Fiscal Year 2015 Indian Community Development Block Grant

Fiscal Year 2015 Indian Community Development Block Grant (ICDBG) Program NOFA Training 1

What’s New in 2015 • • • No HUD Policy Priorities Points for PZs and SCs Points for involving community More if using funds to acquire land More statements of what will be done 2

Today’s Agenda • Purpose and overview of ICDBG • Eligible applicants, uses and requirements • How to submit applications and avoid pitfalls 3

Today’s Agenda (cont) • Screening and rating factors • Criteria in NOFA – definitions, rating factors, scoring • Where to find help 4

Available Funds • FY 2015 appropriation = $60 M • Competitive Grants - $58, 856, 810 (includes carryover) • Imminent Threat - $3, 960, 000 5

Authority • Title I of the Housing & Community Development Act of 1974 (42 U. S. C. 5301 et seq) • ICDBG regulations, 24 CFR part 1003 6

Program Description To develop viable Indian and Alaska Native communities by creating decent housing, suitable living environments & economic opportunities primarily for LMI persons 7

Types of Grants • Imminent Threat Grants • Single Purpose Grants for many community development purposes 8

Imminent Threat Grants • No Area Office allocations • Funds used to remove imminent threats to health or safety • Must meet regulatory criteria 9

Imminent Threat Grants • Criteria for funding – Threat not recurring – Must be unique and unusual circumstance – Must impact entire service area – Project feasible and has reasonable chance of alleviating problem 10

Imminent Threat Grants • Submit to Area ONAP – SF-424 – Description of threat – Independent verification of threat – Detailed budget and form HUD-4123 – Evidence of completion in 12 mos. – Tribal resolution re: no other funds 11

Imminent Threat Examples • • • Asbestos removal Replacement of failed water system Home repairs from floods Mold remediation Uranium in wells 12

New Definitions • Community Based Development Organization = cites regulation at 1003. 204(c) • TDHEs are not automatically eligible • Check with Area ONAP if already determined to be one 13

Old but Key Definition • New Applicant – An applicant who has never received an ICDBG or whose grants have been closed for more than 12 months prior to application deadline date 14

Single Purpose Grants Allocations • HUD allocates funds to six Area ONAP regions • Based on a regulatory formula (24 CFR 1003. 101) 1. Allocate $1 M to each region 2. Allocate the remaining based on each region’s share of tribal population (40%), poverty (40%), and overcrowding (20%) 15

Allocation By Region Eastern Woodlands Southern Plains Northern Plains Southwest $4, 648, 764 $13, 989, 642 $8, 842, 084 $20, 912, 558 Northwest Alaska $3, 188, 032 $7, 275, 730 16

Grant Ceilings • Grant ceilings apply to entire application • One of the screening factors • If exceeded, application not rated 17

Grant Ceilings • • Eastern Woodlands Southern Plains Northwest Alaska $600, 000 $800, 000 $500, 000 $600, 000 18

Grant Ceilings • By Population – Northern Plains = $900, 000 - $1. 1 million – Southwest = $605, 000 - $5. 5 million (only one tribe) 19

Housing Rehab Cost Limits Eastern Woodlands Southern Plains Northern Plains Southwest Northwest Alaska $35, 000 $50, 000 $65, 000 $50, 000 $75, 000 20

Regulations and Requirements • If funded, must comply with regulations, guidelines and requirements of the ICDBG program and regulations referenced in ICDBG regulations 21

Eligible Applicants • Indian tribe, band, group, or nation including Alaska Indians, Aleuts and Eskimos and any Alaska Native Village • Tribal organizations submitting on behalf of tribes 22

Period of Performance • Based on the Implementation Schedule and must be approved by HUD • Required under Rating Factor • Starts In Feb, not Nov 23

Cost Sharing or Matching • Not required for ICDBG • Points awarded for leveraging • ICDBG can be used as match for other programs 24

Threshold Requirements • HUD Thresholds in General Section • Program-Related Thresholds in ICDBG NOFA • Project-Specific Thresholds now called requirements 25

FY 2015 General Section • Applies to all HUD grants • Posted in October 2014 • Found at http: //portal. hud. gov/hudportal/HUD? src=/pro gram_offices/administration/grants/fundsavai l/2015 gensec 26

General Section • Some terminology changed from 2014 • Two thresholds now Ø Timely Submission of Applications Ø Resolution of Civil Rights Matters 27

General Section Requirements • Tribes must comply with four nondiscrimination and related requirements Ø Fair housing and civil rights Ø Section 3 Ø Access for limited English Ø Accessible technology 28

Other Requirements • Could prevent award to successful applicants – Ø Outstanding Delinquent Federal Debts Ø Pre-award accounting system survey Ø Debarments and/or suspensions Ø False Statements 29

Other Requirements Ø Do Not Pay Website Review Ø Code of Conduct – Ethical Standards Ø Prohibition against Lobbying (only applies to TDHEs established under state law) 30

Other HUD Requirements • Ensuring participation of small businesses • Equal access for sexual orientation, gender, marital status • Faith-based requirements • Uniform Relocation Act 31

National Policy Requirements • • Procurement of Recovered Materials Participation in HUD evaluation Environmental requirements OMB Requirements – No longer in Circulars but in 2 CFR part 200 32

National Policy Requirements • • Drug-free workplace Safeguarding resident/client files Compliance with Transparency Act Physical Accessibility 33

Program-Related Thresholds • Outstanding ICDBG Obligation • Compliance with Fair Housing and Civil Rights Laws 34

Project-Specific Requirements • Housing Rehabilitation • New Construction • Economic Development 35

Housing Rehab Requirement • Must STATE that – – Applicant has adopted rehab policies – For HO units - that applicants payments are current 36

Housing Rehab Requirement – That units will be occupied by LMI upon completion – If no statements, applications not reviewed 37

New Housing Construction Requirement • • Developing entity is a CBDO State that applicant has construction standards No other housing is suitable -- AND No other sources (including IHBG) can meet needs -- AND 38

Housing Construction Requirements • Rehab not economically feasible • Household is currently overcrowded, OR • Household to be assisted has no current residence • NOTE -- If this information is not included, the application will not be reviewed 39

Housing Construction Requirements • Don’t just repeat what is in the NOFA • Explain the need for new housing in accordance with requirements of NOFA 40

Economic Development Requirements • Financial analysis prepared by qualified party must demonstrate project is feasible and has a reasonable chance of success • Show public benefit of ICDBG More requested = greater public benefit demonstrated 41

Economic Development Requirements • Grant will not reduce non-federal funds • Not more than a reasonable rate of return on investment is provided • Grant will be disbursed on pro-rata basis with other funds 42

Other Project Requirements • Spelled out in rating factors – – Homeownership Assistance Land to Support New Housing Microenterprises Public Facilities and Improvements 43

Public Service Projects • Limited to 15% of grant request • Must be a new service or increase existing service • Can not be a “stand alone” project • Need not be related to other activities 44

Eligible Activities • 24 CFR Part 1003, Subpart C • Section III. C. 4 of ICDBG NOFA • Rating Factors 2 and 3 45

Eligible Activities Most Common Activities: • • Housing Rehabilitation Land Acquisition for New Housing Homeownership Assistance Public Facilities & Improvements 46

Other Eligible Activities • • Acquisition of Property – also housing units Clearance and Demolition Lead-based Paint Evaluation/Hazard Control Privately and Publicly Owned Commercial or Industrial Buildings • Mold remediation 47

Eligible Activities • New Housing Construction may only be implemented through a Community Based Development Organization (CBDO) 48

Documenting a CBDO (Option 1) • • Socially oriented non-profit Board represents community Free to procure Not subject to reversion of assets 49

Documenting a CBDO • • (Option 2) Section 301(d) of Small Business Investment Act entities SBA approved entities HOME Community Housing Development Organization (CHDOs) Tribal-based community development nonprofit 50

Documenting a CBDO (Option 3) • Similar to Option 1 and 2 Example: - Has all characteristics as 1 but cannot find board with 1/3 or less public officials • TDHEs not automatically CBDOs 51

Eligible Activities Housing Rehabilitation – Rental or homebuyer – Publicly/privately owned – Grants, loans, guarantees, interest supplements – Multiple activity types – Labor, materials, principal fixtures, security devices 52

Eligible Activities Land Acquisition – In conjunction with Housing, Public Facilities & Improvements, Economic Development – Land alone can be acquired for future housing development only 53

Eligible Activities Homeownership Assistance – Only for LMI households – Subsidize interest/principal – Acquire guarantees from lenders – Up to 50% of down-payment – Pay reasonable closing costs – Eligible activity vs. public service 54

Eligible Activities Public Facilities & Improvements – Community Facilities – Special Needs Facilities – Infrastructure 55

Eligible Activities Economic Development • Acquisition, construction, rehabilitation or installation of bldgs or equipment • Assistance to non-profit and for profit organizations • Special requirements for-profits 56

Eligible Activities Microenterprises • Owner must be LMI and have five or fewer employees • Funds used for grants, loans, TA, and general support • No 15% public service cap 57

Eligibility of Government Facilities • Depends where services are provided • Police stations, jails, libraries = eligible • Courthouses, local government offices and other government headquarters = not eligible 58

Ineligible Activities • Maintenance & Operations • New housing construction, unless carried out by a CBDO • Furnishings and personal property • Construction tools/equipment • Income payments 59

How to Apply 60

Application & Submission Information can be found in: • General Section (Section IV) • ICDBG NOFA (Section IV) 61

Application & Submission General Section • Review General Section • Applications must be submitted electronically, via Grants. gov unless waiver is granted 62

Electronic Submission Waiver • Waivers only granted for cause • Submit request in writing with explanation • Examples: lack of available Internet access in rural communities 63

Electronic Submission Waiver • Waiver must be submitted 15 days prior to application deadline date • Send waiver to your Area ONAP Administrator and include good cause for waiver 64

FY 2015 General Section • Applies to all HUD grants • Posted in October 2014 • Found on HUD’s grants webpage and also with ICDBG NOFA download 65

Grants. gov Information • Helpful information on website • Click on “Applicants” to find – Applicant Tools and Tips – Applicant FAQs – User Guides, Organization Registration Guide, and educational videos 66

Register Your Organization • Obtain a DUNS Number • Register with the SAM • Register in Grants. gov with user name and password • Grant approval to submit • Check status 67

Step 1 – DUNS Number • • Most applicants have already Use the # for the entity applying Carefully type the # when registering If no number get one at: – http: //www. dnb. com/get-a-dunsnumber. html? serv=UP-HP-07082014 -new 3 68

Step 2 – Register with SAM • All who get funds must register and renew every year • To register go to: – https: //www. sam. gov/portal/SAM/#1 • Designate an E-Biz POC who can authorize submission of applications 69

Step 3 – User Name and PW • Create a profile in G. gov • Input email address that G. gov should use • Choose secret Qs and As • E-Biz POC is then notified 70

Step 4 – Approval to Submit • EBiz POC must log in and designate AOR • See checklist on G. gov webpage • Sometimes E-Biz POC and AOR can be same person • E-Biz POC can see SAM expiration date 71

Step 5 – Check AOR Status • Should get email of AOR status • Can check status anytime under “Quick Links” • Remind E-Biz POC to designate AOR if not done 72

Download Application • Go to www. grants. gov • Browse by agency or • Search by CFDA number (14. 862) or Funding Opportunity Number (FR 5900 -N-23) 73

Electronic Submission Adobe Reader • Check if your Adobe Reader is compatible with Grants. gov • Adobe Reader is free and available at http: //get. adobe. com/reader/otherversions. c om 74

TA - Electronic Applications • Grants. gov Customer Support: http: //www. grants. gov/contactus. jsp • Technical Problems: support@grants. gov or 800 -518 -4726 75

TA Electronic Applications • Always call Grants. gov helpdesk first • Then Roberta in headquarters if all else fails 76

Submission Dates and Times • • 11: 59 pm on October 22, 2015 Confirmation of Submission Application Submission Validation check Application Validation & Rejection Notification 77

Submission Grace Period • Applicants again have a 1 -day grace period to resubmit applications • Applies if application submitted before deadline and time and receive a rejection notice • Does not apply to paper applications 78

Successful Submission? • Don’t assume all is fine once you hit “send” • Make sure you get and save confirmation emails from grants. gov • Log on to check what was submitted 79

Successful Submission • New in 2015 is ability to see what documents were submitted, not just that application was. • Go to “Check My Application Status” • You can review and download them 80

Reasons for Rejection • • • Invalid DUNS Number Password ID Mixup Not authorized to submit Virus detected SAMS registration not current 81

What to Submit 82

What To Submit • Checklist now organized by what to submit for all types of projects and what to submit for certain projects 83

Submissions for All Projects • Narrative to five rating factors – and one page summary • Applications for Assistance (SF-424) • Disclosure Update (HUD-2880) 84

Submissions for All Projects – Budget - Cost Summary (HUD-4123) - Planning and admin cannot exceed 20% of grant - Only with physical development - Broken down by project - Don’t include costs related to project - Indirect costs comply with OMB regs 85

Submissions for All Projects • Tribal resolution on citizen participation for the application being submitted • Low- and moderate-income (LMI) beneficiaries (if not included, application not rated) • Way to measure LMI varies by type of project 86

Measuring LMI Benefit (Area Benefit) • Activities that benefit all residents of an area where at least 51% of residents are LMI persons • Area must be primarily residential 87

Measuring LMI Benefit (Limited Clientele) • • Clientele presumed to be 51% LMI 51% of surveyed participants are LMI Participation limited to LMI Nature of activity/location indicates LMI benefit 88

Measuring LMI Benefit (Housing) • Residential structures provided/improved must be occupied by LMI persons – Single family structure - LMI occupancy – One unit of duplex - LMI occupancy – Structures w/3 or more units must have at least 51% LMI 89

Measuring LMI (Job Creation/Retention) • Activities must create or retain permanent jobs and • 51% of jobs created/retained must be available to or held by LMI persons 90

Measuring LMI Area Benefit • There are seven options – Primary Option – old way w/new data (1 option) • Standard ICDBG LMI data from the ACS, all people in tribal areas – Other tribal area options (2 options) • AIAN LMI data from the ACS, all HH alone or incombo 91

Measuring LMI Area Benefit cont… • Neighborhood level options (3 options) – Standard CDBG LMI data from the ACS, all people (1 option) – AIAN LMI households from the ACS (2 options) • Applicant generated data per NOFA 92

Measuring LMI – More Info • Website for data downloads – http: //www. huduser. org/portal/icdbg/ho me. html 93

Applicant’s Own Data • Data must meet this criteria – Be collected systematically – Be independently verifiable – Differentiate between reservation and BIA service area population where applicable 94

Applicant’s Own Data • Must submit – Explanation of number of people benefitting from project and number of LMI – Sample copy of survey form – Explanation of methods used to collect data – Listing of incomes by household and size 95

Submissions for Certain Projects • HUD-2993 (for paper applications) • Resolution for tribal organization to submit on behalf of tribe • Resolution on housing standards for NC or HR 96

Submissions for Certain Projects • Resolution on tribal funds committed • Demographic data if census data not “right” • Information when acquiring land for housing • Health care facilities 97

Submissions for Certain Projects • Correctional facilities/detention centers • Code of Conduct • SF-LLL on lobbying 98

Rating Factors 1. 2. 3. 4. 5. Capacity of the applicant Need/Extent of the Problem Soundness of Approach Leveraging Resources Comprehensiveness and Coordination 99

Rating Factors • Have been changed slightly from 2014 • Review table in Section V. A. 1 of the NOFA 100

New Bonus Points • In 2015, 2 bonus points for working in a Promise Zones or Preferred Sustainability Community • Must submit forms signed by POC for each • See V. A. 1. of General Section 101

Rating Factors • Applicants must score a minimum of 70 points to be funded • Cut off for most Area ONAPs is much higher • Points vary if current or new applicant 102

Factor 1 – Capacity • Up to 30 points in total • If funded this year, progress will be measured • If funded in past years, lack of progress will = fewer points 103

Subfactor 1 Managerial, Technical & Administrative Capacity • 15 points current grantees / 30 points new • Possess or can obtain managerial, technical or administrative capacity to carry out proposed project • Identify who will administer project 104

Subfactor 1. a. - Managerial & Technical Staff • 8 points current or new • Describe roles and responsibilities of project director and staff • Experience of all key staff must be relevant, recent, and successful 105

Subfactor 1. b. - Implementation Plan • 3 points current grantees / 8 points new • Identify specific tasks and timelines for completing project • Two projects = two plans • Full points if project can start within 180 days funds are available to grantee 106

Subfactor 1. c. - Financial Management • 2 points for current grantees / 7 points for new • Describe how financial management systems of applicant, CBDO and subrecipient address essential elements of 2 CFR 200 and 24 CFR 1003 • Seriousness/significance of open findings • Current audit if required 107

Subfactor 1. d. - Procurement/Contract Mgmt • 2 points current grantees / 7 points new • Describe how policies and procedures of applicant or organization meet requirements of 2 CFR 200 and 24 CFR 1003 • Findings related to procurement & contract management • Current audit or letter from IPA 108

Factor 1, Subfactor 2, Past Performance • 15 points for current grantees/new applicants not rated here – (a) Implementation/Expenditures (more points if faster spending) (3 pts. ) – (b) Reports (3 pts. ) 109

Subfactor 2 - Past Performance – (c) Close-outs (3 pts. ) – (d) Audits (3 pts. ) – (e) Findings (3 pts. ) 110

Rating Factor 2 Need/Extent of Problem • • Total of 19 points Subfactor 1 - Need and Viability (4 pts). Subfactor 2 – Unfunded applications (3) Subfactor 3 - Project Benefit (12 pts) 111

SF 1 – Need & Viability • Application should include information on need for the project and demonstrate that it meets an essential community development need and is critical to the viability of the community 112

SF 2 - Unfunded Applicants • To spread funds around applicants who have not received a grant in recent years will receive points • Three, two, or one point • Only applies to new applicants 113

SF 3 - Project Benefit • Calculation depends on type of project • Carefully review criteria for each type. 114

Subfactor 2. a. - Public Facilities and Improvements • Up to 12 points • Several options for determining need – CDBG data or ACS data OR • Information or unpublished data that meets certain criteria 115

Public Facilities & Improvement Projects At least 85% LMI At least 75% but < 84% LMI At least 55% but < 74% LMI Less than 55% 12 points 8 points 4 points 0 points 116

Subfactor 2. b. - Economic Development • Beneficiaries are persons served, employed by project, jobs created or retained • Submit census data or other data as explained on earlier slide • Points given are identical to those on previous slide 117

Subfactor 2. c. Housing Construction and Rehab, Land Acquisition for Housing and Homeownership Based on 2015 IHBG formula data $0 - $750 $751 - $1, 250 $1, 251 - $3, 999 $4, 000+ 12 pts 8 pts 4 pts 0 pts 118

Rating Factor 3 Soundness of Approach • Up to 33 points • Address quality/effectiveness of project to enhance community viability, meet identified needs, and sustain the project 119

Rating Factor 3 Soundness of Approach 1. Description & Rationale for Proposed Project (12 pts) 2. Budget & Cost Estimates (9 pts) 3. Commitment to Sustain Activities (12 pts) 120

Subfactor 1 Description and Rationale for Project • Up to 12 points • Describe your project • Describe how project will address identified need • Describe how project will enhance community’s viability 121

Subfactor 2 - Budget & Cost Estimates • 9 points • Include cost breakdowns by line item (including planning & admin) • Include cost estimates and describe qualifications of person(s) who prepared the estimate(s) 122

Subfactor 4 - Commitment to Sustain Activities • Up to 12 points • Demonstrate commitment to community’s viability • Criteria varies by type of project 123

Subfactor 4. a. (Public Facilities/Improvements) • Up to 12 points • Provide statement that tribe or “entity other than tribe” has adopted/developed O&M Plan and commits funds for those responsibilities 124

Subfactor 4. a. (Public Facilities/Improvements) • Must addresses maintenance, repairs, insurance, security & replacement reserves & include cost breakdown • Buildings must show operating funds for services • Service providers submit commitments for operating and space needs 125

Subfactor 4. b. (New Housing Construction, Housing Rehabilitation, Homeownership Assistance Projects) • Up to 12 points • Identify tribal and/or participant’s maintenance responsibilities • Describe responsibilities and provide written commitment to undertake 126

Subfactor 4. c. (Economic Development) • For up to 12 points describe: – How the project will operate – Why it is needed – How it will succeed 127

Subfactor 4. d. (Microenterprises) • For up to 12 pts describe how program will operate • Include types of assistance offered and entities eligible for assistance • Describe process for selecting applicants and analyzing business plans 128

Subfactor 4. e. (Land Acquisition to Support New Housing) • Up to 12 pts • Show that proposed site has: – Suitable soil conditions – Potable drinking water – Access to utilities, vehicular access, drainage, services, and no environmental problems 129

Rating Factor 4 Leveraging Resources • Up to 8 points • HUD will award points based on % of non-ICDBG funds relative to total project cost 130

Leveraging Resources Points Less than 4% At least 4% but less than 11% At least 11% but less than 18% At least 18% but less than 25% or more 0 pts 2 pts 4 pts 6 pts 8 pts 131

Leveraging Resources Allowable Non-ICDBG Resources • • • Tribal trust or other funds Private & public loans/guarantees IHBG funds & other grants Donated goods/services Land needed for project Direct admin costs 132

Leveraging Resources Disallowed Leverage • Indirect admin costs • Operations & maintenance costs for project • Value of existing facility if expansion is proposed 133

Leveraging Resources • Submit information with application • Written statement identifying & committing tribal funds • Approved IHP on file with resources committed or written commitment for future IHBG funds • Letter of commitment from non-tribal entity • Comparable costs for goods, services & land 134

Leveraging Resources • Commitment must be received within 6 months • Letter from contributing entity must: Indicate why commitment cannot be made Provide assurance project is eligible for $ Provide date when funding decision will be made 135

Factor 5 Comprehensiveness & Coordination • Up to 10 points • How your project planning and implementation reflects a coordinated community based process of identifying needs 136

Subfactor 1 - Coordination • Up to 2 pts • How you coordinated with those not providing funds but who share your goals • Describe how community was involved in development of project per CP 137

Subfactor 2 – Outputs, Outcomes, and/or Goals • Up to 8 points • Outputs include – – How many houses rehabilitated How many jobs created Square feet of public facility How many homeownership units built/financed 138

Subfactor 2 • Outcomes include: – Reduction in families in substandard housing – Increased income resulting from employment – Increased quality of life due to public facility – Increased economic self sufficiency of beneficiaries 139

What HUD Does 140

Review and Selection Process • Application received by deadline and per requirements • Applicant is eligible • Proposed project is eligible • Application contains all required components • At least 70% of funds must benefit LMI persons 141

Review & Selection Process • Threshold compliance • Past Performance evaluated under Factor 1 • Rating • Minimum Points 142

Review & Selection Process • Ranking – All types of projects ranked against all others • Tiebreakers – Standardized across AONAPs – Projects selected that can be fully funded over those that cannot be 143

Technical Deficiencies • Errors/oversights that would not alter rating if corrected • Only successful applicants asked & required to correct • 14 calendar days to respond • No funding if no response 144

Pre-Award Requirements • No funding if no response or inadequate response • HUD also does a delinquent Federal Debt and Name Check Review 145

Errors • Reviewer judgments not subject to claims of error • Bring arithmetic errors to ONAP attention within 30 days • If warranted, funding may be provided in next funding round 146

Reasons for Rejection • Failure to submit all required documents • Failure to address all parts of thresholds/requirements • Not enough points in Factor 1 • Not enough points overall • Not enough money to fund all applications 147

Anticipated Award Dates • • Pre-awards must be met Congressional Notification Awards announced in February Execute grant agreement – special conditions 148

Post Award Reporting Requirements • Quarterly Federal Financial Reports (SF-425) • Annual Status & Evaluation Report • Minority Business Enterprise Reports • Close-Out Report 149

General Questions • Area ONAP • Electronic Submission – call 800 -518 -4726 or support@grants. gov 150

Area ONAPs • Alaska: (907) 677 -9860 • Eastern Woodlands: 1 -800 -735 -3239 • Northern Plains: 1 -888 -814 -2945 • Northwest: (206) 220 -5270 151

Area ONAPs • Southern Plains: (405) 609 -8532 • Southwest (Phoenix): (602) 379 -7200 • Southwest (Albuquerque): (505) 346 -6923 152

Technical Assistance (TA) • HUD Reform Act (Section 103) • TA only until NOFA publication • TA includes general guidance about NOFA terms and regulations 153

Area ONAP NOFA Training • Contact your Area ONAP for specific locations and to register for NOFA training • Online ICDBG training: http: //www. hud. gov/offices/pih/ih/grants/ icdbg. cfm 154

Examples of Funded Applications • Can be found on HUD’s website at: http: //portal. hud. gov/hudportal/HUD? src=/pr ogram_offices/administration/foia/highscore • Certain Area ONAPs have posted applications also 155