Advertising Questions

Question:
Do I have to advertise if the city later funds a strategy that is currently unfunded, like our disaster strategy?
Answer:
Yes, you should advertise. When you first advertise upon receiving your new SHIP allocation in July, you can advertise that the city has a disaster strategy that will be funded pending a disaster or need. This will fulfill the requirement in Florida Statutes: "The county or eligible municipality or its administrative representative shall advertise the notice of funding availability in a newspaper of general circulation and periodicals serving ethnic and diverse neighborhoods, at least 30 days before the beginning of the application period. If no funding is available due to a waiting list, no notice of funding availability is required." Section 420.9075 (3)(b)Florida Statutes However, even in this case, you might still want to further advertise and inform your community about the disaster strategy once a disaster occurs.

Question:
Can I advertise for my next year's funds at the beginning of June, so I can take applications 30 days later on July 1 when I start to receive funds from the next allocation year?
Answer:
Yes you can. The advertisement requirements are outlined in the Statute and in greater detail in the Rule: 67-37.005 (6)(a).

Question:
After the last hurricane, we made use of the State’s SHIP disaster strategy to provide recovery assistance. Should we prepare now for the possibility of a future disaster by advertising that SHIP funds may be used for disaster response if such a disaster occurs?
Answer:
Since your jurisdiction is not currently experiencing a disaster, you have not currently budgeted
any funds for disaster recovery. Yet it may be a good practice to advertise now, as you suggest, for the possibility that SHIP funds may be spent for disaster recovery if such a disaster occurs in the next year. After all, the SHIP Statute requires you to advertise the specific ways you will use your SHIP funds at least 30 days before accepting applications for a specific type of assistance. In the past, you made use of the State’s general SHIP disaster strategy, which was created in response to the hurricane disasters of 2004. For the period when an executive order or emergency rule is active, any jurisdiction may provide all the types of disaster assistance that are outlined in the State’s disaster strategy—even if the same type of assistance does not exist in the jurisdiction’s current local housing assistance plan. Remember, however, that Florida Housing now requires each SHIP jurisdiction to include a disaster strategy within its local housing assistance plan. This requirement was recently added to section 67-37.005(7) of the SHIP Rule. You could consider adopting Florida Housing’s standard strategy language. If you do this, make sure to omit any emergency rule language about assistance that is not normally allowed under the regular SHIP Rule or Statute.

In the past, the Housing Coalition has offered a workshop on Disaster Preparedness. The three stages of disaster recovery are Emergency Response (providing emergency shelter), Relief (short-term housing) and Recovery (rebuilding). The design and requirements of most housing funds used by the workshop participants do not allow them to be first responders. While SHIP funds may be used to purchase blue plastic tarps, for example, the purchase of generators and gasoline is outside the boundary of eligible expenditures. Instead, affordable housing program resources are most valuable during the Recovery phase of emergency response. Many housing strategies that have become common across Florida are focused on long-term housing recovery , including rehabilitation, housing replacement, and the new construction of multi- and single family housing.

Disaster preparedness involves adopting a disaster strategy that offers a variety of aid, from temporary repair and payment of insurance deductibles, to rental deposit assistance. Advertise its availability now. In addition, prepare a Request for Quote (RFQ) to identify contractors, document their rates, and prepare to quickly mobilize them to help clean up after a disaster. It becomes more difficult to locate competent contractors once disaster strikes. Several workshop participants have witnessed this first hand. They have observed the recent decline in contractor interest for participating in their emergency repair and rehabilitation programs. Some, including the housing staff in Highlands County, have successfully attracted contractor attention by “bundling” together several repair jobs. Highlands County bid out 20 single-family units for rehabilitation, and received competitive responses from six contractors. Effective disaster response begins with planning. Contact the Coalition at (800) 677-4548 for further assistance with considering how to prepare your community.


Question:
On July 1, my county will begin receiving its new allocation of SHIP funds. I know that the county is required to advertise the availability of funds and begin taking new applications, but I have long waiting lists for all of my SHIP strategies. Will this give new applicants unrealistic expectations, when it will actually be some time before they receive assistance?
Answer:
In your community’s case, you do not have to advertise at this time, since you have a waiting
list. This exemption is outlined in section 420.9075 (3)(b) of the SHIP Statute, which addresses local housing assistance plans: “The county or eligible municipality or its administrative representative shall advertise the notice of funding availability… at least 30 days before the beginning of the application period. If no funding is available due to a waiting list, no notice of funding availability is required.” The statute is not specific about exactly how long a waiting list must be before you are not required to advertise. For this reason, your community should create its own policy on this issue. The frequency at which new applications are taken should be based on considerations like the rate at which you expend funds, how long it takes to process applications, the pace of the contractors you work with, and more.
Of course, a community might have a waiting list for one strategy, but not another. In this case, the community must advertise the availability of funding for the strategy with no waiting list. Furthermore, you should consider advertising now for strategies that are currently not funded, in anticipation of funding them sometime within the next year. A disaster mitigation strategy is the most common example of this situation. Such a strategy provides repair assistance in the aftermath of a natural disaster. By advertising now —even if the strategy is currently unfunded — your community will not have to comply with the 30-day advertising requirement at the time when a disaster strikes and a quick response is critical.

Follow-up Question:
If a jurisdiction does not have a waiting list and will advertise the availability of funds, does the jurisdiction have to wait to receive the first check of its next allocation before advertising?
Answer:
No. As noted in the SHIP Statute, you must provide 30 days of notice before taking new applications for SHIP assistance. Since you know that July 1 marks the day when you will begin to receive your new allocation, you may advertise starting as early as June 1. This will allow you to start taking applications on the day you receive new funds.