that supports small business development and creates employment.

The following activities types of can be funded through CDBG-DR:
• Address issues related to runoff which is contaminating waterways and beaches which are a major factor in attracting tourists
• Establishment of outdoors fitness circuit, bicycle routes and bridges across highly trafficked streets and highways which fully connect the communities surrounding the Condado Lagoon (including Santurce, Miramar, Condado and Old San Juan)
• Beach nourishment projects which expand the area of beach which the hurricanes eliminated
• Public bathrooms near tourist attractions and natural attractions
• Leveraging and connecting existing infrastructure like the Jaime Benitez Park, Ventana al Mar, Parque del Ancla and Paseo Linear by improving transportation alternatives and vehicular access, establishing a fund for eco-friendly/small business to maximize recreation and culinary activities and roads/sidewalks to improve access to the Lagoon
• Funding for the establishment of housing and supportive services for the homeless

The Condado Lagoon is a strategic economic development asset for Puerto Rico and investments need to be made to maintain and expand its impact on the local economy. However, the water quality of the Lagoon after the Hurricanes has been affected due to runoff and flooding from damages to our community as can be seen in the attached pictures below.

Preparedness and Mitigation Activities
The Action Plan should ensure that CDBG-DR funding can be used for other activities including the following which are all necessary in our community:
● Flood barriers, contention walls and other strategies to mitigate and control flooding and storm surge
● Mangrove re-forestation activities to mitigate the effects of erosion
● Dredging of sediments in local water ways like el Caño Martin Peña which produce flooding and erosion to the communities in the San Juan Bay
● Installation of water pumps to drain the area in cases of flooding and disaster

.
For these aforementioned reasons we consider that the Condado Lagoon Revitalization Project is of critical importance to Puerto Rico’s recovery and should be adopted and added as a new program to the Action Plan.

Please feel free to contact us if you have any questions regarding our comments. You can contact me at: attymjm@gmail.com.

Sincerely,

Marisol Jiménez Meléndez
Co-Chair Condado Lagoon Neighbors In Action

Emily puthoff

I encourage you to incorporate as many sustainable strategies as humanly possible into the plan. We need to drawdown our carbon emmissions, and every new plan is an opportunity to design for our future. You can do it! Look to project drawdown for more ideas.

Javier Rúa-Jovet, Director Public Policy-Sunrun

Dear Madam or Sir,

Attached please find photo evidence of Sunrun’s filing of Comments to PR Disaster Recovery Amended Action Plan for the Use of CDBG-DR Funds, sent via the infocdbg@vivienda.pr.gov designated email.

Please confirm receipt of comments.

Thank you,

Javier Rúa-Jovet
Sunrun, Inc.
Director, Public Policy
c 787.396.6511
e javier.ruajovet@sunrun.com

Mekela Panditharatne

Fernando Gil Enseñat
Secretary
Department of Housing Puerto Rico
PO Box 21365
San Juan, Puerto Rico 00928-1365

RE: Comments on Draft Puerto Rico Disaster Recovery Action Plan

Dear Secretary Enseñat:

The Natural Resources Defense Council (NRDC) appreciates the opportunity to review and comment on the Draft Puerto Rico Disaster Recovery Plan (“Recovery Plan”). The NRDC is a national membership organization with over 3 million members and online activists, including members in Puerto Rico, dedicated to addressing environmental harms and social inequities. Please find comments on referenced programs below.

Housing Programs (pg. 126)

NRDC commends the plan for acknowledging the significant numbers of Puerto Ricans who may have been erroneously denied assistance for housing repair under the Individual Assistance program, and for considering alternative methods of documenting ownership. We recommend that locals with strong Spanish language proficiency be hired to conduct inspections to evaluate housing damage. Staff should be rigorously trained so that evaluation standards are applied consistently, and information is accessible. Protocols for damage evaluation should be transparent. Declarative statements signed under penalty of perjury should also count toward meeting FEMA’s standards to show contemporaneous occupancy in addition to notarized affidavits.

Home Repair, Reconstruction, and Relocation Program (pg. 125)

NRDC strongly supports this proposed action. As sea levels rise and extreme coastal storms become more likely, the risk of flooding will increase dramatically. Ensuring hurricane-damaged housing, located in flood and mudslide zones, is relocated or redesigned with consideration of this risk will help to improve Puerto Rico’s resilience to future large-scale events. Providing assistance to eligible homeowners to buy or build new homes in safer locations is a sound approach for ensuring such Puerto Rican citizens are not placed back into a situation of vulnerability.

In general, NRDC supports the two option approach for helping impacted homeowners relocate outside of high-risk floodplains. However, Option 1 (pg. 128) lacks clarity as to whether redevelopment would be permitted on the purchased land. In contrast, Option 2 clearly states “damaged properties acquired by PRDOH will be demolished and vacant lots will be maintained as open space.” If such a criterion applies to Option 1, the Direct Action Plan must make this clear. If such a criterion is not applicable to Option 1, then this is an unacceptable approach as permitting redevelopment would result in infrastructure being placed in areas that are known to be high-risk.

Community Energy and Water Resilience Program (pg. 143)

In addition to water catchment systems, water security and resilience can be enhanced at modest cost if the voucher program included water-efficient toilets, faucets, and showerheads to replace legacy plumbing fixtures in the homes of eligible participants.  US EPA WaterSense certification provides performance benchmarks to ensure that labeled products save water while meeting consumer expectations for performance.

Moreover, the true scope of Puerto Ricans experiencing water insecurity is not well known. This is particularly true in rural and remote areas, served by small water systems. NRDC recommends that FEMA make eligible for funding an independent inventory of hurricane damage to non-PRASA water systems, and related costs, and investigate the viability of connecting isolated communities to nearby, larger municipal water systems. NRDC recently obtained the results of an assessment of 237 small, independent water systems conducted by EPA after Maria. These assessments were conducted in November and December 2017. Nearly half of the small systems—at least about 48 percent of those that reported—suffered from a significant deterioration in operational capacity several months after the storm, in some cases leading to a total inability to deliver water to residents. However, there was a wide degree of variability in the level of detail in reporting hurricane-related damage. Many systems did not comprehensively report damage or operational capacity.

We recommend that the Puerto Rico government contract an independent inventory of hurricane damage to non-PRASA water systems and related costs to remedy water security issues, and investigate the viability of connecting isolated communities to nearby, larger municipal water systems.

Multi-Family Reconstruction, Repair, & Resilience Program (pg. 146)

Housing affordability is improved when appliances and fixtures are energy- and water-efficient.  The program description does not state how multi-family buildings would be made more resilient, nor the performance standards to be applied to eligible projects.   US EPA WaterSense certification of toilets, faucets, and showerheads provides performance benchmarks to ensure that labeled products save water while meeting consumer expectations for performance, and should be required for eligible projects.

NRDC applauds the plan’s recognition that “[h]igh denial rates have left hundreds of thousands without critical assistance and a large unmet housing need.”
 
Critical Infrastructure Resilience Program (pg. 180)

This proposed action is laudable as municipal-owned critical infrastructure should be made more resilient to future disasters, such as flooding. However, the proposed action must be fleshed out in greater detail to ensure CDBG-DR funds are spent effectively. The proposed action requires more specifics on how resiliency would be achieved, such as the standards to which such infrastructure would be rebuilt and how future conditions, like sea level rise, would be considered.

NRDC recommends that formal design specifications for critical infrastructure that could ensure a higher margin of safety against future flood risk be utilized. For example, critical infrastructure should be rebuilt so that it is elevated or flood-protected to either (a) three feet above the 100-year flood elevation, (b) above the 500-year flood elevation, or (c) to an elevation that accounts for future projections of sea level rise and the resulting flood risk over the lifetime of the project.

However, NRDC acknowledges such details may be finalized after Puerto Rico concludes discussions with the Federal Emergency Management Agency regarding funding for public infrastructure repair.

NRDC additionally recommends that FEMA consider funding independent evaluations of resiliency-building infrastructure improvements for drinking water and wastewater systems as part of the initial disbursement of infrastructure funds. Local government should be encouraged to apply for funding for an independent engineering firm with expertise in drinking water regulatory compliance to evaluate water systems. The firm should assess water and wastewater systems, provide a list and cost itemization of projects necessary to ensure compliance with federal drinking water safety standards and to target infrastructure investments to longer-term resilience.
Puerto Rico by Design (pg. 188)

NRDC is highly supportive of the proposed action: Puerto Rico by Design. As the acknowledged by the Action Plan, similar competitions have been conducted by the United States’ Department of Housing and Development, which have generated highly innovative design solutions for reducing the vulnerability of multiple communities to future disasters. Additionally, such competitions have produced multiple cross-sector benefits, and a competition tailored to Puerto Rico’s unique risks and opportunities would likely have the same impact. NRDC commends Puerto Rico’s ambition to generate “shovel-ready” projects through the competition by the beginning of 2020.

NRDC recommends that Puerto Rico Department of Housing contact Amy Chester at the organization Rebuild By Design, if it has not done so already, and secure that organization’s assistance in designing such a competition for Puerto Rico.

Sincerely,

Joel Scata
Staff Attorney
Natural Resources Defense Council, Inc.
20 N Upper Wacker Dr. Suite 1600
Chicago, IL 60606
Tel: 312.651.7925

Mekela Panditharatne
Equal Justice Works Law Fellow
Natural Resources Defense Council, Inc.
1152 15th Street, NW
Washington, DC 20005
Tel: 202-289-6868

Natalia Ramirez

21 de octubre de 2018

Sr. Fernando Gil Enseñat
Secretario
Departamento de la Vivienda
Programa CDBG-DR
P.O. Box 21365
San Juan, P.R. 00928-1365

VIA CORREO ELECTRONICO

Asunto: Comentarios de Espacios Abiertos al borrador de la enmienda sustancial al Plan de Acción

Estimado secretario Gil Enseñat:

La transparencia y la rendición de cuentas son centrales para que la repartición de fondos federales y locales en el proceso de recuperación y reconstrucción sea justa y efectiva. En todo momento, tienen que haber mecanismos abiertos y participativos para que la ciudadanía exija cuentas al gobierno y, de esta forma, pueda monitorear a dónde va la ayuda y cómo se canaliza. Con motivo de la presentación del borrador de la enmienda sustancial al Plan de Acción, presentamos nuestros comentarios para su consideración.

Según se desprende del Plan de Acción, el Departamento de la Vivienda, bajo el programa federal CDBG-DR, se compromete a dirigir una recuperación transparente y ordenada. Sin embargo, el mismo carece de mecanismos y pasos efectivos para garantizar que, en efecto, así sea. Veamos:

1. El Plan no incluye la adopción e implantación de una política de transparencia y acceso a la información que brinde pautas claras sobre qué tipo de información debe ser pública.

Todas las partes interesadas deben comprometerse a mantener una contabilidad adecuada y proveer información sobre los programas, el flujo de la ayuda y los gastos de forma oportuna, transparente, comprensiva y accesible. La aprobación de una política de transparencia y acceso a la información será un paso de avance para mejorar la gestión pública y facilitará la correspondiente fiscalización del proceso.

Referimos para su consideración y, a modo de ejemplo, la Orden Ejecutiva Núm. 125 firmada por el gobernador de Nueva Jersey durante el proceso de recuperación y reconstrucción luego del paso del huracán Sandy en el 2012. Dicha Orden Ejecutiva requiere que se publique en un portal de internet información detallada sobre la asignación y gasto de los fondos de recuperación. Específicamente: (1) cada agencia y departamento del Estado debe someter cualquier proyecto potencial que envuelva el gasto de recursos federales de reconstrucción a la Oficina del Contralor del Estado antes de que comience el proceso de contratación; (2) cada agencia y departamento del Estado debe designar un Oficial de rendición de cuentas responsable de supervisar el desembolso y uso de los recursos de reconstrucción desembolsados; (3) el Contralor, en coordinación con la Oficina de Recuperación y Reconstrucción y la Oficina de Tecnología de la Información del Estado deben hacer públicos en un portal de internet todos los contratos otorgados y pagados con fondos de recuperación; (4) cada agencia y departamento debe publicar notificaciones de prevención de fraude y las mismas deben estar a la vista en todos los proyectos de construcción que envuelvan el uso de fondos de recuperación. De igual forma, las notificaciones deben incluir líneas de números de teléfono libres de costo para reportar el fraude, despilfarro y abuso de estos fondos; y (5) el Contralor y la Oficina de Recuperación y Reconstrucción deben rendir informes periódicos de rendición de cuentas sobre la información publicada en el portal de internet.

El portal de internet del Departamento de Vivienda no contiene política, reglamento u orden que regule la transparencia en el proceso de otorgación y desembolso de los fondos federales CDBG-DR. A tales efectos, recomendamos que se promulgue una política de transparencia y acceso a la información, mediante la cual se detalle qué tipo de información debe estar disponible a la ciudadanía, el formato en que se debe publicar y el proceso que el Departamento debe seguir para que la recuperación y reconstrucción sea transparente y ordenada.

2. El Plan carece de transparencia en el proceso de adjudicación de contratos.

El monitoreo, así como la evaluación externa e independiente del proceso de contratación son claves para asegurar la implementación transparente de los programas de recuperación y reconstrucción y para que los recursos públicos no se desvíen de su propósito, que es ayudar a las poblaciones vulnerables. Es imperativo que el Plan incluya mecanismos apropiados que aseguren controles en la contratación y eviten cambios de órdenes que no sean cónsonos con el objetivo original. Algunos mecanismos pueden ser: pactos de integridad, criterios de evaluación abiertos al público, planes maestros con tiempo determinado y requisitos de construcción, entre otros.

A modo de ilustración, el portal “NJ Sandy Transparency: Accountability. Integrity. Oversight”, del estado de New Jersey publica información sobre todos los contratos por agencias y departamentos pagados con fondos de recuperación luego del paso del huracán Sandy. La información publicada en dicho portal incluye detalles tales como: nombre del proveedor contratado; el asunto de la contratación; documentos de solicitación; la propuesta del proveedor; el contrato íntegro final junto con otros documentos relevantes; y la fecha de otorgamiento del contrato. Cabe señalar, que el portal incluye también una sección de enmiendas y cambios de órdenes a contratos otorgados.

El portal de internet del Departamento de Vivienda solo incluye un enlace al portal Construimos de la Oficina Central de Recuperación, Reconstrucción y Resiliencia (COR3). En dicha página cibernética no se divulgan los contratos otorgados con fondos federales de recuperación. El hecho de incluir un enlace que dirige a la página oficial de la Oficina del Contralor no cumple con el estándar de máxima divulgación de la información, ya que en este no se precisa cuáles son los contratos pagados con estos fondos y a cuáles programas y proyectos se han adjudicado. Por tal razón, recomendamos divulgar todos los contratos con nombre de proveedor, el asunto de la contratación y propuestas de licitación.

3. El Plan no dispone para la divulgación de información sobre los fondos federales del programa CDBG-DR en formato de datos abiertos.

Los datos relacionados a la distribución de fondos del programa CDBG-DR deben publicarse en formato de datos abiertos. Esto significa que todo conjunto de datos producidos o recopilados por el Departamento de la Vivienda deben estar a la disposición de la ciudadanía para que los puedan utilizar libremente de manera sencilla y cómoda. Esto es importante, ya que permite evaluar, analizar y comparar información que resalte tendencias, estadísticas, o patrones que muestren desigualdades y desafíos, así como evidenciar el progreso en el uso de estos fondos.

Así por ejemplo, el portal “NJ Sandy Transparency: Accountability. Integrity. Oversight” antes mencionado, contiene una sección de monitoreo de fondos por cada agencia estatal que ha recibido fondos de recuperación. En la misma se puede acceder en formato de datos abiertos, hojas de cálculo de excel descargables, mediante las cuales se puede filtrar y analizar la información fácilmente. Las hojas de cálculo contienen datos pertinentes relacionados a todos los programas por agencia estatal. Incluso, ofrece la opción para ver toda la data, un resumen y un glosario de referencia para entender la data publicada. Para cada agencia se provee la siguiente información: fecha, origen de los fondos (agencia federal que los otorga), nombre del programa al cual se destinan los fondos, descripción del programa, nombre del proyecto, descripción del proyecto, cantidad asignada, cantidad obligada y cantidad desembolsada.

Es menester señalar que el portal Construimos del COR3 no cumple con los estándares de datos abiertos, ya que no se incluyen hojas de cálculos en excel con la información requerida para que los datos se puedan descargar y reutilizar para su correspondiente análisis.

Además, la información provista en dicho portal es incompleta, pues se desconoce la fecha de otorgación de los fondos de asistencia pública por municipio o por agencia, a qué proveedor se le otorgó el contrato o las propuestas de licitación que se han recibido, y cuánto dinero se ha destinado o desembolsado por proyecto. De la misma forma, el portal Construimos enumera una lista de subvenciones federales adicionales para la recuperación del país; sin embargo, no se desprende información acerca de si se han desembolsado esos fondos, a quién se les ha adjudicado y la cantidad.

El Plan de Acción que se adopte debe sacar partido de los requisitos de cumplimiento federal para los fondos federales de recuperación a fin de atrincherar una cultura de acceso a la información y rendición de cuentas. Las recomendaciones que compartimos son precisamente una hoja de ruta para asegurar que los fondos del programa CDBG-DR se utilicen y distribuyan efectiva y responsablemente.

Con el ánimo de lograr mayor transparencia en la distribución de estos fondos, solicitamos muy respetuosamente, tenga a bien evaluar y promover estas buenas prácticas desde el Programa CDBG-DR del Departamento de la Vivienda.

Cordialmente,

Lcda. Natalia Ramírez Echevarría
Coordinadora de proyectos
Espacios Abiertos

Diane Cohen

To Whom It May Concern,

I am writing to encourage consideration, as part of a mixed-use neighborhood development plan, to include a place for the exchange of (reused) materials. All future neighborhoods should be designed with a community-based ReUse Center due to the multiplying benefits that occur when this type of infrastructure is in place. A huge contributor to resilient communities, ReUse Centers provide affordable materials to people who need them most, a convenient alternative to the landfill, a place to teach and preserve important skills, and they create quality jobs. Perhaps more importantly, they can not only be self-supporting financially once launched, they provide enormous assets and value to the community.

Material exchanges or ReUse Centers, in particular community-based ReUse Centers, are a powerful way to reduce waste and rebuild community. I am the Director of a nonprofit organization in Ithaca, NY, and have participated in EPA-funded disaster reponse training. Lack of reuse infrastructure is a universal problem, but please consider it in future planning. We offer a free online business plan template for any community who wants to start their own independent community reuse center: template.ithacareuse.org.

I appreciate the opportunity to submit this comment.

Sincerely,
Diane Cohen
Executive Director
Finger Lakes ReUse, Inc.
https://www.ithacareuse.org

jan susler

Puerto Rico Subcommittee of the
National Lawyers Guild
c/o People’s Law Office
1180 North Milwaukee Avenue
Chicago, Illinois 60647

October 21, 2018

Hon. Fernando Gil Enseñat, Esq.
Secretario, Departamento de Vivienda
P.O. Box 363188
San Juan, Puerto Rico 00936-3188

Dear Secretary Gil Enseñat,

On behalf of the National Lawyers Guild Puerto Rico Subcommittee, we offer the attached comments to the draft Substantial Amendment to the Action Plan for the Community Development Block Grant – Disaster Recovery.

Jan Susler
Attorney at Law

Puerto Rico Subcommittee of the
National Lawyers Guild
c/o People’s Law Office
1180 North Milwaukee Avenue
Chicago, Illinois 60647

Vulnerability is not simply a product of natural conditions; it is a political state and a colonial condition.

Floods wash away the surface of society, the settled way things have been done. They expose the underlying power structures, the injustices, the patterns of corruption and the unacknowledged inequalities.

The comments offered here endorse the comments of Ayuda Legal Puerto Rico, and hope to put them in the context of the historical use of Community Development Block Grants – Disaster Recovery funds, aiming to avoid repeating the errors of the past disaster recoveries, which have adversely affected those hit hardest: low and middle-income people and their communities.

The U.S. Congress established the Community Development Block Grant program, in 1974, to provide flexible funds that states would control. Grants were historically awarded to grantees who met three Housing and Urban Development criteria:
to (1) benefit low and moderate income people, (2) aid in the prevention or elimination of slums or blight, and (3) meet other urgent community development needs because the conditions pose a serious and immediate threat to the community.

For more than 30 years, HUD allowed limited waivers to these criteria, usually to facilitate applications by low-income people. However, after September 11 (2001) and Hurricane Katrina (2005), the first two criteria were eliminated, and the third criteria was applied to business interests of the well-connected, obviating any plan for fair or long term rebuilding. In the hands of neoliberals, the disaster recovery program originally designed to assist the needy converted into its opposite, privileging the private sector and stranding the needy.
Specifically, following Hurricane Katrina, the state of Mississippi diverted CDBG funds “away from programs addressing the housing needs of LMI [lower and middle income] victims of Hurricane Katrina toward financing commercial port expansion,” contrary to the purpose of CDBG funding:
The members [of Congress] are rightly outraged by a state plan that will siphon off more than a half-billion dollars in disaster aid for the redevelopment of the port of Gulfport, which local boosters have long envisioned as a hub for cruise ships and gambling. That is not what Congress intended when it voted to distribute the Katrina aid through the Community Development Block Grant program, which was set up in the 1970s to improve housing, economic opportunities and quality of life for the poor.

Kevin Fox Gotham, a sociology professor at Tulane University and an internationally known expert on real estate and housing policy, political economy of tourism, post-disaster recovery and rebuilding, called this diversion of CDBG funds “not accidental or unintentional. Rather, officials in Mississippi, with the approval of HUD, attempted to reallocate CDBG funds to encourage port expansion and recovery efforts for commercial businesses, thereby engaging in a planned subversion of the original objectives of the CDBG program.”
Also after Hurricane Katrina, the state of Louisiana failed to apportion appropriate funding to renters whose homes had been affected, a frequent criticism of CDBG recovery plans. An administrative complaint filed with HUD alleged that this amounted to “the planned misuse of federal funds” for its “refusal to provide adequate resources for renters;” the complaint also alleged that the state failed to detail how the CDBG funds would be allocated to meet the requirement that 50% of the funds be targeted to primarily benefit low and moderate income people. While protests eventually resulted in the allocation of additional funds, the significantly delayed funding fell far short of the needs of the population CDBG was supposed to assist. “In short, CDBG-DR program design and implementation rules diverted funding away from housing assistance for renters, privileging homeowners and thereby buttressing long-standing housing inequalities.”
New Jersey’s CDBG plans for recovery after Hurricane Sandy (which struck in 2012) similarly failed to take into account the needs of low and middle income people – who were disproportionately affected and who were disproportionately Black and Latinx – with inequitable volumes of funds allotted to benefit those in higher income brackets. The plan was thus criticized for failing to address an equitable recovery, i.e., for failing to address the vulnerabilities of the population CDBG is supposed to be designed to target.
Yet another historical problem important to avoid repeating is the use of CDBG and other post-disaster relief as an opportunity to implement far-reaching neoliberal policy reforms, while people are still reeling from the disaster, otherwise known as disaster capitalism or vulture capitalism. As with the diversion of CDBG funds from low income people to commercial port expansion in Mississippi,
[d]elays in financing the rebuilding of New Orleans and subsidies to high-end real estate in Lower Manhattan are not merely accidental side effects, policy failures or unforeseen consequences of otherwise well-meaning government programs and actions. Nor are the problems of recovery and rebuilding the result of institutional ineffectiveness or bureaucratic sluggishness. Rather, the shortcomings of the government response to Hurricane Katrina and 9/11 are constitutive features of neoliberal government action and policy that privileges speculative financing and market rule to engineering urban recovery.

On behalf of the Puerto Rico Subcommittee of the National Lawyers Guild, we endorse the comments of Ayuda Legal Puerto Rico, encourage you to avoid repeating the above-cited errors made in previous disaster recovery situations, and urge you to enact an equitable plan that emphasizes the purpose of CDBG-DR, to benefit low and middle income people.

Dated: October 21, 2018
Comments prepared by:
Jan Susler, Attorney at Law
Puerto Rico Subcommittee of the
National Lawyers Guild
c/o People’s Law Office
1180 North Milwaukee Avenue
Chicago, Illinois 60647
773.235.0070
jsusler@gmail.com

Rachel Hiskes

Comentario Publico
Rachel Hiskes
Residente Rio Piedras
21 de octubre, 2018
Re: Plan Enmendado Vivienda PR para Sumisión a HUD
~ AREA PLANIFICACIÓN ~
La importancia de incorporar la experiencia y peritaje de residentes y negocios en la recuperación de sus entornos- conocimiento local es vital. Planificación debe estar en manos de las comunidades, especialmente comunidades especiales; de los cuales muchos tienen PDI, Planes de Desarrollo Integral. Es necesario reclutar planificadores y organizadores comunitario/as en grandes cantidades que provienen de las mismas comunidades y organizaciones de base. Ejemplos notables son el Fideicomiso para el Desarrollo de Rio Piedras y Fideicomiso del Cano Martin Pena.
También es prioritario planificar para los efectos de cambio climático; ya se ve la erosion de costos, el nivel de mar subiendo, temperaturas y intensificación de tormentas y lluvias. Puerto Rico debe llevar a cabo un proceso de planificación a grandes escalas en la Junta de Planificación con insumo de todos los sectores, sean municipales o organizaciones sin fines de lucro.
~CONTROL DE INUNDACIONES: INFRAESTRUCTURA/PUERTO RICO SE DISENA~
Ninguno de los fondos de CDBG-DR debe usarse para alteraciones mayores del terreno como las canalizaciones y diques que USACE esta presupuestando para Puerto Rico. Estas medidas están siendo cuestionados últimamente, y ciencia reciente ensena que realmente solamente mueven agua abajo; no mitiga causas mayores.
En cambio, infraestructura verde, como las barreras naturales como ostras, manglares, de dunas, arrecifes en la costa tienen alta incidencia de éxito. En el caso de comunidades con ríos, introducir piedras, maderas, estabilización de bancos charcas de retención son medidas que tienen un éxito notable.
Abajo unas inversiones necesarias en Rio Piedras y alrededor de la Isla:
· Sistemas de aguas pluviales, alcantarillado inexistente en muchos lugares causan inundaciones. Contratos deben exigir un porcentaje de 75% trabajador/as locales; y en gerencia de proyectos debe de ser igual.
· Sistemas de aguas sanitarias, mucha tubería rota alrededor de la isla presentan aguas con material fecal que es problema de salud pública.
· Construcción de vías tiene que seguir las guías de Calles Completas; hacer valer la regulación de DTOP de calles que cumplen con carriles para bicicletas, aceras amplias, sombras/arboles; también bancos/zafacones; espacio para peatones. Caminos para todos, peaton, envejiciente, ciclista, niños, choferes, etc.

~VIVIENDA~
· Mucha propuesta de nueva construccion; mientras hay exceso de propiedades vacantes
· Títulos de Propiedad : parcelas entegradas por la autoridad de tierras desde los años 1950 y pero falta la documentación, muchas personas dueñas de parcelas fueron negadas asistencia de FEMA por no poseer documentación de Autoridad de Tierras.
Estos fondos deben de usarse para la permanencia de comunidades. Debe de establecerse bajo ODSEC la regulación necesaria para Comunidades Espeicales celebrar sus asambleas, retener su población, atender sus necesidades, y en caso que relocalizar la comunidad es una opción decida voluntariamente por la comunidad, entonces usar los fondos CDBG para el buyout.
De igual forma, comprobar posesión y derecho a una propiedad debe incluir muchos elementos; y tener como prioritario comunidades estables, con casas habitadas por dueñas y una población estable. Brindar la oportunidad de tenencia colectiva bajo Fideicomisos o Cooperativas tiene que ser una opción para este programa. También la implementación de este programa debe contar con comités de vecinos, lideres de organizaciones de abogacía como Ayuda Legal Huracán María, PR por el Derecho de Vivienda Digna, y Coalición de Coaliciones.
~RENACER AGRICOLA~
Este programa debe llenar vacíos para pequeños agricultores/ los que no cualifican bajo USDA, no tienen el seguro costoso que es requisito para ayudas federales agrícolas. También debe contemplar las fincas que también son residenciales- brecha en los alquileres que no permiten vivienda.

~IMPLEMENTACION~
Los fondos CDBG-DR compone un sector de la economía que debe dominar una fuerza trabajadora no ligado a una administración en particular, sino experimentado en la gobernanza, en experiencias de desastres, y con residencia en Puerto Rico. Estos fondos son públicos, y no deben pasar por infinitos números de contratistas, ni expertos que no residen ni tributen en Puerto Rico. Es necesario establecer el peritaje de administración de vivienda en los excelentes profesionales de PR, y atraer de vuelta la clase de profesionales que han tenido que emigrar.
Seguramente Vivienda en sus fondos de administración, debe contemplar expandir sus empleados, y también las otras unidades que implementen, como ODSEC que ya casi no existe y es de poca ayuda para las comunidades en las tomas de decisión tan apremiantes que tienen.
Creo que la contratación RFP que actualmente tiene Vivienda solamente seria realista para su actual contratista Horne, y empleados públicos con el expertise en Puerto Rico son necesarios.
Gracias por la oportunidad de comentar, y mucho éxito en la tremenda labor de recuperación que emprende Vivienda.
Rachel Hiskes

Emily Puthof

I encourage the plan to include every opportunity in the design to drawdown carbon emissions and to incorporate sustainable, resilient infrastructure and housing decisions.

Maria R. Batista Santaella

Comments on the Puerto Rico’s Action Plan for CDBG-DR Funds
October 21, 2018
Via email to: infoCDBG@vivienda.pr.gov
Submitted by: Carlos Mercado, Sub Director of Puerto Rico Trade and Commerce Company

The Puerto Rico Trade and Commerce Company (PR Trade) appreciates the opportunity to present comments on Puerto Rico’s Action Plan for the Community Development Block Grant funds for Disaster Recovery allocated by the Supplemental Appropriations for Disaster Relief Requirements, authorized by Public Law 115-56 and Public Law 115-72 2017; and announced through Federal Register 83 FR 5844 on February 9, 2018. The comments are made to the Substantial Amendment to the approved Action Plan.
As part of the Government of Puerto Rico, PR Trade was in the frontlines of the emergency response and the recovery. Leading the task of assisting small and medium size businesses (SMEs) around the island regain their operations was crucial to ensure access and availability of basic goods and services, particularly in low and medium income (LMI) communities, severely affected by the hurricanes. The efforts, carried by the initiative “Puerto Rico Emprende”, provided much needed direct support to SMEs to remain or reopen, reinstate their supply chain and retain jobs.
Puerto Rico’s Action Plan for the CDBG-DR funds recognized the importance of SMEs for the local economy and support is included as part of the “Economic Recovery Programs” activities. Nevertheless, planning activities must extend to the local SMEs as part of the Government efforts to promote community resiliency. Acknowledging how important is for all sectors in the community to be prepared and able to respond during and immediately after an emergency is crucial to effectively face any disasters in the future. PR Trade supports the initiatives of the Government of Puerto Rico intended to maximize the CDBG-DR funds available and contribute to this effort with the following comments to the Action Plan.
1. Whole Community Resilience Planning Program (Page 113)
An important lesson learned in the mist of the emergency and the recovery process, was the limited readiness and resilience capacity among local SMEs. LMI communities rely and depend on their local businesses for their everyday needs. After the hurricanes, because a significant number of small businesses were unable to operate, communities struggle to access basic needs like food, water and medical services. The Whole Community Resilience Planning Program included in the Action Plan focused on facilitating comprehensive community recovery. Since it refers to the community as a whole, PR Trade recommends including activities that also target SMEs to develop effective planning and improve their readiness and resiliency management capacity.
PR Trade is ready to support the Government goal of more resilient communities by ensuring that SMEs integrate to the Whole Community Resilience Planning program, performed risk analysis and have in place readiness and resiliency plans aligned with their communities’ particular needs. These efforts will promote job retention and access and availability of critical goods and services in emergency situations.
2. Small Business Incubators and Accelerators (Page 159)
Supporting the growth and success for start-ups and new businesses in the early stages of operation is important to the island’s economic development. The Action Plan includes business incubators and accelerators to support star-ups and new businesses. PR Trade urges to include export accelerators as part of the eligible activities. Assisting local businesses expand to new markets promotes business continuity, retain and create new jobs; and increase tax revenue. After the hurricanes, PR Trade provided small businesses direct assistance to accelerate their export plans and participate in export missions to remain operational during the disaster recovery process. These actions help retain and create jobs and expose local goods and services to new markets and created new business opportunities.
Incorporating export accelerators to the Small Business Incubators and Accelerators program will be an important element to the economic recovery.
3. The Strategic Projects and Commercial Development program (Page 169)
The Strategic Projects and Commercial Development program is aimed to commercial rehabilitation activities and bring commercial structures up to code or to improve their facades. PR Trade recognizes the importance of this program and recommends the investment of CDBG-DR funds in promoting preparedness and resilience among the public market places (Plazas de Mercado). All municipios have at least one public market place, ensuring their capacity to remain operational after a disaster with alternative energy, communications and potable water solutions is crucial for local economies and communities.
PR Trade is ready to work with the Government to increase small business readiness and mitigation efforts, for potential future disasters, through access to solar panels, Wi-Fi services, potable water and solid waste management strategies.

Annie Mayol, President and COO, Foundation for PR

Comments on the Puerto Rico’s Action Plan for CDBG-DR Funds
October 21, 2018
Via email to: infoCDBG@vivienda.pr.gov
Submitted by: Annie Mayol, President and COO, Foundation for Puerto Rico

Foundation for Puerto Rico (FPR) appreciates the opportunity to present comments on Puerto Rico’s Action Plan for the Community Development Block Grant funds for Disaster Recovery allocated by the Supplemental Appropriations for Disaster Relief Requirements, authorized by Public Law 115-56 and Public Law 115-72 2017. Foundation for Puerto Rico is beholden of being recognized in the Action Plan, “as one of the multitude of civic stakeholders have played key roles in the immediate recovery efforts”. FPR is a 501(c)(3) local non-profit organization whose mission is to transform Puerto Rico through social and economic sustainable development

Below is FPR comments to the latest amendments o the Action Plans.

Planning Programs
a) Planning Coordination (Page 111)

As part of the work of the work of updating, reformatting, and improving the Hazard Mitigation Local plans community stakeholders should have the opportunity, including NGOs and Businesses, to engage in the development of the plan. The approval of the plan should require evidence of local stakeholder engagement in the planning process. The Hazard Mitigation Plan should also include a municipal government capacity assessment to align the plan with local needs.

b) Whole Community Resiliency Plan (Page 113)

Foundation for Puerto Rico recommends that the definition of a vulnerable community be framed by the vulnerability and resilience community profiles to be developed by the administering entities, which will incorporate hazard data (flood, hurricane, landslide and others) and exposure data (asset data, concentrated damage, census data, infrastructure data, health, education, economic revitalization, environment and others). A broader definition based on data available, will provide accurate representations of community vulnerability. Moving beyond traditional definitions of vulnerability and resiliency will reflect the actual needs of the community over the long term.

Comments on Eligibility Criteria

For the eligible criteria, the scope of what is reimbursable should be tied to the program guidelines, which define reimbursable activities as documented of staff time related to data validation and analysis around vulnerability and resiliency profiles developed in the initial phase.
Program Description (Page 114)

The identification of high-risk areas should utilize the vulnerability and resilience community profiles developed by the administering entities, which will incorporate hazard data (flood, hurricane, landslide and others) and exposure data (asset data, concentrated damage, census data, infrastructure data, health, education, economic revitalization, environment and others). These profiles can then be used to create an Online Dashboard to guide future local, regional and island-wide planning, recovery, mitigation and resilience efforts.

For Phase 2, the plans should be based upon the community vulnerability profiles that will be developed as part of Phase 1. These vulnerability profiles will encompass a broader definition of hazards that a community may face before, during, and after an emergency. Moreover, final plans should be based on data obtained from the vulnerability and resilience community profiles developed in the initial phase.

I. Economic Recovery Programs

a) Small Business Financing (Page 154)
Introduction (Page 169)
The DDEC should add to its commercial sector considerations the tech industry, as a separate core sector. The tech sector will allow the island to count with a global market of purchasers, it brings such importance that it needs to be considered individually.

Eligibility (Page 171)

All estimates included in the businesses’ recovery plans submitted by eligible companies should be measured on a quantitative base tied to qualitative assumptions, for example all forecasts should include assumptions based on market or historical experience. This also applies to page 174 under the section of Eligibility in relation to its 5th bullet point.

Distribution Method (Page 171 & 174)

FPR recommends adding to the process of method of distribution, besides the Governmental Bank of PR and DDEC, a Request For Proposal “RFP” that includes but is not limited to other financial institutions like cooperatives and non-profit organizations to ensure the participation of additional key sectors that are closer to the communities and have more reach outside of the traditional metropolitan area. These key players should be considered as having a very important role in the development of the island’s economy and seen as a support for DDEC.

c) Workforce Training Programs (Page 160)

Eligibility

FPR recommends increasing to $10,000,000 the amount of funds that can be administered through units of local government, non-profit organizations, and governmental and quasi-governmental agencies who will be invited to propose workforce training programs. Organizations that operate closer to the communities are familiar with the needs of local job markets and agile in the development of specialize training suitable for the particular market.

General Comments
Overall recommendation for Economy Recovery Programs: there needs to be an active and immediate plan in order to assure the timeliness of funds allocated to small businesses is accomplished. It should also include that the loans under this action plan are a chance for companies to improve their business credit and be able to have in the future more access to capital options in the future. All business economy recovery plans presented by eligible participants should be quantitative and qualitative drafted, prepared with market estimate assumptions and/or historical data. Funds received to create jobs or to keep active jobs should pay the employees at market value opportunity.

Marianne Ramírez Aponte

Museo de Arte Contemporáneo de Puerto Rico
Comment to Action Plan CDBG-DR
September 21, 2018

As a note on the outlined section for Economic Recovery Programs contained in the draft for the Puerto Rico Disaster Recovery Action Plan, the Museo de Arte Contemporáneo de Puerto Rico (MAC) would like to highlight the value of arts and culture as essential tools that can be leveraged for recovery efforts as well as for long-term economic development in Puerto Rico. Investing in our cultural infrastructure serves the dual purpose of stimulating local business activity throughout various communities and supporting a thriving visitor economy by enhancing Puerto Rico’s position as a global destination.

In the aftermath of Hurricane Maria, the MAC has recognized the profound impact that a coherent action plan involving arts and culture has on the economic recovery of affected communities. Empowering this sector is key in establishing resiliency and revitalizing local economic activity that can translate tangibly into exportable cultural products, but also supports marketing strategies that promote Puerto Rico as a competitive destination. Puerto Rico’s cultural capital should be recognized an indispensable asset to the tourism sector and the visitor economy, and thus contemplated as a valuable component of any economic development strategies implemented. On behalf of Puerto Rico’s cultural organizations and creative industries suggests that the CDBG Action Plan Draft for Public Comment issued on September 21, 2018 be further amended as follows in recognition of the contribution this sector can make in the island’s recovery:

Strategic Projects and Commercial Development
Include arts and cultural economic development projects as an additional “Program Accomplishment” and allocation additional funds to ensure that funding for additional projects will be available.

City Revitalization Program
Include arts and culture-related activities as activities incorporated within the revitalization goals of this program. The current Program Objectives includes “improvements to public space (plaza, town squares ), cultural and art installations. Specific funding should be set aside for direct funding to nonprofit cultural institutions to carry out these activities.

About the MAC:
The Museo de Arte Contemporáneo de Puerto Rico (MAC) is an artist-founded, collecting art institution located in the Santurce neighborhood of San Juan. It is devoted to the study, documentation, collection, preservation and promotion of art produced since the mid-20th century in Puerto Rico, the Caribbean and Latin America and by their respective migrations. The MAC has developed and implemented a wide range of community-based art and culture initiatives to bring cultural equity to economically vulnerable communities.

Yolanda Rodriguez

Gobierno Municipal de Vega Alta

Re: Solicitud de Fondos del Programa CDBG-DR para Desarrollo Económico

El 7 de marzo de 2018 el Municipio de Vega Alta (MUNVA) presentó una propuesta de solicitud de fondos del Programa CDBG-DR para proyectos identificados como de gran prioridad. El total de fondos solicitados es de $71,750,000.00, de los cuales $20,000,000.00 se destinarían a vivienda y $51,750,000.00 a infraestructura.

En dicha propuesta no se peticionaron fondos para Desarrollo Económico. Sin embargo, es de cardinal importancia el que se añada a la propuesta presentada este importante componente, especialmente en lo concerniente a crear las bases para atraer actividad empresarial. La razón tiene que ver con la gran cantidad de empresas y negocios localizadas en nuestro pueblo que fueron afectados por los huracanes.

Los fondos solicitados para impulsar el componente de Desarrollo Económico del MUNVA se utilizarían para los siguientes proyectos:

1. Reconstruir la estructura de El Morro para convertirlo en un parque industrial liviano con el propósito de fomentar el establecimiento de pequeñas empresas de diverso tipo

2. Adquisición de estructuras abandonadas que antes cobijaron empresas y negocios para reconstruirlas y mercadearlas a empresarios y emprendedores interesados.

3. Desarrollo de un Programa de Corporaciones Municipales, el cual se encargaría de fomentar el empresarismo y la asistencia técnica a empresas existentes.

4. Conversión de dos escuelas en desuso y que fueron transferidas al MUNVA, en oportunidades de negocios y de inversión.

5. Adquisición de dos escuelas pertenecientes al Departamento de Educación que se encuentran en desuso del barrio Maricao y Bajuras.

Israel roman martinez

Surcando la historia inc. Una organizacion de base comunitaria en focada no solo en la historia y cultura, sino que etanos enfocados en brindar servicios. Todo voluntario. Estamos trabajando en varios proyectos junto al municipio con un acuerdo colaborativo en lajas.
Una base kp4 comunitaria que sirva de enlace entre la comunidad y dependencias gubernamentales. Ya hay tres miembros con licencia Kp4 y otros GMRS. Soy WP4QCH.
Hemos pedido a l DE una escuela en comunidad rural de lajas candelaria, para convertirla en refugio permanente, almacen de suministros, centro comunal y salones de talleres educativos y centro tecnologico comunitario.
Ambos proyectos los estamos trabajando para que sea autosuficiente energetico y agua potable.
Hemos crado un bonding con otras organizaciones para tales eectos.
Un proyecto esencial lo es la reparacion del canal de riego del valle de lajas. Lleva dando servicio mas de 80 años y es poco el mantenimiento dado y dado el aumento en el area que sirve es indispensable para nyestra region y un poco de presupuesto para que agencias y organizaciones comunitarias empiezen a trabajarlo.
Las comunidades son esenciales en este proceso y no las creadas ayer para adquirir los fondos hoy. Eso hay que considerarlo. Para que juntos podamos yudar en el proceso.

Erika Ruiz

Comments to the Puerto Rico CDBG-DR Amended Action Plan
Enterprise Community Partners

Enterprise Community Partners, Inc. would like to applaud Vivienda on their continued outreach to the public on the happenings of the action plan, through informational bulletins, the dedicated website to CDBG-DR and publishing contracts on your website .Enterprise would like to formally submit our comments to the first amendment of the CDBG-DR action plan in response to 2017 Hurricanes Irma and Maria.

We recognize the challenge in designing programs to address a wide range of issues while additional information and data continues to paint a fuller picture of true community needs. Based on our experience and understanding of the need in Puerto Rico, as well as, the conversations we’ve had with communities on the island, many of our comments are focused on the following areas:

Resiliency: In reviewing the amendment, we recognized several missed opportunities to incorporate resiliency as a key theme for recovery.
Predevelopment Funding: Pre-development lending also does not have a clear allocation – a necessary process to bring organizations who need to be involved in implementation into this work.
Inclusiveness: To effectively serve low income groups who are most vulnerable, we would like to reiterate the need to establish a committee to ensure community engagement and inform residents on how their needs are being addressed and how the recovery effort is evolving..

Below are additional comments to the action plan. We welcome any opportunity to discuss our comments and be a resource to your agency. To discuss our comments, I can be reached at (202) 649-3927 or via email at eruiz@enterprisecommunity.org

Sincerely,

Erika Ruiz
Director, Enterprise Advisors

Comments

ADDITIONAL RESOURCE/GENERAL NOTE
In the last few weeks, The Blueprint report, Notes for a Planning and Public Policy Framework for Housing in Puerto Rico, prepared by the Center for the New Economy was released. It states that although the Recovery Plan and CDBG-DR Plan define actions, there is a need to embed these actions in a larger public policy and planning framework. The State Housing Plan (2014-18) is current until this year, we strongly recommend that is be updated as it is an important document to lay out the housing needs of people across the island and strategies for housing overall, not just programming of recovery resources.

ON CRITICAL INFRASTRUCTURE
• p. 15: While the document mentions flooding, winds and rain as potential risks and hazards that could lead to future disasters in Puerto Rico, more specific language to address seismic tremors and fire in all mentions of risks and hazards would be more comprehensive

• p. 179: Where the plan states it will support critical community infrastructure, to qualify its role and scope, we recommend the following: “infrastructure that will support communities and mitigate risk from natural hazards.”

• p. 179: Consider allowing for non-grey infrastructure like parks for flood mitigation or green-scaping, which enable adaptation to local conditions. Most eligible activities are traditional large-scale “grey” infrastructure, which are high cost, require a lot of regulatory approval and may not be viable or feasible in many communities.

ON TITLE SUPPORT
The document represents a continued lack of clarity related to titling and property registration, and how that may or may not be related to “Informal Construction:”
• p. 52: “Property title concerns” – property registry is not a requisite for construction or building to code. Nor is it related to the sub-heading: “High denial rates have left hundreds of thousands without critical assistance and a large unmet housing need.”

• p. 146: The document states that title services are not available to individuals in a flood plain. This contradicts the goal of rehabilitation programs that would require a title to move forward. Housing owners would need to prove title and ownership to get federal assistance – this could have a damaging impact.

ON METHOD OF DISTRIBUTION AND SELECTION CRITERIA
Non-profit organizations played a crucial role in responding to need after the hurricane and are in contact with the people and communities they serve. Non-profits should be able to play an important role and be able to access funds in the following programs mentioned in the CDBG-DR Plan:
• Whole Community Resilience Planning.
• Home, Repair, Reconstruction, or Relocation Program
• Title Clearance Program
• Community Energy and Water Resilience Installation Program
• Multifamily Reconstruction. Repair and Resilience
• Construction and Commercial Revolving Fund
• Small Business Financing. – Non-profits also need assistance in strengthening their administrative and operational capabilities to address need, they already are doing the work, but impact is hindered by lack of funding. There should be a program, similar to this small business financing, that addresses critical capital needs to be able to recover and grow their organizations, create and retain jobs and meet triple bottom line goals that will further reconstruction.

Pre-development funding: a program should be designed to support non-profits housing developers carrying out SHF and multifamily development. These organizations need pre-development capital to get them to construction loan closing. A pre-development fund should be created to assist these organizations through this phase of development. Pre-development funds could be managed by FIDEVI or a similar organization that have experience in underwriting projects. CDBG-DR funds could be assigned as grants to these sub-recipients which would then structure pre-development loans to non-profit organizations.

• For the sub-recipient distribution model and the partner distribution model, four criteria are mentioned, including “Meet all established performance goals.” These are not included in the action plan.

• p. 123: Selection criteria is of particular concern in the section on Whole Community Resilience Planning, which states that the Foundation for Puerto Rico has been selected to receive and administer $55,000,000. Overall, what is the process to select partner organizations? Since there were no requests for proposals for this program and others that name a partner, a justification or methodology should be included as to how they were selected for full transparency.

ON COMMUNITY PLANNING
• pp. 111-12: The Planning Programs outlined make no reference to existing plans, such as the Puerto Rico Land Use Plan adopted in 2015, and no reference to Municipal Territorial Plans, which many municipalities adopt.

• p. 112: The section on Municipal Planning does not specify who will carry out and implement activities of planning. Will PRDOH be the main implementation arm? If so, we recommend partnering with local CDCs and planning divisions on the ground and work within the framework of the Land Use Plan and Local Municipal Plans under the Planning Board. This is an opportunity to take a whole building approach to the effort. How will the municipal planning activities align with whole community resiliency plans explained further in this section?

• p. 113:
o Under the Whole Community Resilience Planning program, awards of up to $20,000 may be distributed. This amount is far too limited to allow for serious community planning. This is not enough for a full-time staff member, which is what this effort will require, for a minimum of three years. Salaries should be commensurate with living wage, and it is important that there be a lead and an associate to help coordinate the planning.

o Additionally, there should be a technical advisory consultant or team assigned to support staffers leading the community planning effort. Lastly, if there Is a regional planning component, we recommend that there is appointed staff to lead this effort as well.

o There is a mention in the document that some communities may receive up to $500,000 through a competitive process. Please consider adding additional details to the description. What communities might be eligible? Who will guide the competitive process?

• P.114:
o Please consider the Planning Board as a partnering entity since they are eligible per the definition of partners in page 96 which identifies that partners are governmental agencies or governmental organizations. To foster local planning, these local planning efforts should be integrated or aligned with local municipal plans and the land use plan of Puerto Rico. We recommend that population and need be priorities for assignment of Whole Community Plan awards.
• p. 175:
o “HGMP funds will comply with FEMA resilience standard:” Ensure that FEMA has a resilience standard that fits the profile of Puerto Rico, particularly with eye toward housing vernacular and cultural sensitivities present in communities. It is important to ensure that communities are participating in defining that standard and invested in the solution. Additionally, it is important to define community “resilience” in accordance with community standards.

o FEMA priorities should reflect priorities set forth by Reimagina, as well as other community-based planning projects.

• p. 180: Community Resilience Centers are an excellent and comprehensive approach. We need to ensure that centers are retrofitted to withstand all hazards and wind loads at a Category 5 hurricane.

ON DISPLACEMENT
One of the overall program requirements is “Minimizing Displacement.” However, throughout the document, there are several contradictions related to mitigation, and a policy of displacement as the last option before new construction. On p. 101: “The programs as currently designed in the action plan are focused on moving families out of harm’s way.” See also the newly introduced program for an international design competition, titled “Puerto Rico by Design,” destined for strategic areas devastated by the hurricanes.

ON HOUSING
Vacant Housing: Puerto Rico has a huge vacant commercial and residential property issue. This was the case before Hurricanes Irma and Maria, but it has worsened as many people have left the Island for the mainland for a variety of reasons. These vacant properties can be rehabilitated to provide much needed affordable housing and for new businesses that can help the local economy. While the various programs within the action plan reference rehabilitation of properties as eligible uses, there isn’t a clear program addressing vacant properties. The greater challenge is the identification and classification of vacant properties in order to activate them if appropriate. Inventory of vacant properties island wide and at the municipal level requires planning and strategy efforts with support from various state agencies.

ON RENTAL ASSISTANCE
While providing funding for Law 173 projects through the Rental Assistance Program is important and extremely helpful in assuring continuing operating subsidy so there aren’t additional seniors in unstable housing situations. Unfortunately, considering the high level of low income populations in Puerto Rico, rental subsidy is an essential resource to enable extremely low-income households to access housing. While utilizing the 4% LIHTC program for the production of housing is important, layering CDBG-DR funding in the form of rental subsidy can allow for additional funding leverage through increased debt capacity and serve the lowest income populations who don’t have many other options. Production of tax credit units without dedicated subsidy only addresses some of the affordable housing supply gap.

ON HOMEBUYER ASSISTANCE PROGRAM
This newly introduced program does not reflect how it will be integrated with other programs.
• Will it be targeted toward individuals who must face displacement, including low-income families?
• Is there data available that shows how first responders have suffered from housing loss and/or must relocate due to flooding?
• Will it be programmatically tied into the policy of reusing vacant housing in the traditional urban centers?
• Land Banking Strategies are not funded under the plan.

ON HOME RESILIENCE PROGRAM
Which department at university is administering this, and do they have the capacity to do so? Is it a cross-divisional team of engineering, planning and architecture?
• Why is program limited to energy and load? It should include a holistic approach to building and utilizing state-of-the-art building science and efficiency principles that encourage efficient building envelopes, siting of residential facilities and utilization of best practice methods in design and ventilation. Enterprise is developing a guide that should be considered as a precursor to the origination of this Guidebook.
• Additionally, what other private sector and technical assistance (TA) partners will be brought in to support this effort? The university should consider creating an advisory committee of experts to inform the approach and tap resources at the federal agencies working in energy and efficiency, such as NREL and DOE.
ON HOME REPAIR PROGRAM
• Why are only single-family homes qualified? Multifamily housing should be qualifiable as well.
• Priority groups recommended include single head of household, along with elderly, and individuals with medical needs.
• This program is only for substantially damaged housing. Setting aside funding for moderately damaged housing, which would be less than 50 percent of the value of the home repair, would also allow for significant home improvements.
• Assessing homes will be a difficult task when homes are not built to code or are self-built. It is critical that teams be qualified to assess housing and that they possess a strong understanding of housing in Puerto Rico.
• The program should also consider if a damaged home was not in the flood zone, but still experienced substantial damage. Maria was a large wind event, and this type of damage should be accounted for, as should precipitation.
• Eligibility threshold for substantially damaged should be revised. If the repairs exceed $60k, and the cost to make it livable again is $70k, it makes more sense to do rehab than total reconstruction.

HOUSING COUNSELING PROGRAM
Housing counseling should include counseling on home repair and fortification. Enterprise is working with partners throughout Puerto Rico, including Habitat for Humanity, PR Builders Association, University of Puerto Rico and a slate of other partners to develop guides and a training program that can be used to promote this effort. Enterprise launched a home resilience counseling program after Superstorm Sandy to provide owners of low- and moderate-income housing with guidance on repairs and scoping for rehab that would fortify homes. Enterprise will gladly share program details with the team.

COMMUNITY ENERGY PROGRAM
• Stipulate if solar thermal and solar electric are eligible for the program. It appears solar thermal is eligible, since there is recognition of hot water, but this is point is important to clarify.
• Will there be a need to pare other rehab programs with site to fix and repair roofs, so solar panels can be installed? Similarly, with water catchment – will there be a commensurate repair budget provided or pared with a rehab program? Is there potential for incentives through utilities to expand resource for families?
o Will there be a requirement to tie to grid or is there a stand-alone option for PV?
o What is going to be considered eligible under the 6K rebate/grant for energy systems – will it be panels, invertors, batteries for the energy systems?
o What is going to be considered eligible under the 6K rebate/grant for water systems – will it include tanks, attachments, pumps, filtration devices and water efficient fixtures?
o The program should promote efficiency in concert with renewable energy deployment and ensure that each household has an efficient energy “grid” in place so that renewable energy resources can be maximized.
• How is the PPPE qualified to provide technical guidance on the program development? The program should consider bringing in DOE or other federal or local agency with technical expertise.

AGRICULURE RESILIENCE
• Promoting agricultural resilience and food security is an important step forward. It is also important to blend with farm-to-market opportunities and the ability to get locally sourced and grown produce to market, encouraging economic support for smaller farmers.

• Greenhouses can be resource- and structurally-intensive, particularly in urban areas. Consider conducting feasibility studies of this idea and continue to promote soil-based crops.

REBUILD BY DESIGN
We commend Vivienda for embracing the model of design competition to foster best-in class thinking about keeping the island safe from future natural hazards and storm events, as was successful after Sandy.

• Public engagement is a critical component to being able understand program impacts and get real time feedback on progress. Establishing a committee of various stakeholders and community groups that would serve as a resource of information and have ongoing engagement. In other communities impacted by disasters, these committees have been extremely helpful thought partners to CDBG-DR grantees.

• Citizens Advisory Council is an important idea that has been discussed by the Housing Department Secretary and should formally be included in the Action Plan and the Citizen Participation Plan. What will be its role? Who should participate? What will be the scope? How will members be appointed? All of these are questions to consider. Representative of different sectors like local Foundations, CHDOs, non-profit housing developers, industry associations, professional groups, financial institutions and community-based organizations should participate in the Council.

• p. 130: In the section on the Title Clearance Program, there is no detail as to a course of action, only a reference to Puerto Rico’s Recovery Plan HOU 12. This document and its details are not yet available. For such a critical program, it is recommended that more public hearings be held when such a document becomes available.

• P. 116: Again, there are no details provided on a course of action for “Agency Planning Initiatives,” which references six courses of action in the Recovery Plan.