State of North Carolina Action Plan

This page reflects the final version of the State of North Carolina Action Plan approved by HUD on April 25, 2025.

1. Executive Summary

1.1 Overview

The United States Department of Housing and Urban Development (U.S. HUD) announced that the State of North Carolina (the State) will receive $1,428,120,000 in funding to support long-term recovery efforts following Hurricane Helene (FEMA DR-4827-NC) through the North Carolina Department of Commerce (NCDOC). Community Development Block Grant—Disaster Recovery (CDBG-DR) funding is designed to address needs that remain after all other assistance has been exhausted. This plan details how funds will be allocated to address remaining unmet needs in western North Carolina counties impacted by Helene.

To meet disaster recovery needs, the statutes making CDBG-DR funds available have imposed additional requirements and authorized HUD to modify the rules that apply to the annual CDBG program to enhance flexibility and allow for a more rapid recovery. HUD allocated $1,428,120,000 in CDBG-DR funds to the State in response to DR-4827-NC, through the publication of a notice in the Federal Register (FR), [Vol. 90, No. 10, January 16, 2025]. This allocation was made available through the Disaster Relief Supplemental Appropriations Act, 2025 (Division B of the American Relief Act, 2025, Public Law 118-158, December 21, 2024).

The State notes that on January 24, 2025, President Donald J. Trump signed Executive Order (EO) 14181, entitled “Emergency Measures to Provide Water Resources in California and Improve Disaster Response in Certain Areas.” Section 5 of EO 14181 is labeled “Additional Actions to Help North Carolina Families” and subsection 5(b) directs the Secretaries of HUD and the Department of Homeland Security (DHS), working through the Federal Emergency Management Agency (FEMA), to provide an Integrated Federal Housing Strategy and Implementation Plan “that expedites options for housing relief to survivors displaced by Hurricane Helene.”

The State sees the rapid development of the State of North Carolina Action Plan for HUD CDBG-DR Funding in Response to Hurricane Helene (Action Plan) and its strong focus on housing recovery needs as responsive to the President’s call to expedite housing options. We look forward to working with our federal partners in both developing the strategy and obtaining quick approval of this Action Plan to the benefit of Helene survivors and impacted communities throughout western North Carolina.

Table 1: CDBG-DR Program Allocation and Funding Thresholds¹

* Percentages derived from total allocation (Activities + Mitigation) due to Administration amount applied to entirety of the allocation.

** CDBG-DR Mitigation Set Aside ($186,277,00) is 15% of CDBG-DR Allocation for Unmet Needs ($1,241,843,000) but represents 13.04% of the CDBG-DR plus Mitigation total ($1,428,120,000).

NCDOC is not allocating funding to planning or public service activities so rows for those items are not reflected in Table 1. 

To frame the discussion in this Action Plan, readers should be aware of the overall structure of the CDBG- DR program. CDBG-DR is not a permanently authorized program and exists only when Congress appropriates funding for the initiative. Since it is not a permanently authorized program, CDBG-DR does not have standing regulations in the Code of Federal Regulations (CFR) but is implemented through FR notices that specify waivers and alternative requirements and implement requirements. The FR notices do leverage, where appropriate, regulations for the annual CDBG program which can be found at 24 CFR 570 and also conveys waivers and alternative requirements that HUD has opted to apply to these funds.

On January 8, 2025, HUD issued its Universal Notice, which will govern the $12 billion of CDBG-DR funding appropriated by Public Law 118-158. The Universal Notice works in tandem with an Allocation Announcement Notice (AAN), published in the FR on January 16, 2025, which formally made the allocation of $1.428 billion of CDBG-DR funding to the State for Helene recovery purposes. The AAN has an applicability date of January 21, 2025, which is important as it is the starting date for various timelines identified in the Universal Notice.

On March 19, 2025, HUD issued revisions to the Universal Notice to improve its alignment with policies of the Trump Administration as those policies have evolved since January 20, 2025. Coincidently, March 19 was also the day the public comment closed on NCDOC’s draft Action Plan. NCDOC has worked to address and/or incorporate the Universal Notice revisions into the Action Plan as quickly as possible. It is NCDOC’s analysis that the changes have not significantly impact two critical components of the Action Plan, namely the unmet needs analysis (Section 2) and the descriptions of programs to be funded (Section 4). NCDOC will use the term “Revised Universal Notice” to identify the combination of the January 8 Universal Notice plus the March 19 memo revisions.

Beyond the original Universal Notice, NCDOC also prepared the draft Action Plan using a document entitled "Universal Notice Action Plan Guide and Template, Version 1.0” that was posted to the HUD website on or about January 17, 2025. That document was subsequently removed from the HUD’s CDBG- DR Universal Notice webpage and a revised version of the template was posted to the same website on March 20, 2025. NCDOC has moved to align this final Action Plan with the changes implemented by the March 19 memorandum as well as the revised template. NCDOC does note that the template describes itself as a “supplemental tool” and an “optional resource” for grantees to use in developing their action plans and NCDOC has substantially followed it as an outline. NCDOC did note several inconsistencies in tables presented in the plan guide/template and has attempted to reconcile those situations in favor of consistency of presentation and clarity of data. These instances are footnoted where they occur in the Action Plan.

1.2 Disaster Specific Overview³

Hurricane Helene reached the State on Friday, September 27, 2024, bringing historic rainfall, strong winds, and tornadoes generated by the storm. On that day, former Governor Roy Cooper requested a Major Disaster Declaration from the federal government for 39 North Carolina counties and the Eastern Band of Cherokee Indians. On September 28, 25 counties in the State were declared a major disaster by former President Biden under provisions of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act or P.L. 93-288), approving Individual and Public Assistance (IA and PA) for these counties as well as the Eastern Band of Cherokee Indians. On October 5, two additional North Carolina counties were declared eligible for federal IA, followed by twelve more on October 16.

The impact of Helene was substantially to the west of the Interstate 77 corridor which bisects the State from north to south. Within the western portion of the State, rainfall was focused along the spine of the Blue Ridge Mountains as they run southwest from the Virginia-Tennessee-North Carolina border area to the North Carolina-South Carolina-Georgia border area. The following map highlights this portion of the State.

The following two maps present the concentrated nature of the rainfall associated with Helene and the areas of the State directly and severely impacted by the aftermath. The first map shows the estimated rainfall totals for western North Carolina associated with Helene. The second map indicates the counties covered by the FEMA major disaster declaration and eligibility for FEMA IA and PA.

1.2.1 Most Impacted and Distressed Areas

HUD’s Revised Universal Notice requires that at least 80% of CDBG-DR funds be used to address unmet needs or mitigation activities in the HUD-Identified Most Impacted and Distressed (HUD-Identified MID) area(s). In its AAN, HUD identified its MID area for the State at the county level and, in some cases, specific zip codes within counties. HUD also permits the State to identify additional areas as its own MID (State- Identified MID) but no more than 20% of the funds may be spent in the State-identified MID area. Collectively, the HUD-Identified and State-Identified MID areas are referred to as the Combined MID area throughout the Action Plan. Table 2 below identifies the various MID areas.

1.2.1.1 Most Impacted and Distressed (MID) Areas

Table 2: HUD- and State-Identified MID Areas

The above table reflects several decisions made by NCDOC pursuant to the AAN and the Revised Universal Notice. First, NCDOC has opted to expand the HUD-Identified MID to include the entirety of four (4) counties in which HUD had identified a single zip code as an MID area. These four counties are: Caldwell, Cleveland, Madison, and Polk. Thus, funds expended for projects and activities in these counties will count toward the HUD-imposed requirement that at least 80% of CDBG-DR funds be expended in the HUD- Identified MID area.

Second, while HUD also identified a single zip code in Mecklenburg County as MID, NCDOC will not expand the HUD-Identified MID area to the entire county.

Central to these two decisions is the fact that Mecklenburg County has not been designated by FEMA, as of March 25, 2025, to receive aid for permanent reconstruction activities under Categories C through G of FEMA’s PA program. The County has only been authorized to receive emergency and debris removal assistance under Categories A and B. The four counties that have been fully included in the HUD-Identified MID based on the zip codes have all been designated by FEMA to receive PA assistance for Category A through G. NCDOC sees this distinction as indicating a greater need for long- term recovery assistance in those four counties.

FEMA PA Categories C through G are:

• C: Roads and Bridges
• D: Water control facilities
• E: Buildings and equipment
• F: Utilities
• G: Parks, recreational, and other facilities

1.2.1.2 Grantee-Identified MID

The Revised Universal Notice also authorizes grantees to designate additional areas as the State-Identified MID area. NCDOC hereby designates as the State-Identified MID all other counties that FEMA has designated to receive both IA and PA across Categories A through G. Counties meeting these criteria as of January 20, 2025, are listed in the table above as the State-Identified MID. All State-Identified MID counties shall only be able to apply for assistance consistent with specific program requirements as listed in section 4 of this Action Plan, keeping in mind that the State must use at least 80% of its CDBG-DR funds (including mitigation set-aside funds) in the HUD-Identified MID area.

1.2.1.3 Overview of Impacts of Qualifying Disaster

Damage across western North Carolina due to Helene is substantial and widespread. Table 3 below is from a report prepared by the North Carolina Office of State Budget and Management (OSBM) and reflects estimates of damage and needs across multiple economic sectors (amounts are expressed in millions). The estimated total losses to the State associated with Helene exceed $57 billion, and necessary recovery investments will likely produce a substantial drag on the region’s economy for years into the future.

Table 3: Quantified Disaster Impacts of Helene - Damage and Needs Estimated by Sector (in Millions)

The key takeaway from this table is that 30% of the total direct damage across all economic sectors arises from damage associated with housing and this fact drives the NCDOC’s use of its allocated CDBG-DR funding as there are few federal financial resources to assist with housing recovery efforts. HUD, in its analysis of unmet needs, does not take the expansive view reflected in the OSBM report and uses data that considers only narrow segments of unmet need in the areas of housing, infrastructure, and economic revitalization. In light of these issues, NCDOC’s position is that it is imperative to contribute in a significant way to housing recovery in western North Carolina and is proposing a set of programs that devote approximately 74% of available CDBG-DR funding, or $1.052 billion, toward that goal.

With respect to housing needs, the OSBM report provided the following high-level information based on FEMA IA and American Community Survey (ACS) data available as of early December 2024. Certain data points have been updated where possible.

• More than 280,000 households have applied for FEMA IA, and more than 157,000 households have been approved for some level of assistance as of March 23, 2025.
• Approximately 73,700 homes are expected to be found to have suffered damage.
• Single-family homes, manufactured homes, and duplexes account for a majority of affected residential structures.⁶ This fact will be a principal influence upon the State’s allocation of CDBG-DR funds.
• The overall need for housing assistance is estimated to be $15.4 billion.
• This includes $12.7 billion due to residential structure damage, which will change as FEMA conducts further on-the-ground assessments.
• Mobile homes were more prevalent as a share of all housing units in counties covered by the major disaster declaration. About 15.4% of housing units in those counties were mobile homes compared to 12% in the rest of the State.
• Displaced residents will need transitional and short-term housing, personal property replacement, and other assistance.

1.2.2 General Matters

1.2.2.1 Management of Helene Recovery Efforts

Governor Josh Stein took office as the 76th Governor of North Carolina on January 1, 2025, and he has designated the NCDOC to administer the CDBG-DR funding allocated to the State in response to the impact of Hurricane Helene. NCDOC has experience working with CDBG funding as it is the recipient of the annual State CDBG program funding from HUD ($42.2 million in fiscal year (FY) 2024) and will leverage that experience to provide a foundation for Helene CDBG-DR implementation efforts.

To provide an unwavering focus on Helene recovery efforts, Gov. Stein has taken several steps.

• First, he has established a new Division of Community Revitalization (DCR) within NCDOC to manage CDBG-DR funding, oversee the rebuilding of homes destroyed or damaged by Helene, and coordinate and lead efforts to revitalize the economy of western North Carolina.
• Second, DCR will work in conjunction with the newly established Governor’s Recovery Office for Western North Carolina (GROW NC), which will provide a cross-agency vision for Helene recovery efforts, coordinate the response of those agencies, and deploy the expertise and innovation necessary for a swift and robust recovery effort.
• Third, Gov. Stein has created the Governor’s Advisory Committee on Western North Carolina Recovery (the Committee), the membership of which includes more than two dozen public and private sector representatives from across western North Carolina. This committee will meet monthly and advise on strategies to address the needs of communities affected by Helene in areas such as housing, infrastructure, small business, and others related to the rebuilding of western North Carolina. The establishment of this multifaceted effort demonstrates Gov. Stein’s understanding that successful recovery efforts require a high level of on-going attention and engagement at the executive level and that business as usual will be inadequate to fully meet recovery needs arising from the damage inflicted by Helene. Further, NCDOC’s quick development of this Action Plan is a component of the State’s overall effort to accelerate recovery work in the spring of 2025.

To advance this effort, Gov. Stein is seeking funding from the North Carolina Legislature for various recovery activities and NCDOC has the intention of treating at least some portion of those expenses as pre-agreement costs to be repaid through CDBG-DR funds. Consistent with the requirements of the Revised Universal Notice, NCDOC will identify programs where pre-agreement cost reimbursement may be involved. NCDOC and, more specifically, DCR will have responsibility for the Helene-related CDBG-DR funding. Activities and programs funded with CDBG-DR provided in response to hurricanes Matthew (2016) and Florence (2018) will be seen to completion and closeout by the North Carolina Office of Recovery and Resilience (NCORR), but NCORR will have no role in management and oversight of the Helene recovery effort.

1.2.2.2 Environmental Review Responsibilities

Flowing from Gov. Stein’s designation of NCDOC to administer the CDBG-DR funding, NCDOC will be the Responsible Entity (RE) for carrying out actions required pursuant to HUD’s environmental review procedures at 24 CFR 58, including the responsibilities of States as defined at 24 CFR 58.4(b).  To enhance NCDOC’s ability to effectively carry out these responsibilities, NCDOC will directly hire an individual with extensive environmental review experience to manage this critical process. NCDOC will conduct environmental assessments, environmental reviews, or environmental impact statements for CDBG-DR assisted activities, as appropriate, and will make determinations as to activities that are categorically exempt or categorically excluded activities from these requirements.  NCDOC will process necessary filings such as the Finding of No Significant Impact (FONSI) or the Request for Release of Funds (RROF) as required under 24 CFR 58, Subpart E.

NCDOC does not intend for any subrecipient or contractor to carry out environmental review procedures with one exception. For administrative convenience as outlined in section 1.2.2.4., NCDOC may opt to allow the City of Asheville, North Carolina to carry out certain environmental responsibilities related to the State’s CDBG-DR funding for activities that will take place within the boundaries of the city. 

1.2.2.3 Relationship of Helene Recovery to HUD Consolidated Plan

As the lead agency for annual formula funding provided to the State by HUD’s Office of Community Planning and Development (CPD), NCDOC submits to HUD the State’s five-year Consolidated Plan and Annual Action Plan (the Consolidated Plan) as required by 24 CFR 91. The Revised Universal Notice at section III.B.6. provides time-limited waivers related to the consolidated planning process that are effective for 24 months (through January 16, 2027). Within this timeframe, grantees are directed to update consolidated plans to reflect disaster-related needs. The State’s existing five-year Consolidated Plan covers the period 2021 to 2025, and the process to update the plan will begin later in 2025, in anticipation of the submission to HUD of a new plan in the second quarter of calendar year 2026. When undertaking this update, NCDOC will ensure that Helene-related recovery needs are reflected in that Consolidated Plan, thereby meeting the Revised Universal Notice requirements.

1.2.2.4 Use of State CDBG-DR Funds in the City of Asheville

Concurrent with the allocation of $1.4 billion in CDBG-DR funding to the State, HUD announced a separate CDBG-DR allocation of $225,010,000 directly to the City of Asheville, North Carolina (the City). Pursuant to the AAN, the City must spend 100% of its funds to address unmet needs and mitigation activities within its HUD-Identified MID area, which is the entire city.

The City is located within Buncombe County, which is part of the State-Identified MID area, and this fact raises the question of whether State CDBG-DR funds should be expended in Asheville. NCDOC has had productive discussions with City officials regarding this issue, and a framework for coordinated action has been developed. The primary area of coordination relates to the Housing Reconstruction and Rehabilitation (Housing R&R) program described in Section 4 of this Action Plan. NCDOC will devote more than $800 million of CDBG-DR funding to the Housing R&R program across the Combined MID area and will have economies of scale that the City is unlikely to achieve with a much smaller program. NCDOC and City officials have tentatively agreed that NCDOC will entertain applications under the Housing R&R program for qualifying homeowners in the City. If the homeowner meets program qualification criteria, NCDOC will undertake the necessary reconstruction or repairs. The City will ultimately use its CDBG-DR funding to reimburse NCDOC for the actual construction costs of each unit. Further, NCDOC will permit the City and organizations in the City to apply to NCDOC for CDBG-DR funding for projects in the City, assuming such entities meet the specific qualifications specified for the respective programs. NCDOC will provide greater detail on these matter as it develops policies and procedures for implementation of those program.

1.2.2.5 CDBG-DR Website

The CDBG-DR language in the Disaster Relief Supplemental Appropriations Act, 2025, requires that each grantee establish and maintain a comprehensive disaster recovery website. NCDOC has established and will host the website for the Helene CDBG-DR allocation and URL is: commerce.nc.gov/recovery.

This webpage CDBG-DR page will ultimately include and reflect the information required by HUD’s guidance in section III.B.8. of the Revised Universal Notice. This will include the Action Plan and subsequent amendments, program application information, a portal for applicants to track the progress of their applications, program guidance, procurement contracts, quarterly performance reports, and other pertinent information.

1.2.2.6 Compliance with Applicable Statutes

On March 19, 2025, HUD issued a memorandum revising the Universal Notice to better align CDBG-DR program requirements with policies of the Trump Administration. One of the provisions revised by the March 19 memo is section I.C.1 and the new section I.C.1 c. explicitly requires that grantees use their CDBG-DR funds in a manner that complies with applicable statutes including:

• Section 109 of the HCD Act (42 U.S.C. 5309)
• Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d et seq.)
• Title VII of the Civil Rights Act of 1964 (42 U.S.C. 2000d et seq.)
• Title VIII of the Civil Rights Act of 1968 (The Fair Housing Act) (42 U.S.C. 3601-19)
• Sections 504 and 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794)
• The Americans with Disabilities Act of 1990 (42 U.S.C. 12131 et seq.)
• Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) (Public Law 104-193).

NCDOC will use its CDBG-DR funds and implement its programs as proposed by this Action Plan consistent with the laws cited in section I.C.1.c. of the Revised Universal Notice. Additional requirements under this section of the Revised Universal Notice are addressed in the program descriptions and discussion later in this Action Plan.

1.3 Unmet Needs and Mitigation Needs Assessment Summary

Table 4 below provides the overview of the State’s $1.428 billion allocation of CDBG-DR funding across programs that begin to address the damaging impacts of Hurricane Helene. As the available CDBG-DR funding is less than the State’s estimated unmet recovery needs, it is targeted in three ways:

• First, to principally deliver benefit to individuals, households, and communities with the fewest resources to recover, pursuant to a federal statutory requirement that at least 70% of all funds be expended for activities that benefit low- and moderate-income (LMI) individuals;
• Second, to target at least 80% of those expenditures in the HUD-Identified MID areas; and
• Third, the directive of the federal appropriation law which directly references the “restoration of housing and infrastructure, economic revitalization, and mitigation…”.

While the need to comply with these fundamental requirements establishes outer boundaries for use of the funds, the State has substantial latitude in the mix of specific programs, funding levels for activities, and overall implementation. The choices reflected herein are informed not just by data on damage but also by consultation with and feedback from impacted individuals, communities, institutions, and other stakeholders. The framing for these choices can be found in subsequent sections of this Action Plan.

Table 4: Unmet Needs and Proposed Allocations⁷ 

The restoration of housing for both renters and homeowners in Helene-impacted areas is the State’s highest priority as thousands of units have been determined by FEMA IA data to meet HUD’s definition of “most impacted.” The number of seriously damaged or destroyed by Helene is predicated upon self- assessments documented in the FEMA IA registration process.

Rehousing North Carolinians is a necessity to both keep smaller, rural communities in the western part of the State viable and to sustain an economy that depends significantly upon tourism and agriculture. In conjunction with housing restoration, the State will assist property owners in addressing repairs to private roads and bridges by providing mitigation funding to ensure public safety access and that future severe weather events do not trigger similar damage.

While infrastructure needs are significant, a substantial portion of permanent repair and reconstruction costs will be covered by FEMA’s PA program, which will cover 90% of those costs. To help address the required 10% state/local cost share under the PA program, the North Carolina Legislature has already provided $250 million for non-federal cost share needs. Beyond these needs, NCDOC is proposing a community infrastructure program to address needs which may be outside the scope of FEMA’s PA program.

As western North Carolina has many small and rural communities, restoring downtown areas and commercial districts in a resilient manner in those communities will be a critical activity. To recreate focal points for regional commercial activity, the State will be reserving funding for this purpose as well.

2. Unmet Needs Assessment

2.1 Evaluate the Impacts of Three Core Aspects of Recovery

The Helene-impacted region of western North Carolina accounts for approximately 23% of the State’s gross domestic product (GDP), and Hurricane Helene left significant, long-term impacts on that portion of the State. In addition to the devastating loss of life, the storm seriously damaged or destroyed more than 8,800 homes and damaged tens of thousands more. Millions of North Carolinians lost access to critical services like water, sewer, electricity, telecommunications, and healthcare facilities. Thousands of miles of roads and bridges were damaged, cutting communities off and limiting egress for residents and entrance by essential response and recovery teams. The region’s economy has suffered a severe blow, threatening livelihoods and the long-term viability of communities.

Estimates of damage and needs as of December 13, 2024, are more than $59.6 billion across the State, including $44.4 billion of direct damage, $9.4 billion of indirect or induced damage, and $5.8 billion of potential investments for strengthening and mitigation. Five categories comprise close to 90% of estimated direct and indirect damage: Economy, Housing, Utilities and Natural Resources, Transportation, and Agriculture.

The damage attributable to Helene is roughly three and a half times the $16.7 billion impact of Hurricane Florence upon the State in 2018.

Helene produced severe or catastrophic impacts on homes and essential services and those impacts can be summarized as follows:

• Large-scale damage to homes: Helene is projected to have damaged more than 73,000 homes, with many thousands having experienced severe or catastrophic impacts.
• Disruption of life-sustaining services: Helene damaged or destroyed sewage and water treatment systems in multiple communities and 44 emergency response facilities. The storm resulted in the evacuation of 145 healthcare facilities (including hospitals; nursing homes; and adult, family, mental health, and community health facilities) across western North Carolina.
• Impacts to transportation and utilities: Entire communities lost access to core services and communication. The storm caused damage to roads and bridges at more than 6,900 sites, forcing traffic closures, including on I-40. Landslides and flooding cut residents off from outside help and communication.

Some of Helene’s impacts that may be particularly long-lasting include:

• Delay in return-to-business: With the loss of essential services, utilities, and transportation corridors came long-term cessations in operations for businesses across western North Carolina. The complexity of restoring infrastructure has directly slowed the reopening of businesses and has impaired access to key customer bases. In turn, businesses face challenges to their survival, which may have significant impact on the region's communities.
• Multi-year damage: Key centers of production and revenue generation in industries such as agriculture and tourism experienced impacts that are likely to last for years (e.g., damage to nursery plants, which will need multiple seasons to regrow; damage to backcountry infrastructure and natural landscapes at State and national parks, which may not return to ‘normal’ for years). The longevity of this damage is likely to slow rebuilding and may make it more challenging for communities to recover, retain residents, and attract visitors.
• Substantial uninsured home and property losses: Helene damaged thousands of structures, including many residences. Unlike in coastal areas, most homeowners do not carry flood insurance. This coverage gap will dramatically reduce private financial resources for recovery. Increased costs to complete recovery and mitigate future harm
• Increased construction costs: Several factors are impacting construction costs. First, construction costs have risen significantly since COVID-19. Second, the need to work in rugged, highly sloped terrain adds cost across the board to construction design, materials, and implementation. Third, multiple recovery efforts from concurrent natural disasters across the Southeast may lead to higher-than- normal costs than for disaster recovery.
• Opportunity for strengthening and mitigation: Unprecedented damage and impact to the State have led to calls for strengthening and mitigation to prevent future disasters of this magnitude from happening again. Part of this effort will focus on ensuring more durable access to small, rural communities and individual homes by strengthening privately-owned roads and bridges.

These challenges complicate the comprehensive damage and needs assessment due to:

• Impaired access: Large-scale flooding and landslides caused extensive damage to transportation infrastructure in the region. The extensive road damage has at times slowed aid and hindered damage assessments of many of western North Carolina's more isolated communities. Road construction crews have worked tirelessly to make it safe for first responders and inspectors to move in and out on a limited set of transportation corridors.
• Difficulty of communication: Helene caused significant damage to communications infrastructure in western North Carolina. These impacts were amplified by damaged transportation infrastructure, which has slowed network restoration by service providers, and the region's mountainous topography, which limited the range and quality of connections provided by temporary solutions. The resulting severe, prolonged communications disruption has limited the ability of first responders and inspectors to communicate across and outside the region.
• Disparate nature of communities: Many affected communities and residences are spread far apart and isolated by western North Carolina's mountainous terrain. This is evidenced by the region's relatively low population density. Counties in the major disaster declaration that experienced greatest rainfall have an average population density of 156 residents per square mile, compared to 169 per square mile in Florence-affected counties and 223 per square mile for the State as a whole. The lower population densities in western North Carolina have consequences for CDBG-DR program and policies choices as there is a distinct need to respond to the needs of a widely dispersed population living in difficult to access terrain. This fact becomes a driver of the decision to devote substantial CDBG-DR mitigation funding to address property access via private roads and bridges.

Table 5: LMI Analysis - Federal Declared Disaster Areas⁸

Non-MID Totals

Combined MID Totals

2.2 Housing

Data regarding housing damage and recovery needs arising from the impact of Helene continues to accrue more than six months after the disaster declaration. The housing portion of this unmet needs assessment (UNA) relied substantially upon data available to OSBM as of early December 2024, roughly 10 weeks after Helene struck. It is further informed by the Housing Impact Assessment (HIA) done by the Federal Housing Recovery Support Function (RSF) pursuant to the National Disaster Recovery Framework (NDRF).

In both cases, there is a substantial reliance upon data collected by FEMA through the registration process for its Individuals and Households (IHP) or IA Program as well as data available from Census Bureau sources. The FEMA IA data will continue to evolve as the application deadline for Helene-related assistance has been extended until April 7, 2025. With more than 280,000 IA registrations and 157,000 applications approved as of March 23, 2025, it is clear that the majority of registrations have already taken place.

The Housing RSF is one of six RSFs, and HUD is the coordinating agency for the Housing RSF. The mission of the Housing RSF is to:

• Support efforts to address pre- and post-disaster housing issues;
• Facilitate delivery of federal resources to implement housing solutions;
• Support activities to assist local, state, and tribal governments in the reconstruction and rehabilitation of damaged and destroyed housing; and
• Support efforts to develop new, accessible permanent housing options.

The Housing RSF Assessment was made available to NCDOC in mid-March and is particularly valuable in refining Helene’s impact upon the assisted housing stock in western North Carolina and impacts including, but not limited to, the pre-storm homeless, elderly, and those having access and functional needs. It will also identify key considerations for a broad, effective housing recovery effort. Consistent with the advisory in the draft Action Plan, NCDOC is incorporating information from the Housing RSF Assessment into the final Action Plan.

This much is clear from both the initial OSBM report and the RSF Housing Impact Assessment: Helene caused extensive damage to the western North Carolina housing stock. The following initial estimates with respect to housing damage and recovery needs are from the OSBM report of December 2024:

Table 6: Quantified Housing Damage, Necessary Investment Estimates, and Unmet Needs (in Millions)

Damage and Needs

Necessary Investments

The RSF Housing Impact Assessment provides a deeper evaluation of the post-Helene housing situation in western North Carolina as well as a more targeted data analysis.  The following section integrates information from the OSBM reports and the Housing Impact Assessment.

The scope for housing repair estimates in the OSBM report includes:

• Residential housing: single-family, multi-family, rental residences, public housing, and supportive housing (including subsidized affordable housing);
• Transitional sheltering;
• Housing for individuals with disabilities, individuals experiencing homelessness, and individuals with severe mental illness; and,
• IA and PA payments, with additional non-housing assistance, such Other Needs Assistance (ONA) and other FEMA programs, separated out.

These estimates include damage to housing structures, registered motor vehicles, personal property, and buildable land but excludes losses from private, non-residential buildings or government buildings. In developing these estimates, OSBM relied primarily on Individual Assistance claims data and housing data from the U.S. Census Bureau’s ACS.

The takeaway from Table 6 is that the estimated housing damage plus necessary investments for mitigation and resilience is $15.38 billion.  OSBM projected that $6.779 billion of that amount would be available from federal resources, most notably CDBG-DR at an estimated $4,771 billion. The reality is that North Carolina was allocated $1.428 billion in CDBG-DR by HUD, which is only 30% of the identified unmet need for housing.  

Residential Damage: OSBM forecasted the total damage to residential structures using FEMA IA data through December 2, and scaling to project the total damage based on comparisons to Florence claims through the first three months and total claims. OSBM estimates $12.7 billion in residential damage, including both single- and multi-family housing. The RSF Assessment, using FEMA IHP data available as of January 15, 2025, provided the following profile of housing damage:

Table 7: Units Experiencing Destruction and Major Damage by Occupancy

• FEMA Assistance: OSBM analyzed FEMA IA data published on December 2. The deadline to apply for FEMA IA has been extended to April 7, 2025, so OSBM projected the number based on the currently known number of applications. As noted above, IHP registrations total more than 280,000 and more than 157,000 applications for post-Helene assistance have been approved as of mid-March, 2025.
• FEMA IA: To estimate impacted households, OSBM reviewed IA claims presently submitted and projected the number of total applications received based on this data. OSBM estimates between 25,000 and 30,000 households receiving housing assistance through IA. As of March 23, 2025, FEMA reports that more than $158 million has already been paid out to Helene survivors for housing assistance under the IA program with additional amounts to be paid in the future. An additional data point provided by the Housing Impact Assessment is that 492 of 2,978 households reviewed for direct housing have been approved for units by FEMA and that 75 households had units in place by the time the Assessment was issued.  
• FEMA ONA: FEMA publishes daily data on approved ONA funds, which cover immediate housing and life needs, vehicles, essential household items, other personal property, and disaster-related funeral or child-care costs, with the other IA data. OSBM estimated 147,000 households will receive ONA, and FEMA reports more than $252 million has been paid out to Helene survivors for ONA purposes with additional amounts to be paid in the future.
• FEMA PA: FEMA will reimburse housing-related expenditures through PA related to emergency protective measures and public housing facilities. OSBM scaled PA assistance from Hurricane Florence based on comparisons in storm damage to estimate FEMA PA for Hurricane Helene recovery. This projection includes public housing authority units and government programs that house certain populations, like Transitions to Community Living. Currently available PA data only includes approved payments for a small percentage of applicants and cumulative payments under all PA categories (A-G) are no longer available on FEMA’s website as of March 2025.
• Small Business Administration Loans: The federal residential funding also includes disaster loans for homeowners and renters through the Small Business Administration (SBA). The SBA application window for physical property damage has been extended through April 27, 2025. OSBM projected the final recipients, 13,900 households, and total loan amount based on an average anticipated loan of $74,100 by scaling the number of approved applicants and average loan from Hurricane Florence. The scaling factor was calculated by first projecting the Hurricane Helene FEMA IA home-damage inspection data to estimate the total number of inspection-verified damaged homes and the average damage per home. OSBM compared this estimate to the Hurricane Florence IA home-damage numbers and averages to determine the scaling factor. NCDOC received data from SBA via email in late January and at that point had only approved 1,703 homeowner/renter loan applications for a total of $115.9 million.  Of the 6,401 applications filed as of that time, 2,203 applications were reported as declined and 2,231 applications had been withdrawn.
• Private Insurance: OSBM used insurance coverage levels from IA data and Hurricane Florence to project the residential damage that private insurance would cover. This analysis divided potential claims into those with flood damage and all other claims. While OSBM’s initial projection was that that only 5.2% of households with verified flood damage had flood insurance, the Housing Impact Assessment presents a more detailed and, in some ways, more dire picture regarding insurance coverage through homeowners and flood insurance.  The following two tables reflect coverage along these lines.

Table 8: Homeowners and Renters Insurance Coverage

Table 9: Homeowners and Renters Flood Insurance Coverage

The critical points made by these data are that renters were essentially not covered by either property or flood insurance and that 25% of homeowners were without property insurance and also has exceptionally low levels of flood insurance. The bottom line is that housing recovery in the Helene-impacted areas of western North Carolina will rely greatly upon public funding. 

• Transitional Sheltering: This estimate includes both FEMA PA and HUD Rapid Unsheltered Survivor Housing (RUSH) program needs.
• FEMA PA will reimburse 100% of transitional sheltering costs in designated counties for the first six months following Hurricane Helene. At its peak on October 4th, counties in western North Carolina opened 22 shelters serving 1,162 occupants but, according to the Housing Impact Assessment, all congregate shelters were closed as of January 25, 2025. OSBM estimated the total cost of sheltering based on the number of occupants in disaster shelters. Using an American Red Cross (ARC) estimate of cost per occupant, OSBM estimated a transitional sheltering cost to FEMA of $10.8 million over the first six months of recovery. The Housing Impact Assessment provides the following information regarding FEMA’s Transitional Sheltering Assistance (TSA):

Table 10: FEMA Transitional Sheltering Assistance in North Carolina Post-Helene

• HUD’s Rapid Unsheltered Survivor Housing (RUSH) program provides funding to states and local governments to address needs of individuals and families experiencing homelessness or at risk of homelessness in the wake of a federally declared disaster. North Carolina received $3 million of RUSH funding in October 2024 and requested an additional $7 million from this program.   However, North Carolina was allocated only $1.9 million of this request on February 27, 2025.⁹

Certain characteristics of the housing supply in western North Carolina create challenges for hurricane recovery and rehousing displaced individuals, such as: 

• Seasonal Housing: In the 39 declared counties, seasonal housing represents approximately 10% of the total housing stock, with a range of less than 1% in many of the Piedmont counties to nearly 45% in Avery County. Statewide, seasonal housing is only 3.9% of the housing stock.
• Vacant Units: In the 39 declared counties, 7.3% of total housing units are designated as ‘vacant-other’ according to ACS data. Often, housing units designated as ‘vacant-other’ are indicated as such due to condition, foreclosure, or other legal reasons, or for personal/family reasons and cannot easily or quickly be reincorporated into the occupied housing stock. Statewide, vacant-other units are only 4.6% of total housing units.
• Affordable Housing: HUD defines housing cost burden at several levels: a moderate housing cost burden means that a household pays more than 30% of income for housing while a severely cost burdened household pays in excess of 50% of income for housing. According to the Housing Impact Assessment, 20% of all homeowners and 45% of all renters in North Carolina are cost burdened. Within the combined MID area, Buncombe County has the highest concentration of cost burdened households. Further, the OSBM report indicates that in disaster-declared counties, 40.8% of households earn less than 80% of the area median income (AMI), so affordable housing is a key issue for this population. As noted earlier, manufactured housing units (MHUs) (often referred to as mobile homes) represent a substantial proportion of the housing stock in the counties covered by the major disaster declaration for Helene (DR-4827-NC). The Housing Impact Assessment identifies the following counties within the combined MID area as having more than 20% of their housing primarily categorized as mobile homes but including several other alternatives: Alexander, Burke, Graham, McDowell, Madison, Surry, Swain, Wilkes, and Yadkin.  This information provides important focus given NCDOC’s intention to focus on providing MHU owners with traditionally built houses in an effort to provide more resilient housing in response to these disaster impacted households.
• In proposing to allocate $1.052 billion or 74% of its CDBG-DR allocation for housing recovery, NCDOC will seek to assist as many low- and moderate-income households as possible with their housing needs while still reserving 20% of funds for infrastructure and economic development needs and supporting the long-term oversight of these funds by using 5% for administrative costs. 

2.2.1 Emergency Shelters and Interim and Permanent Housing

The following table uses data from HUD’s 2023 Point-in Time (PIT) count to demonstrate homelessness estimates for North Carolina as a whole, for the counties covered by the Helene disaster declaration (DR-4827), and for the combined MID area as defined by HUD and NCDOC. Consistent with the description of similar data in the Housing Impact Assessment, it should be noted that NCDOC has included the North Carolina Balance of State Continuum of Care in the combined MID estimate as the data for disaster impacted counties cannot be disaggregated. NCDOC sees this approach as a partial offset to the fact that PIT count is widely recognized as a significant undercount of homeless individuals. 

Table 11: Point-in-Time (PIT) Count – Type of Shelter¹⁰ 

2.2.2 Rental and Owner-Occupied Single Family and Multifamily Housing

The following table addresses HUD’s desire to understand the distribution of housing tenure along the lines of homeowners and renters. It demonstrates that within the Combined MID area, 71.7% of all households are homeowners with the converse being that 28.3% of households are renters. 

Table 12: Housing Tenure¹¹

2.2.3 FEMA Verified Loss by Occupancy

The Housing Impact Assessment provided the following data on FEMA verified losses for homeowners and renters. The underlying data set (FEMA FIDA Report) dates to December 21, 2024, when total registrants numbered 270,760 versus the March 2025 total in excess of 280,000. One observation is that the number of owner-occupied units with a verified real property loss greater than $25,000 was 1,296 or 0.8% percent of the December total of 161,584 homeowner registrants. A second observation is that almost 92% of all registrants (248,801) did not have any FVL for personal property. 

Table 13: FEMA Verified Loss (FVL) by Occupancy

Registrant Occupancy: Owner

Registrant Occupancy: Renter

2.2.4 Public Housing, HUD-Assisted Housing, and Other Affordable Housing

Thirty (30) PHAs have been identified as serving communities in the Combined MID area. This census is based on information available on HUD’s website which provides contact information for PHAs in the State. These PHAs have a mix of Annual Contribution Contract (ACC) units, Housing Choice Vouchers (HCVs), and Project-Based Vouchers.  

The Housing Impact Assessment indicates public housing damage assessments have been completed and reflect limited damage to public housing and to units where households use HCVs. On the public housing side, only 26 units were reported in the Assessment as having been damaged and while several others had yet to report their damage as of January 15, 2025.  No data is available in the Assessment regarding damage to HVC units. 

Concurrently, displacements as a result of damage were also limited and the Assessment indicates a total of 209 displacements between HCV holders (190) and public housing residents (19). Approximately 25% of those households displaced were rehoused by mid-January and additional progress has likely been made in the interim. 

The Housing Impact Assessment also provides a useful picture of damage to the 465 properties in the HUD multifamily housing portfolio that are located in the 39 counties declared under DR-4827. These properties either have a Federal Housing Administration (FHA) mortgage insurance, Project-based Rental Assistance (PBRA), deed restriction covenants or a combination of these instruments.  Of the 465 properties, only 10.45% sustained damage.  The following table details the level of damages.

Table 14: HUD Multifamily Housing Program Property Damage

The Assessment reported that 71 households in HUD Multifamily properties were displaced as of early March 2025 and had been provided temporary housing. On a related point, the Assessment indicated that only 19 units at 6 multifamily properties in the North Carolina Housing Finance Agency (NCHSA) portfolio were off-line as of January 21, 2025. Similarly, the Assessment included data on damages to the USDA Rural Development multifamily portfolio, indicating that 66 properties suffered some damage but only 4 sustained major damage.  This impact resulted in 21 units in Buncombe and Yancey counties being uninhabitable. 

The following table provides a county-by-county summary of various types of housing assistance and units available within the counties covered by DR-4827. 

Table 15: County-by-County List of Assisted Housing Impacted by the Disaster¹²

2.3 Infrastructure

2.3.1 Electrical, Gas, Water, Sewer, Waste, and Telecom Infrastructure

The electrical, gas, water, sewer, waste, and telecom infrastructure of western North Carolina services about three million residents and 500,000 businesses. The geography of this area creates unique challenges for pipes, wires, transmission and pumping stations, and related equipment as it must span terrains that are uniquely susceptible to natural disaster and especially difficult to repair or rebuild (e.g., equipment traversing destroyed bridges or alongside high slopes; infrastructure that spans long distances to service low population density areas, etc.). 

The total damage and need impact is estimated to be nearly $7 billion. This is based on reports of damage from the NC Department of Environmental Quality (DEQ), NC Department of Natural and Cultural Resources (DNCR), municipal-owned electrical membership organizations, electrical cooperatives, private electricity and gas providers, and the Federal Communications Commission (FCC).¹⁴  

The direct damage and needs estimate is comprised of: 

• $1 billion in damage to the electrical wiring and electrical infrastructure facilities of 25 municipal-owned systems, seven cooperative-owned electrical systems, and Duke Energy Carolinas and Duke Energy Progress (collectively referred to in this report as Duke Energy) in a region serving nearly two million households;
• $100 million in damage to local parks, and erosion to riparian buffers and trail networks across the State;
• $41 million in damage to gas lines impacting 400 customers and 10 retail propane locations that were severely damaged or destroyed resulting in the loss of 5,000 propane tanks;
• $205 million in damage to 29 public and private high hazard dams and 13 mining sites;
• $3.7 billion in damage to 163 water and sewer systems and hundreds of miles of impacted distribution pipes across more than 24 impacted towns in affected counties;
• $128 million in damage at up to 400 facilities maintaining hazardous waste and 50 million cubic yards of debris, including 10 million cubic yards of curbside vegetative and construction / demolition waste needing to be recycled or disposed of in landfills;
• $100 million in damage to telecommunications and internet infrastructure, including submerged substations, thousands of downed utility poles, and downed transmission towers, covering a region with over 70 independent telecommunications and internet providers; and
• $1.7 billion in funding to make infrastructure and technology upgrades to secure a more resilient western North Carolina.¹⁵ 

The financial toll of the disaster remains staggering, with nearly $7 billion in total damage and needs. OSBM estimates that the federal government and private sector will cover $6 billion of this total, leaving $730 million still unfunded, even after considering the State’s investments to date.¹⁶

OSBM projects that private businesses will bear more than $1.2 billion in damage costs, drawing from multiple funding sources. Duke Energy, for instance, will shoulder the burden of restoring its infrastructure and will finance the repair costs by issuing storm bonds to cover over $900 million in expenses. These funds will go towards replacing nearly 2,000 transformers, more than 12,000 power poles, and other critical infrastructure devastated by the storm. In western North Carolina, gas providers will rely on a combination of insurance and their internal pipeline integrity mechanisms to manage their $41 million in repair costs. 

Private stormwater system owners are expected to handle $100 million in damage through private insurance claims wherever possible, minimizing public burden. Meanwhile, uninsured private stormwater system owners, including Homeowner Associations (HOAs), will either absorb the repair costs or pass them along to their customers in the form of higher fees over time. Similarly, telecommunications providers facing damage will likely absorb an estimated $100 million in repair costs upfront, then shift those expenses to consumers through rate hikes where feasible.¹⁷

2.3.2 Roads and Bridges

Hurricane Helene has severely impacted approximately 5,000 miles of State-maintained roads across the affected area in western North Carolina, including several major national interstates and arterial routes that serve as critical transportation corridors. The North Carolina Department of Transportation (NCDOT) has found damage to 674 bridges and 712 culverts. Western North Carolina has 25% more public bridges than the State average, with the percentage of private bridges likely even higher due to the terrain and population density. 

The terrain in this region is especially challenging, as it is mountainous with an elevation on average two to three times that of the Piedmont, which complicates road and bridge repairs. Western North Carolina also includes a significant number of privately maintained roads, with municipal and private roads making up 48% of all roads in the region compared to 41% for the State as a whole. This higher proportion of non-State infrastructure adds further complexity to recovery efforts. The following outlines the methodology used to estimate transportation needs resulting from Hurricane Helene. Estimates are based on data provided by government agencies, damage models, historical data, and trends. The total transportation impact is estimated at $10.3 billion, the vast majority of which is anticipated to be covered by federal funding sources. 

Of this total need, the NCDOT highway and bridge system is projected to require $6 billion in repairs and replacements. Once major repair and replacement projects are underway, NCDOT will require substantial cash flow support while awaiting federal reimbursements. The Department's existing cash reserves are already committed to routine operations and ongoing programs, making additional financial resources essential to ensure long-term sustainability and the continued functionality of vital infrastructure. 

Structures in scope for transportation estimates include: 

• Public roads, bridges, tunnels, and sidewalks maintained by the State;
• Municipal roads, bridges, tunnels, and sidewalks;
• Private roads, bridges, and culverts;
• Public transit, including bus systems;
• Rail and rolling stock; and
• Ports and airports.

Private Roads and Bridges – The OSBM’s Disaster Recovery section has extrapolated data from previous storms, such as Tropical Storm Fred, to estimate the impact on private infrastructure in counties affected by Hurricane Helene. OSBM used this to estimate the potential number of affected private roads and bridges across counties hit by Hurricane Helene and scaled up the impact based on North Carolina Emergency Management (NCEM) advice on the severity of the damage relative to previous events. Private roads make up almost half of all roads in the region – more than 7,000 private roads, bridges, and culverts have been damaged. 

While FEMA has already approved funding for over 3,000 minor repairs, significant support will be needed for larger repair and replacement projects. The unique nature of the mountainous terrain in western North Carolina presents additional challenges requiring specialized approaches to road and bridge repair, and the figure below is indicative of the terrain and issues faced in establishing and maintaining access to homesites via private roads and bridges. Note the steep incline of the road and the fact that there is significant washout along the edges of the road.

Key issues of concern for repair of Helene-related infrastructure damage include:

• Construction costs: The assessment for infrastructure damage conservatively assumes construction costs will be 15% higher than estimated due to a shortage of available construction services and/or an increase in the cost of raw material and labor driven by multiple concurrent disasters across the Southeast. Experience from Hurricanes Matthew, Katrina, Harvey, and Florence, and Superstorm Sandy suggests similar shortages drove construction costs 8-20% higher in the aftermath of the event.¹⁸ In addition, Hurricane Helene construction costs are likely to be driven up by the continued impact of the pandemic recovery and more difficult terrain.
• Damage Magnitude: Proportional damage numbers, e.g., percent of roads damaged or destroyed, from county severity classification and inspection of locations with higher flooding, landslides, and road incidents.
• Hazard Mitigation Costs: The damage to road and bridge infrastructure across the Helene-impacted area is substantial, and hazard mitigation measures will be necessary to reduce future risks and long-term costs. OSBM estimates that $1.7 billion will be needed for infrastructure and technology upgrades across Western North Carolina, including improvements to strengthen transportation, utilities, and other critical systems. Of this total, $1.28 billion is expected to be allocated for hazard mitigation efforts specifically related to roads and bridges. This estimate was calculated by applying OSBM-reported mitigation cost factors, which range from 10% to 30% of total repair and replacement costs, to the $6 billion in state-maintained road and bridge damage, $1.38 billion in municipal road network damage, and $460 million in private road and bridge damage. Using midpoint values within these ranges, a conservative estimate of $1.28 billion was determined.

2.4 Economic Revitalization

Western North Carolina is forever changed in the wake of the devastating impacts of Hurricane Helene, significantly impacting the area’s economy. Thousands of businesses in the region suffered damage from rushing flood waters, landslides, wind, and falling trees. Even businesses spared from direct damage were often cut off from workers and customers due to washed-out roads or being unable to open due to extended outages of electricity, water, sewer, and communications. 

The findings of this analysis confirm that the economic devastation from Hurricane Helene is unparalleled in modern State history: nearly $16 billion in total impact. The total includes an estimated $3 billion in damage to business and non-profit property, including structures, equipment, and vehicles; plus $435 million in needs for hazard mitigation; and more than $12.4 billion in economic loss from reduced business revenue, resulting in billions of dollars less income for workers and business owners. OSBM estimates payments from private insurance, federal grants and subsidized loans, State funding, unemployment insurance, and other assistance will cover about $3 billion of the $16 billion total damage and needs.

Most of the damage from Hurricane Helene was concentrated in the western third of the State. Western North Carolina is home to scenic parks and cultural attractions that drive tourism and support local hospitality, retail, and restaurant businesses. Seasonal tourism surrounding “peak leaf season” in fall is particularly important in many of the counties most affected by Helene, with local businesses regularly citing the relative importance of October to annual revenue. The mountains receive nearly 30% of annual visitor spending in fall and early winter, totaling more than $2 billion in western North Carolina during the prior fall season. 

Several counties within the affected region rely on arts, entertainment, recreation, accommodation, and food services for 5% or more of total employment, much higher than the 1-3% share for those industries in most other areas of the State. Of the 100 counties in the State, 39 are eligible for FEMA IA. Those counties: 

• Make up 45% of the State’s total GDP (20% excluding Mecklenburg and Forsyth Counties);
• Host 115,237 separate employer business establishments (46% of which have five or fewer employees);
• Are home to an additional 384,000 “mom and pop” businesses with no employees and $18.7 billion in receipts;
• Had an average unemployment rate of 3.3% in 2023, lower than the State average of 3.5%.
• Are home to unique businesses that play major roles in supplying products for specific industries, including Baxter International in McDowell County, an intravenous (IV) fluid manufacturer whose North Carolina plant supplies 60% of IV fluids nationwide, and quartz mining operations in Spruce Pine, which supply most of the world’s high-purity quartz for semiconductors and other technologies worldwide.¹⁹ Following Hurricane Helene, some businesses have begun to clean up and reopen after initial disruptions but face obstacles to complete recovery, particularly in the hardest-hit counties. 

Although regional unemployment data lags the effects of major disaster events, initial unemployment claims in the State in the week after Hurricane Helene spiked to more than three times the average in 2024 thus far. Although unemployment in the region was, on average, lower than the State unemployment rate before the storm, the unemployment rate in the affected region rose to a range of 6% to 9% in the month after Hurricane Helene struck. 

As of March 23, 2025, FEMA provided more than 157,000 households with housing and other assistance related to the effects of Hurricane Helene, totaling approximately $410 million in support. FEMA assistance to families helps sustain local consumer spending, which helps businesses that remain open but are experiencing lower sales from a lack of out-of-town visitors. 

FEMA reported that over 90% of gas stations, grocery stores, and pharmacies in the area affected by Helene had resumed conducting transactions by October 13. These locations represent key consumer staples, and spending levels in these stores were nearing pre-Helene levels. Other businesses, however, are operating far below pre-Helene levels.

Agricultural Economic Impacts

Economic damage in the agricultural sector due to Helene is estimated at $4.9 billion. The direct damage and needs estimate is $4.1 billion, comprising farm infrastructure, machinery, and equipment damage; crop, forestry, and trout farm losses; stream debris removal and stabilization needs; agricultural land restoration needs; wildfire risk response; and mitigation efforts. Livestock, dairy, and poultry producers experienced significant infrastructure damage but limited animal losses.  

There is an estimated additional $783 million in indirect and induced impacts from crop losses. In addition to these economic “ripple effects” from crop losses, the disruption of the peak tourism season in the region will have substantial, but unquantified, impacts on agricultural businesses. Agritourism and direct-to-consumer sales are a significant part of the agricultural economy in western North Carolina. Federal funding requests estimated insurance coverage, and State appropriations to date are expected to cover $1.6 billion of the damage, leaving $3.3 billion unfunded.

Agricultural production in the mountains tends to be predominantly small, diverse operations. As of 2022, U.S. Department of Agriculture – National Agricultural Statistics Service (USDA-NASS) survey data indicates there were approximately 18,600 farms in the 37 western counties impacted by Hurricane Helene. This western region is also home to large fresh produce farms. The region’s proximity to large population centers in the Southeast and its cooler mountain climate allow it to grow cool season crops near large markets.²⁰

Agricultural production in the region is primarily specialty crops with limited federal crop insurance coverage. The Greenhouse, Nursery, and Floriculture sector is the largest sector of the farming community with annual revenues of over $400 million. Nursery and vegetable produce operations were particularly devastated by Hurricane Helene. Many of these businesses are located in low-lying areas that suffered the worst flooding and swift water destruction. The majority of vegetable, nursery, and sod crops in these locations were lost. Initial estimates indicate that over 80% of plant nurseries were destroyed and inventories can take one to eight years to re-establish.

Beyond the immediate production losses, for the agricultural community to recover, significant remediation efforts are needed to restore farmland, pasture, and forestland from the effects of high winds, landslides, extreme erosion, sediment deposits, and stream redirection.

3. Mitigation Needs Assessment

Western North Carolina also includes a significant number of privately maintained roads and bridges, with municipal and private roads making up 48% of all roads in the region compared to 41% for North Carolina as a whole. This higher proportion of non-state-maintained infrastructure adds further complexity to recovery efforts. The Office of State Budget and Management (OSBM) has extrapolated data from previous storms, such as Tropical Storm Fred, to estimate the impact on private infrastructure in counties affected by Hurricane Helene. OSBM used this to estimate the potential number of affected private roads and bridges across counties hit by Hurricane Helene and scaled up the impact based on Emergency Management advice on the severity of the damage relative to previous events. 

Private roads make up almost half of all roads in the region – more than 7,000 private roads, bridges and culverts have been damaged. The following table from the Housing Impact Assessment identifies the ten counties with the greatest number of private roads and bridges requiring replacement and repair. As this information is from a FEMA analysis in early November 2024, it is likely to underestimate the actual need.

Table 16: Top 10 Declared Counties with Private Bridges and Roads in Need of Replacement or Repair

While FEMA has already approved funding for over 3,000 minor repairs, significant support will be needed for larger repair and replacement projects. The unique nature of the mountainous terrain in western North Carolina presents additional challenges requiring specialized approaches to road and bridge repair. For this reason, NCDOC is planning on using a substantial portion of its CDBG-DR mitigation set aside to help address these costs for homeowners.   

The following table sets forth NCDOC’s proposed allocation of CDBG-DR mitigation funding across the three core aspects of recovery as cited by HUD.

Table 17: CDBG-DR Mitigation Set-Aside Needs Assessment and Allocation (in millions)

3.1 North Carolina Enhanced Hazard Mitigation Plan

The North Carolina Enhanced Hazard Mitigation Plan (Enhanced HMP), updated in 2023, is a comprehensive, federally approved framework designed to identify and address the State’s most significant hazards. Developed collaboratively by State agencies, local governments, and key stakeholders, including EM professionals and environmental organizations, the Enhanced HMP serves as the foundation for guiding mitigation priorities and strategies statewide. The 2023 update reflects new data, emerging risks, and lessons learned from recent disasters, aligning with FEMA’s hazard mitigation planning requirements and serving as a critical resource for reducing the impact of natural and human-made disasters.

The Enhanced HMP outlines key priorities, including enhancing community resilience, reducing vulnerabilities in infrastructure and housing, and supporting at-risk populations. This mitigation section builds on the Enhanced HMP’s foundation by tailoring strategies to address the impacts of Hurricane Helene, leveraging recent findings from updated damage assessments and integrating targeted recommendations to address unmet needs in housing, infrastructure, and public health. 

3.1.1 Current Mitigation Efforts by the State of North Carolina

The State has developed a range of mitigation programs to address North Carolina’s most pressing vulnerabilities. These initiatives are aligned with the goals of the Enhanced HMP and focus on reducing risks, building community resilience, and improving infrastructure. By prioritizing data-driven strategies and leveraging State and federal resources, these programs aim to address specific hazards while promoting equitable and sustainable recovery efforts. 

Flood Resiliency Blueprint

Led by the NCDEQ, the North Carolina Flood Resiliency Blueprint (the Blueprint) aims to identify and prioritize flood mitigation projects across the State. It provides tools to assist local governments in floodplain management, risk assessments, and implementation of nature-based solutions. Recent projects include comprehensive flood modeling in high-risk counties and the establishment of community-level flood action plans. More information is available at deq.nc.gov.

Natural Infrastructure Flood Mitigation Program

The Natural Infrastructure Flood Mitigation Program (NIFMP), administered by NCDEQ, emphasizes using ecological approaches to mitigate flood risks in key watersheds. Projects include wetland restoration, stream bank stabilization, and the implementation of green infrastructure in urban areas to reduce runoff. The program has successfully funded initiatives that simultaneously improve water quality and reduce flooding. Additional details can be found at deq.nc.gov.

Land and Water Fund Flood Risk Reduction Grant Program

The North Carolina Land and Water Fund’s (NCLWF’s) Flood Risk Reduction Grant Program’s focuses on economically distressed areas, providing grants for designing and implementing flood mitigation projects. Under the auspices of the NC DNCR, the NCLWF continues to prioritize resources for underserved communities and has funded projects such as levee repairs and stormwater management enhancements. More information is available at nclwf.nc.gov.

Hazard Mitigation Assistance Programs 

Administered by North Carolina Emergency Management (NCEM), this suite of programs includes the Hazard Mitigation Grant Program (HMGP), Building Resilient Infrastructure and Communities (BRIC) program, and Flood Mitigation Assistance (FMA) grant program. These programs provide critical funding for long-term mitigation measures, such as elevating homes, reinforcing public buildings, and improving drainage infrastructure. More information is available at ncdps.gov.  

Emergency Management Disaster Relief and Mitigation Fund

The $15 million Emergency Management Disaster Relief and Mitigation Fund, administered by NCEM, supports technical assistance (TA) and disaster relief. It aims to close gaps in recovery and mitigation efforts by ensuring resources are available to communities most in need. Recent allocations have included support for rural areas to develop emergency response capabilities and integrate hazard mitigation into local planning efforts. More details can be found at ncdps.gov.

Priority Hazards Identifid in the North Carolina Enhanced HMP 

The State's Enhanced HMP identifies the hazards that pose the most significant risks to communities across the State. These hazards are prioritized not only based on their potential to disrupt daily life and cause extensive damage but also on their impact on public safety and long-term resilience. By serving as a foundational document, the Enhanced HMP ensures that mitigation strategies align with the State’s overarching goals to protect people, property, and critical infrastructure. Central to this prioritization is the Priority Risk Index (PRI), a systematic tool used to evaluate and rank hazards. The PRI assigns numerical scores to hazards based on five key factors: probability, impact, spatial extent, warning time, and duration. Higher PRI scores indicate greater risk, with scores closer to 3.0 reflecting more severe threats compared to lower scores closer to 1.0, which denote less significant risks. This scoring system ensures that the State focuses its mitigation efforts on the most critical hazards. Historical data from the National Weather Service (NWS) Storm Events Database complements this prioritization by providing empirical evidence on the frequency, severity, and impact of past events. 

Table 18: Hazard Type and Key Impacts

Hurricanes and Coastal Storms 

Mitigation strategies for hurricanes and coastal storms focus on enhancing evacuation procedures, reinforcing coastal infrastructure, and promoting flood-resistant construction practices. Programs like the HMGP and BRIC provide critical funding for these efforts. Mitigation strategies include enhancing evacuation procedures, reinforcing coastal infrastructure, and promoting flood-resistant construction practices. 

Flooding

To address the recurring threat of flooding, the State prioritizes stormwater management, floodplain preservation, and infrastructure improvements. Initiatives such as the Blueprint and NIFMP emphasize nature-based solutions and community-level flood mitigation planning. 

Severe Weather Events

Mitigation strategies for severe weather include public awareness campaigns, advanced early warning systems, and adherence to storm-resistant building codes. These measures aim to reduce the impacts of tornadoes, thunderstorms, and hail on communities and infrastructure. 

Wildfires 

The State’s wildfire mitigation strategies focus on forest management, community outreach on fire prevention, and strategic fuel reduction practices. These efforts aim to minimize wildfire risks while protecting ecosystems and residential areas. Working through the Carolina Land and Lakes Resource Conservation and Development Council (Carolina Land & Lakes), a majority of counties encompassed by the Helene major disaster declaration are beneficiaries of Community Wildfire Defense Grant funding under the Bipartisan Infrastructure Law (BIL) and are updating expired Community Wildfire Protection Plans (CWPPs) or developing their first CWPPs.

Weather-Related Hazards and Adaptation

Mitigation efforts focus on strengthening community resilience to extreme weather events through risk reduction strategies, resilient infrastructure, and adaptation measures. These initiatives help address hazards such as extreme heat, cold, and flooding by enhancing infrastructure durability and reducing long-term vulnerabilities.

Impacts of Hurricane Helene on the State 

The following findings draw upon two key documents that analyze the impacts of Hurricane Helene and provide insights into the vulnerabilities and unmet needs across the State. These documents include the Saint Bernard Project Preliminary Unmet Needs Assessment (SBP PUNA), developed by the Saint Bernard Project (SPB), which assesses housing and infrastructure impacts, and the OSBM report from December 2024, which provides a comprehensive evaluation of the economic, infrastructural, and community-level damages. Together, these reports form the basis for identifying critical gaps and priorities in mitigation efforts. 

Housing Damage 

Hurricane Helene caused severe damage to LMI housing in affected counties, particularly in rural and coastal regions, leaving many unable to return to their homes for prolonged periods. The SBP PUNA documents that over 30% of impacted households experienced displacements in the six months since Hurricane Helene impacted North Carolina. Families often relocated multiple times due to limited housing availability, compounding economic and emotional stress. Recovery challenges were particularly acute in rural areas where affordable housing stock was already limited, underscoring the need for targeted investments in housing resilience. Strategies such as retrofitting homes, elevating structures, and implementing acquisition programs for repetitive loss properties are critical. Funding programs like HMGP and CDBG-DR can support these efforts. 

Critical Infrastructure

Key infrastructure such as transportation networks, water supply, and electricity systems suffered extensive damage during Hurricane Helene. Rural areas experienced power outages that lasted over 21 days, severely disrupting daily life and economic activity. Transportation disruptions further delayed emergency response and supply chains. Infrastructure assessments revealed that 70% of the damaged systems were constructed before 1980, highlighting the pressing need for modernization and improved resilience standards. Coordination with housing strategies is essential, as infrastructure resilience directly supports housing stability. 

Economic Impact 

The OSBM report estimates total economic damage from Hurricane Helene in the tens of billions of dollars, with significant losses in agriculture and fisheries. Crop failures due to prolonged flooding reduced annual revenues by 38% in some counties, crippling local economies and leaving many small farmers without viable recovery paths. Small businesses faced similar challenges, with an average of 45% reporting revenue losses post-disaster. Investment in resilient housing and economic recovery programs is vital to stabilizing these communities. 

Health and Safety 

Public health crises emerged in the aftermath of Hurricane Helene, including spikes in waterborne diseases and increased mental health challenges. Rural healthcare facilities reported a 150% increase in patient volumes, straining limited resources. Long-term mental health impacts were particularly pronounced among displaced populations, with a 30% increase in reported cases of anxiety and depression in impacted areas. Enhancing healthcare capacity and integrating health-focused elements in housing recovery plans are recommended. 

Correlation and Synthesis

The findings from the OSBM report, the SBP PUNA, and the PRI rankings reveal overlapping vulnerabilities that highlight critical areas for intervention. Housing and infrastructure are particularly susceptible to damage from hurricanes and flooding. Furthermore, economic and public health consequences stress the need for integrated mitigation strategies that address immediate recovery and long-term resilience. 

Recommendations for Mitigation Strategies

The recommendations below are derived from the Enhanced HMP and OSBM Hurricane Helene Report.  

One category of major need – addressing mitigation and resilience through repairs to private roads and bridges - cuts across both the housing resilience and the infrastructure categories outlined below. Western North Carolina includes a significant number of privately-owned roads, bridges, and culverts that provide access to individual housing units or small clusters of houses. 

The current estimate of private road and bridge projects to be addressed could be as high as 7,000. FEMA has been addressing the need for permanent repair if the repair is such that a temporary approach would fail to provide the requisite level of safety or emergency access. On this point, FEMA approved funding for over 3,000 minor repairs as of December 2024, but significant support will be needed for larger repair and replacement projects.

However, for many individuals who will qualify for CDBG-DR assistance to rebuild or repair a home, providing access is a critical component of returning them to their homes and they almost uniformly lack the resources to address road and/or bridge repairs.  Further, NCDOC has an interest in mitigating against the possibility that a future flood event could again eliminate their ability to move out of harm’s way. 

OSBM originally projected that $350 million in CDBG-DR funding would be necessary to address needs associated with rebuilding these critical links for homeowners. The reality is that NCDOC will be unable to devote more than $130 million to the effort and proposes to make this investment as part of its overall mitigation strategy.     

1. Enhancing Housing Resilience
   • Improve safety for resident through mitigation and resilience investments that strengthen roads and bridges providing access to housing units that are difficult to access.
     • Implement stricter building codes focused on hurricane and flood resistance, as emphasized in the HMP.
     • Expand funding for retrofitting existing housing and developing affordable, resilient housing stock.
     • Promote acquisition programs for repetitive loss properties and support elevation projects in flood-prone areas, aligning with OSBM recommendations.
   • Example: Retrofitting homes in high-risk areas could yield a 4:1 return on investment by preventing future damages.
2. Upgrading Infrastructure
   • Prioritize investments in stormwater management systems, transportation resilience, and utility redundancy, consistent with HMP goals.
   • Establish regional hubs for emergency services to ensure faster response times, as highlighted in OSBM analyses of infrastructure weaknesses.  
3. Creating Economic Recovery Programs
   • Provide grants and low-interest loans to support small businesses and key sectors like agriculture, addressing economic vulnerabilities outlined in the OSBM report.
   • Establish a State-backed insurance pool to ensure quicker financial recovery, connecting economic stability to housing recovery efforts.  
4. Strengthening Emergency Preparedness
   • Invest in modernized early warning systems and real-time monitoring technologies, aligning with HMP strategies for disaster preparedness.
   • Expand training programs for local EM personnel, with a focus on protecting housing and infrastructure during disasters.
5. Integrating Public Health Measures
   • Strengthen healthcare infrastructure in rural areas to handle surge capacity, a recommendation supported by OSBM findings on post-disaster health impacts.
     • Launch mental health support initiatives and public awareness campaigns on disaster preparedness, integrating health considerations into housing recovery plans. 

Resiliency Efforts: The recovery investments afford an opportune time to efficiently introduce building, infrastructure, and technology upgrades that will ensure that future storms do not cause the same level of destruction, better safeguarding both public safety and economic stability. Four categories of resiliency efforts have been identified: Water Infrastructure Resiliency & Interconnections Fund ($500 million), Stormwater Systems Resiliency ($60 million), Dams Repairs & Overtopping Study ($760 million), and Natural Resource Stewardship ($375 million). Providing resiliency funding for water systems to interconnect to neighboring water systems supports communities with a backup option should a water system go offline for an extended period. 

Due to the terrain in western North Carolina, interconnections that are more common in the rest of the State tend not to exist in the impacted region. DEQ estimates a need of $500 million for interconnections between water and wastewater systems to join two water sources or systems allowing water to be transferred between them. Bolstering stormwater and dam resilience will curb against future catastrophic flooding. Before Hurricane Helene, there was already a high need for repair and upgrades to dams and stormwater systems across the region. DEQ estimates a need of $60 million for stormwater measures for further resiliency, such as wet ponds, bioretention cells, infiltration systems, stormwater wetlands, sand filters, and permeable pavement. 

DEQ estimates an additional need of $760 million to assess and repair high-hazard dams that pose a substantial threat to the health, safety, and welfare of downstream residents and businesses. The renovations for resiliency measures previously made on the North Fork Dam stopped even more catastrophic damage from impacting communities, and additional dams across western North Carolina need to implement similar resiliency measures. DEQ estimates a total of $375 million needed to increase natural resource resiliency. Part of this is a need of $15 million for flood mitigation projects to prepare for future storms through the NIFMP within the Division of Mitigation Services and an additional $20 million to protect water quality, wildlife habitat, and provide open space through DEQ’s Stewardship Program. 

DEQ also identified $40 million in mapping needs, as Hurricane Helene caused over 2,000 landslides in western North Carolina, with 260 of them damaging multiple homes or posing an imminent threat to residents. Last, DEQ requires an estimated $300 million for future-flood resiliency projects in eight river basins, including Hiwassee, Little Tennessee, Savannah, French Broad, Broad River, Catawba, Watauga, and New River, Yadkin-Pee-Dee.²²

Experience Using CDBG Funding for Mitigation Purposes

The State has experience using CDBG funding for mitigation purposes as it received CDBG-Mitigation (CDBG-MIT) funding in the wake of Hurricanes Matthew (2016) and Florence (2018). The State received a total of $202 million of CDBG-MIT funding for these events and has implemented a series of programs and activities that address HUD’s requirements for qualifying mitigation expenditures. These programs and activities are outlined below, and the State will leverage the experience gained with this portfolio to inform and improve its delivery of mitigation actions as part of the Helene recovery. 

• Strategic Buyout Program – This program designates Disaster Risk Reduction Areas (DRRAs) in areas that are particularly vulnerable to property damage from future disasters and provides funding for the purchase of eligible properties in DRRAs.
• Infrastructure Recovery Program – This program provides funding to repair, replace, rebuild, make more resilient, or improve public facilities that were damaged by Hurricanes Florence and Matthew, and engages in public service activities that support community recovery. Projects are prioritized based on their ability to reduce risk and loss of life and property during future disasters and to improve resilience to future severe weather events.
• Public Housing Restoration Fund – This fund provides funding to rehabilitate, repair, or replace PHA properties that were negatively affected by Hurricanes Florence and Matthew. Funds are also used to address unmet recovery long term and mitigation, or to make facilities more resilient from future storm events.
• Affordable Housing Development Fund – The Affordable Housing Development Fund was established to create new housing stock in a way that is more responsive to the needs of the recovering community while mitigating the effects of potential future hazards through resilient design and planning.
• Homeownership Assistance Program – This program allows for up to $20,000 in down payment assistance for eligible applicants and up to $30,000 for applicants who are first-generation homebuyers, plus up to 5% in reasonable and customary closing costs incurred by first-time buyers to move to areas that would be more resilient to potential future hazards.
• Code Enforcement and Compliance Support Program – To account for the increased demand for code enforcement due to increased construction work associated with mitigation activities, the Code Enforcement and Compliance Support Program identifies deteriorated or deteriorating areas and provides funding and resources to carry out code enforcement activities necessary to complete disaster recovery in those areas.

Further, the State has undertaken or completed the following CDBG-MIT funded resilience planning and TA activities:

• Regions Innovating for Strong Economies and Environment (RISE) Regional Resilience Portfolio Program – RISE supported resilience in storm-impacted regions of the State by providing TA to partners to support risk assessments, identify priority risk reduction actions, and enhance resilience.
• NC Resilience Exchange – The NC Resilience Exchange is an online resource for data, case studies, guidance, and funding opportunities for NC communities. The site provides local leaders with information about how hazards will affect their communities and resources to plan and implement projects to address those risks.
• Heat Action Plan Toolkit – The Heat Action Plan Toolkit was developed by the State Climate Office (SCO) of North Carolina and the Carolinas National Oceanic and Atmospheric Administration (NOAA) Climate Adaptation Partnership (CAP) for use by local governments to reduce the human health impacts of extreme heat events and increasing temperatures.  
• Eastern NC Community Floodprints – CDBG-DR and CDBG-MIT planning funds have been deployed to develop landscape planning “floodprints” for MID communities affected by Hurricanes Matthew and Florence.
• NC Resilient Coastal Communities Program (RCCP) – This State, local, and private partnership provided partial funding for TA and financial assistance to help local communities overcome barriers in coastal resilience and adaptation planning, and to boost local government capacity in the State’s 20 coastal counties.
• Statewide Probable Maximum Precipitation Study for North Carolina – NCDEQ is supporting a study of the probable maximum amount of precipitation at a location for a given duration that is meteorologically possible (the “worst case” scenario for rain or snow). This updated data will support watershed and resilience planning by helping governments and other entities plan for the design, location, and relocation of water infrastructure – such as dams, culverts, and drainage networks — and ensure safety and functionality.
• NIFMP and Nature-Based Flooding Solution – NCDEQ is using planning funds to develop the NIFMP.
• Atlas 14 Rainfall Statistics Update – NCDOT is supporting actions to update the NOAA’s “Atlas 14” precipitation intensity, duration, and frequency estimates. This data is used by the public and private sectors for infrastructure design purposes.
• Regional Precipitation Frequency Estimates and Data System – Updates the Statewide Intensity-Duration-Frequency (IDF) curves to account for climate change projections and quantify future climate-related risks.
• Downscaled Climate Projection Development – The SCO is developing a suite of climate projections at smaller spatial scales, such as single watersheds, for use by local and regional stakeholders.

4. Connection Between Proposed Programs and Projects and Unmet Needs and Mitigation Needs Assessments

4.1 Allocation and Award Caps

The NCDOC is the lead agency and responsible entity for administering $1,428,120,000 in CDBG-DR funds allocated for Helene recovery efforts. CDBG-DR funds available to address unmet needs will be allocated to basic program categories pursuant to the table below.

Table 19: CDBG-DR Program Allocation and Funding Thresholds

NCDOC’s program allocation choices have been primarily driven by the OSBM report which indicated housing recovery as being the area having overwhelming direct need.  As there is no other significant source of public funding to promote housing recovery for low- and moderate-income North Carolinians negatively impacted by Helene, NCDOC views CDBG-DR as the appropriate resource for housing recovery given the needs presented. While the allocation of CDBG-DR to housing needs is above a strictly proportional share, NCDOC views this as an appropriate overweighting given the notable lack of other Federal resources available for housing recovery.

To further support the proposed housing allocation, NCDOC notes that substantial infrastructure repair and reconstruction funding is available through FEMA’s Public Assistance program and the US Department of Transportation’s various federal highway programs. Regarding economic revitalization, the SBA has been active in promoting business loan programs that it administers, and the US Commerce Department’s Economic Development Administration received funding in December 2024, a portion of which should ultimately be available to assist western North Carolina. Further, given the extensive damage to agricultural interest, North Carolina is counting on assistance via various programs available through the US Department of Agriculture to help stabilize the long-term situation.
Regarding use of CDBG-DR mitigation funding, NCDOC is opting to use $130 million of the available $186 million to address repetitive problems associated with access to housing via private roads and bridges. The unique and rugged topography of western North Carolina means that flat, easily accessible land is at a true premium and that a high proportion of homes and other housing units can only be accessed by roads and bridges that are not publicly owned. NCDOC cannot implement an effective housing recovery program in western North Carolina without addressing the private road and bridge issue and sees CDBG-DR mitigation funding for these costs as public safety ingress and egress is critical to the long-term viability of housing and communities in this mountainous region.

NCDOC notes that it is not proposing to implement any programs focused on the acquisition or buyout of real property but does permit acquisition as a complimentary eligible activity under each program to be funded. To minimize displacement and assist those who might be displaced by projects funded with CDBG-DR dollars, NCDOC will follow the requirements of the Uniform Relocation Act (URA), applicable HUD and US DOT regulations implementing the URA, as well as other Federal statutes bearing on the rights of individuals and businesses if they are impacted by those Federally funded projects. NCDOC will develop and follow a Residential Anti-Displacement and Relocation Assistance Plan to guide its actions and those of its subrecipients where necessary.

On a related point, NCDOC recognizes HUD’s directive to provide a general exception criteria, when necessary, to maximum award amounts for each program to comply with federal accessibility standards or to reasonably accommodate a person with disabilities.  NCDOC will incorporate this general exception into its policies and procedures for each program.

At a minimum, 70% of program funds must meet the LMI National Objective. The flagship Housing Reconstruction and Rehabilitation (Housing R&R) program will prioritize very low- and low-income households, with the greatest prioritization for households with incomes less than 60% of AMI. Households with income at or above 120% of AMI will not be eligible for this program. 

NCDOC is procuring an implementation vendor to assist with the operation of intake centers for program applicants. This vendor will be procured with an emphasis on ample outreach and program accessibility. In partnership with this vendor, the State will develop a comprehensive outreach campaign and, where applicable and feasible, may provide services and mobile outreach centers to ensure all households have support to complete a pre-application survey, and will provide additional assistance to those invited to formally apply. 

Additionally, households with one or more of the following characteristics will be prioritized and invited to apply in the earliest applicable phase: households with members 62 and older, households with children under the age of 18, and households with special needs or special accommodation requirements (disabled). 

The Workforce Housing Program will be 100% targeted to LMI individuals, including the elderly. The housing ownership opportunities created by this program will also reduce the risk of homelessness by funding developments to serve LMI households. 

Table 20 below responds to HUD’s request for side-by-side review of unmet needs and related program allocations. NCDOC has used the direct impact data collected by OSBM as reflected in Table 3 regarding Quantified Disaster Impacts.  As OSBM did not break out rental versus owner occupied housing, NCDOC opted to allocate 30% of total direct housing need to rental housing and 70% to owner occupied housing which is consistent with many public comments received on the draft Action Plan. The infrastructure unmet need is the sum of the utilities and transportation line items from Table 3 while economic revitalization is the sum of the economy and agriculture line items.  The public service estimate relies upon the health and human services line item from Table 3.

As noted elsewhere in the Action Plan, NCDOC sees restoration of owner-occupied single-family housing as the key to recovery in western North Carolina. The allocation to that purpose is overweight but the estimated unmet need but that allocation is essentially at the expense of infrastructure and economic revitalization activities. Again, NCDOC sees other sources of funding as available to address those needs while housing recovery is substantially reliant on CDBG-DR as a funding source.

4.2 Funding Criteria

4.2.1 Administration

NCDOC allocates $71,406,000 of the total CDBG-DR award for administrative costs associated with the life of the grant. This represents the maximum amount permissible for administrative costs per the CDBG-DR appropriation language of Public Law 118-158 and HUD’s requirements under the Revised Universal Notice. NCDOC advises HUD that it may seek to recover pre-award and/or pre-application costs related to administrative expenses consistent with the guidance provided by Section III.B.14. of the Revised Universal Notice. Such costs may be incurred back to the date of the presidential disaster declaration date (September 28, 2024, for DR-4837-NC).

Table 21: Grantee Administration Activities Overview

4.2.2 Planning

NCDOC is opting not to provide CDBG-DR funding under this allocation for planning activities. The State’s goal is to provide the maximum amount possible for recovery activities given the discrepancy between estimated unmet needs and the CDBG-DR award. Due to the limited initial appropriation, the State will seek to promote planning activities related to recovery by using available State resources and leveraging key partners across the State.

Table 22: Grantee Planning Activities Overview

4.2.3 Housing

The State proposes implementing a series of housing programs to address housing damage caused by Hurricane Helene. These programs will address needs across the housing spectrum, specifically the homeowner, small rental, and larger multifamily segments. Within these programs, there will be the opportunity to address several key priorities expressed by HUD in the Revised Universal Notice, notably supporting public housing and other assisted units. To the extent that special-needs assistance housing has been impacted by Helene, those units may also be eligible for assistance for reconstruction and repair funding. 

Table 23: Housing Programs Overview

4.2.3.1 Reconstruction and Rehabilitation of Owner-Occupied Housing

Table 24: Reconstruction and Rehabilitation of Owner-Occupied Housing Details

The cornerstone of post-Helene housing recovery will involve the reconstruction and rehabilitation (R&R) of owner-occupied, single-family units across counties covered by the HUD-Identified MID designation. The Housing R&R program will prioritize homeowners that have major damage to their unit or a unit that has been destroyed (as both are defined by HUD in the Revised Universal Notice or AAN) with the opportunity to have their homes reconstructed or rehabilitated consistent with applicable code requirements. The program may also provide mitigation funding for:

• Measures designed to protect residents and structures against predictable hazards given their location; and
• Replacement or repair of private roads and bridges that provide access to housing being reconstructed or rehabilitated.  

NCDOC advises HUD that it may seek to recover pre-award and/or pre-application costs related to administrative and construction-related expenses under the Housing R&R program consistent with the guidance provided by section III.B.14. of the Revised Universal Notice. Such costs may be incurred back to the date of the presidential disaster declaration date (September 28, 2024, for DR-4837-NC). NCDOC is hopeful of obtaining access to State funds in the second calendar quarter of 2025 to begin work through the Housing R&R program.  This will enable progress in addressing housing unmet need in the 2025 construction season. 

NCDOC will use contractors to manage and complete the construction process for homeowners approved for funding through the Housing R&R program. With the assistance of staff and contractors, the State will work with a pool of qualified contractors assigned to repair, reconstruct, or replace damaged properties; applicants will not select their own contractors. The program will pay contractors directly, and no funds will be paid to homeowners for construction costs except under the reimbursement option described below. Applicants will be required to enter into agreements with NCDOC setting forth the terms and conditions of the program.

Maximum awards under the Housing R&R program may include funding to implement mitigation and resilience actions, including elevation, restoration, and improvement of private roads and bridges, which reduce the risks to inhabitants and protect the public investment in the reconstructed units. NCDOC emphasizes the fact that the aggressive topography of western North Carolina can make access to home sites impossible without private roads and bridges. To effectively address this problem, the State will use a substantial portion of the mitigation set-aside funding ($130.4 million of $186.3 million) to mitigate against the possibility that LMI homeowners receiving assistance under the Housing R&R program will face similar access problems in the future and ensure access and egress for public safety purposes. 

NCDOC views this approach to mitigation as consistent with guidance provided in section III.D.4. of the Revised Universal Notice which defines mitigation activities as “those activities that increase resilience to disasters and reduce or eliminate the long-term risk of loss of life, injury, or damage to and loss of property, and suffering and hardship, by lessening the impact of future disasters.” Further, this provision instructs grantees “to incorporate mitigation measures when carrying out activities to construct, reconstruct, or rehabilitate residential or non-residential buildings.” NCDOC interprets the investment in resilient private roads and bridges in this mountainous region to be within the scope of this definition and directive.  

Construction standards will be a combination of requirements. The fundamental standard will be the North Carolina Building Code (NC Code). The 2024 Revision of the NC Code will go into effect on July 1, 2025, and for purposes of the Housing R&R program, all construction funded by the Housing R&R program will be subject to the 2024 Revision as all components of the 2024 Revision are accessible on the State Fire Marshall’s website via the link above. Any additional municipal building requirements will apply to construction in that jurisdiction. Finally, construction will comply with standards imposed by HUD in its Revised Universal Notice for all reconstruction of residential buildings and for all reconstruction of substantially damaged residential buildings (i.e., where repair costs exceed 50% of replacement or reconstruction cost). 

All housing units assisted through the Housing R&R program (and related mitigation and access assistance) shall either provide benefit to LMI persons through housing (LMI Housing) or meet Urgent Need (UN) criteria as outlined, respectively, at 24 CFR 570.483(b)(3) and 24 CFR 570.483(d) and modified by the Revised Universal Notice. While NCDOC does not anticipate widespread use of UN National Objective under the Housing R&R program, it may be a necessary, for example, in situations to ensure housing is reconstructed or rehabilitated for certain populations that are over the 80% AMI threshold; promote more complete recovery of small rural communities; or address other anomalies that could halt the provision of assistance to households that lack the resources to recover from the impacts of Helene. In instances where NCDOC uses the UN National Objective to qualify assistance under the Housing R&R program, NCDOC will comply with the requirements of section III.B.2.(iii) of the Revised Universal Notice and document how the activity responds to the urgency, type, scale, and location of the disaster-related impact described in the UNA.

All housing activities will address unmet housing needs in counties encompassed by the Combined MID area and will ensure that all participants in the program can demonstrate that damage to the home can be tied back to damage from Hurricane Helene. 

Recognizing that the funds allocated to the Housing R&R program will likely not address all needs, populations with the greatest needs will be prioritized. At a minimum, at least 70% of program funds must be expended for Housing R&R activities that meet the criteria for the LMI Housing National Objective, but NCDOC is projecting that level to be at least 90%. 

To ensure effective pursuit of LMI benefit in the Housing R&R program, NCDOC will prioritize very low- and low-income households, with the highest prioritization for households with incomes less than 60% of AMI.  As a secondary criterion, households with one or more of the following characteristics will be prioritized and invited to apply in the earliest applicable phase: households with members 62 and older; households with children under the age of 18; and households having physical accessibility needs or individuals with documented disabilities. Applications will be accepted for households between 80 and 120% AMI, but they will be in the final phases and would need to be qualified as meeting the UN National Objective. Households with income at or above 120% of AMI will not be eligible for this program under any circumstance. 

NCDOC is procuring an implementation contractor to assist with the implementation of the Housing R&R Program and the operation of intake centers for program applicants. This contractor will be procured with an emphasis and goal of ample outreach and program accessibility. In partnership with this contractor, NCDOC will develop a comprehensive outreach campaign and, where applicable and feasible, may provide services to ensure eligible households can apply. 

NCDOC is implementing an application process designed to ensure compliance with HUD’s overlapping requirements that at least: 1) 80% of the funds be expended in the HUD-Identified MID area; and 2) 70% of funds be expended for activities that benefit LMI persons. Given these requirements, NCDOC will first invite applications from households in the HUD-Identified MID area and will prioritize those applications based on household income and subsequently on characteristics described above. Accuracy of all information provided by potential applicants through the application process will be verified by NCDOC or its contractor.

Table 25: Application Phasing Criteria for Housing R&R Applicants

Based on comments received during the public comment on the draft Action plan, NCDOC is opting to include a reimbursement component in the Housing R&R program.  Reimbursement will constitute Phase 3 of the Housing R&R program, will only be available to homeowners at or below 80% AMI, and will only be implemented after the managed construction process under Phases 1 and 2 have addressed all applications eligible for funding.

Also pursuant to public comment, NCDOC has opted to change the phasing and prioritization for households at or below 60% AMI in the State-defined MID area. Households in this group have been moved to Phase 1 and have been assigned the 3rd and 4th priority slots while households between 60% and 80% AMI in the HUD-defined MID area have been moved to Phase 2 and assigned the 1st and 2nd priority levels. NCDOC will closely monitor the application portal and may choose not to accept remaining potential applicants to apply or place remaining applicants on hold until prioritized household applicants are fully processed and their needs addressed.

The treatment of MHUs under the Housing R&R program is substantially guided by HUD’s Notice CPD-2023-10, entitled “Use of Community Development Block Grant (CDBG) Funds in Support of Housing,” and issued on October 26, 2023. Several key takeaways from the Notice include the statement that purchases of MHUs that are part of a community’s permanent housing stock are eligible as acquisition or direct homeownership assistance; that land acquisition for placement of the MHU is permissible; and that grantees may consider supporting tenant acquisition of an MHU community as part of an overall strategy. 

Wherever possible, NCDOC shall work to replace severely damaged MHUs or MHUs located on the owner’s property with stick-built or modular housing units of appropriate size based on household size and other factors.  This approach is grounded in the idea that the additional marginal cost associated with a permanent structure is justified given the ability to incorporate additional resilience and mitigation measures, provide greater value appreciation for the owner, and better address site-specific topographical considerations. Alternatively, NCDOC may opt to replace a damaged/destroyed MHU with another MHU based upon a site review and consultation with the homeowner.

In instances where the previous site of a housing unit is no longer viable due to localized changes in the topography or a destroyed or severely damaged MHU is located on leased land, NCDOC may opt to buyout the real property or MHU (as appropriate) as a cost effective approach to relocating the household out of harm’s way. Such buyouts could be accompanied by down payment assistance in certain instance to be defined in the program’s policies and procedures. 

Applicants to the Housing R&R program will be required to provide information regarding all assistance received for recovery purposes as required by section 312 of the Stafford Act. Any funds found to be duplicative will be deducted from the CDBG-DR award prior to the disbursement of the award amount. A review of potential duplication of benefits (DOB) is necessary for all CDBG-DR funded activities as this assistance is intended to supplement—not replace—other public, private, and non-profit sector resources that have already been provided for the same need or loss and are legally required to constitute a duplicative source of financial assistance.

NCDOC will issue uniform policy guidance which will govern DOB process applicable to all CDBG-DR funded programs described in this Action Plan, and that policy guidance will be available on its disaster recovery website. 

Homeowners assisted under this program will generally be required to maintain homeownership and primary residency of the assisted property for a minimum period of three years beginning at the time construction is completed. During this time, NCDOC has the right to request documentation for proof of occupancy to ensure the applicant has continued owning and residing in the home for the required three-year period. The total grant award must be repaid, at a prorated amount, if the homeowner is determined to be out of compliance before the three-year occupancy period has expired. Pursuant to public comment on the draft Action Plan, NCDOC will implement an appeal process to address specific cases where an exception to the three-year requirement may be warranted.  The appeal process will be identified in the program policies and procedures.

A second home is defined in the Revised Universal Notice as a home that is not the primary residence of the owner, a tenant, or any occupant at the time of the disaster or at the time of application for CDBG–DR assistance. Second homes, vacation residences, and short-term, seasonal, and vacation rental properties are not eligible for assistance under the Housing R&R Program. Applicants who purchased or moved into a damaged property after the date of FEMA’s major disaster declaration for Helene in North Carolina are not eligible for assistance under this program. 

The funds awarded under the Housing R&R program may not be used for the following actions:

• Forced mortgage payoffs.
• Compensation payments.
• Temporary housing assistance benefits, including mortgage and rental assistance.
• Reconstruction of housing units in a designated floodway.

NCDOC shall prepare detailed operating policies and procedures for the Housing R&R program which will both provide greater definition on points highlighted herein and serve as working guidance for the implementation of the program. 

4.2.3.2 Workforce Housing for Ownership

Table 26: Workforce Housing for Ownership Details

There is a distinct need within the HUD-Identified MID counties for additional homeownership opportunities that are affordable to broader segments of the workforce to incentivize them to remain in western NC following Helene and to partially remedy inadequate housing production in past years across western NC. The term “workforce,” as used under this program, refers to households up to 80% of AMI.  

To address this need, the Workforce Housing for Ownership (WHO) program will fund development of workforce housing units for ownership. Qualified local governments, public, private, or non-profit organizations, and Community Development Housing Organizations (CHDOs)/Community Based Development Organizations (CBDOs) may be eligible to apply for WHO program funds.

NCDOC anticipates conducting only one application round in 2026 for the WHO program. The competitive criteria will reflect HUD’s standard approach to competitive programs outlined in the HUD Grants Management Handbook (HUD Handbook 2210.17) and summarized below. NCDOC will further define these criteria when it issues the notice of funding opportunity (NOFO) for the WHO Program. 

Table 27: Competitive Framework - Workforce Housing for Ownership Program

For clarity purposes, HUD and the public are advised that 100% of WHO Program funds will be expended in the Combined MID area and that 100% of funds will be expended for units to be purchased by qualifying LMI individuals. 

NCDOC will make exceptions to the maximum award amounts, when necessary, to comply with federal accessibility standards or to reasonably accommodate persons with physical disabilities.

Scoring criteria will be described in the NOFO documents and will incorporate concepts focused on project site; development team experience; project readiness; resilient and/or innovative design components; community need; value of the CDBG-DR investment; level of community engagement; unit and income mix; and the leveraging of partnerships. Consistent with public comment received on the draft Action Plan, NCDOC will also establish policies to achieve geographic distribution within the HUD-defined MID area. If funds remain after the initial selection round, any subsequent round will also be competitive consistent with criteria used in the initial round. 

4.2.3.3 Multifamily Construction and Repair Program

Table 28: Multifamily Construction and Repair (MCR) Program Details

The Multifamily Construction and Repair (MCR) Program seeks to reconstruct, rehabilitate, or construct the rental housing stock in a way that is responsive to the needs of Helene-impacted communities. The program will fund reconstruction/rehabilitation activities and new construction and will entertain applications from two categories of projects: small projects having seven or few units and large projects having eight or more units.  Projects may be either single structures or may involve multiple structures in proximity to one another. Pursuant to public comments received on the draft Action Plan, both small and large projects may include mixed-use components, with requirements to be identified in the notice of funding availability and program policies and procedures. 

The small project component will provide a priority for projects in the HUD-Identified MID area and will adopt an “open application window” for qualifying projects, meaning that applications may be submitted at any time so long as funding remains available. NCDOC is suballocating approximately 30% or $57,400,000 of the total allocation for small projects. To implement this program, NCDOC will require property owners/applicants to use contractors selected to participate in the single-family Housing R&R program to assure effective cost and quality control. NCDOC will assign a contractor to a project upon submission of a pre-application. 

Each award will be calculated using consistent program construction and award calculation standards, which are summarized further in this section and will be detailed in the program guidelines. The maximum amount of grant assistance will be $1,500,000 per project, including any mitigation costs, while the minimum will be $250,000. NCDOC may make exceptions to the maximum award when necessary, to comply with federal accessibility standards or to reasonably accommodate persons with disabilities. 

Because each award will be evaluated based on a necessary and reasonable scope of work (SOW) and cost of materials using industry standard cost estimating software, comparative market analysis, or price per square foot and/or review of multiple construction bids, NCDOC anticipates that on average, most awards will be lower than the maximum award. 

For this program, the NCDOC will prioritize applications from property owners who owned the property   as of September 28, 2024, the date of the Helene major disaster declaration.  

For the large project component (eight or more units), eligible applicants will be multifamily property owners and developers including, but not limited to:

• For-profit entities;
• Non-profit organizations;
• Public sector partners, such as local governments, PHAs, and other designated public agencies;
• CHDOs; and
• CBDOs.

The large project component will be suballocated 70% or $133,940,000 of the total allocation for the program. The program structure will be competitive in nature and NCDOC will conduct multiple rounds to select projects for funding. Proposals will be evaluated and selected pursuant to project application processes issued by NCDOC via NOFOs. Each NOFO will establish the details for application associated deadlines, selection criteria, and the award process. NCDOC has increased the maximum amount available for a project from $10 million to $15 million based upon public comment received on draft Action Plan.

NCDOC will consult with the North Carolina Housing Finance Agency (NCHFA) regarding projects that may seek or have been awarded LIHTCs. NCDOC will implement a funding priority for projects located in Difficult Development Areas (DDAs) and Qualified Census Tracts (QCTs) within the Combined MID area regardless of whether the project is receiving LIHTCs. In designing the large project criteria, NCDOC will design such efforts in consultation with NCHFA.

• Difficult Development Areas (DDAs) - NCDOC has sought criteria which may help to further refine the targeting of assistance to communities across western North Carolina. One useful tool is HUD’s DDA designation which identifies areas with high construction, land, and utility costs relative to area median gross income. This designation helps attract Low Income Housing Tax Credit (LIHTC) projects to the DDA by providing enhanced tax benefits to projects located in the DDA, thereby making those projects more attractive to investors. 
  Two counties in western North Carolina have DDA designations by HUD for 2025: Avery and Transylvania. In addition, there are seven (7) DDAs in the Asheville Metro Fair Market Rent (FMR) area and are designated by zip codes: 28704; 28732; 28759; 28790; 28801; 28803; and 28804. Additional DDAs are in the Iredell County Metro FMR area (zip codes 28036 and 28117) and the Hickory/Lenoir/Morganton Metropolitan Statistical Area (MSA) (zip code 28673 and 28682). Finally, there are six DDAs in the Charlotte-Concord-Gastonia Metro FMR area: 28705; 28079; 28202; 28203; 28204; and 28277. NCDOC will leverage these designations to target certain programs to the benefit of the DDA areas.
• Qualified Census Tracts (QCTs) - Similarly, NCDOC will examine the use of the QCT concept to also target CDBG-DR funding to areas of need. QCTs are defined as areas where at least half of households have incomes less than or equal to 60% of AMI or a poverty rate of 25% or higher. Counties in the Combined MID have QCTs, representing approximately 86 census tracts based on HUD’s 2025 data.  NCDOC believes this designation holds value for targeting CDBG-DR funds to historically distressed communities and will seek to incorporate it within overall constraints on the use of the funds.

The definition NCDOC will use for affordable rent is the same as the HOME Investment Partnerships Program (HOME) definition. These rental limits are updated periodically and are calculated by metro area or county, and specific affordable rent limits are updated annually. Units created or rehabilitated using CDBG-DR funds for rent must not exceed these rent limits, based on the geographic location and bedroom size of the unit. New construction project will be obligated to a 20-year affordability period, again using HOME criteria.

NCDOC will evaluate proposals and prioritize proposals for projects which are located within the HUD-Identified MID area. New construction and rehabilitation must occur outside of the HUD-defined floodplain, or where floodplain designation is peripheral and distinct from the location of any planned development activity for the project.

NCDOC anticipates conducting multiple application rounds over the next several years for the large project component of the program. The competitive criteria will reflect HUD’s standard approach to competitive programs outlined in the HUD Handbook 2210.17 and summarized below. NCDOC will further define these criteria in its forthcoming policies and procedures and will repeat those criteria when it issues the NOFO for the program. 

Table 29: Competitive Framework – Multifamily Construction and Repair Program

The above categories will incorporate the following criteria which will be further outlined in program NOFO:

• Site location and suitability;
• Proposer capacity;
• Affordability structures, with a preference for projects with units set aside to serve Extremely Low Income and Very Low Income populations;
• Proposals with units and amenities set aside for those with disabilities or for special needs populations;
• The total development cost versus the CDBG-DR share of that cost;
• Proposal feasibility;
• Proposed development’s Readiness to Proceed;
• Coordination with resiliency and disaster recovery planning and/or design; and
• Proposals or solutions which present innovative and leveraged approaches to the affordable housing problem after disaster.

Specific prioritization for the selection of projects will be published prior to the launch of applications and, consistent with public comment received on the draft Action Plan, NCDOC will also establish policies to achieve geographic distribution within the HUD-defined MID area.

4.2.4 Infrastructure

Table 30: Infrastructure Program Overview

4.2.4.1 Community Infrastructure Program

Table 31: Community Infrastructure (CI) Program Details

The Community Infrastructure (CI) Program will deploy CDBG-DR funding to aid local governments by funding:

• “Stand-alone” projects, which may be funded with up to 100% CDBG-DR funding, and are necessary to address identified unmet disaster recovery needs arising from the impact of Helene in communities and counties that are not funded by other federal recovery; and
• Improvements to FEMA-assisted PA or HMGP funded projects, if such improvements improve resiliency, useful life, or otherwise provide a housing recovery benefit or long-term housing need not covered by the PA or HMGP portion of the project.

This competitive program provides funding for infrastructure projects that will help impacted communities become more resilient to current and future natural hazards. The program will require mitigation components to be included within the scope(s) of awarded projects to advance long-term resilience. Applicants will be asked to itemize costs and benefits when submitting applications for funding, in accordance with program requirements to be outlined by NCDOC. Proposed activities must also consider local plans and policies; reduce future risk to the recovering jurisdiction or municipality; and include an analysis of how multiple sources of funds may be leveraged to complete the project.

In evaluating applications, NCDOC will consider a variety of projects such as:

• Projects which demonstrate adaptable and reliable technologies to guard against premature obsolescence;
• Projects with a substantial amount of other funding available;
• “Shovel ready” projects;
• Projects which provide greater benefit to housing recovery; and
• Projects which serve areas with higher LMI percentages will be favored in the scoring criteria.
• NCDOC will not entertain requests to fund county or local government emergency operations centers. 

NCDOC anticipates conducting only one application round for the CI program. The competitive criteria will reflect HUD’s standard approach to competitive programs outlined in the HUD Handbook 2210.17 and summarized below. NCDOC will further define these criteria when it issues the NOFO for the program. 

Table 32: Competitive Framework − Community Infrastructure Program

NCDOC will review projects for CDBG-DR and program eligibility and will select projects based on scoring and ranking approaches that are in alignment with NOFO and application processes. Consistent with public comment received on the draft Action Plan, NCDOC will also establish policies to achieve geographic distribution within the HUD-defined MID area.

4.2.5 Economic Revitalization

Table 33: Economic Revitalization Programs Overview

4.2.5.1 Commercial District Revitalization

Table 34: Commercial District Revitalization (CDR) Program Details

NCDOC is establishing the Commercial District Revitalization (CDR) program for eligible local governments and non-profit organizations to revitalize designated commercial districts damaged by Hurricane Helene.  Encouraging economic opportunities, while supporting the recovery of commercial areas, is essential to ensuring that commercial tenants, customers, and jobs are restored. By facilitating the return of commercial districts and businesses to profitability, jobs will be created or retained within the community and residents will continue to have access to the products and services they need within their local community. 

NCDOC must focus its investment in the HUD-Identified MID area and will structure the application process to provide a priority for eligible applicants in that area. Eligible uses of funds under the CDR will include, but not be limited to: 

• Acquisition, demolition, site preparation, or rehabilitation of commercial structures carried out by a subrecipient;
• Assistance to small businesses for rehabilitation and physical improvements to their places of business;
• Mixed-use projects involving commercial revitalization and housing components; and
• Facade improvements to private or public structures in commercial areas.

The inclusion of mixed-use projects under this program is a direct response to public comments received on the draft Action Plan and will be further clarified. Note that CDBG-DR funds may not be used under this program for the purpose of acquiring property through the exercise of eminent domain authority.  

NCDOC anticipates conducting two application rounds for the CDR program. The competitive criteria will reflect HUD’s standard approach to competitive programs outlined in the HUD Handbook 2210.17 and summarized below. NCDOC will further define these criteria when it issues the NOFO for the program.

Table 35: Competitive Framework – Commercial Revitalization Program

NCDOC will review applications for CDBG-DR and program eligibility and will select projects based on scoring and ranking approaches that are in alignment with NOFO and application processes. Consistent with public comment received on the draft Action Plan, NCDOC will also establish policies to achieve geographic distribution within the HUD-defined MID area.

4.2.6 Public Services

NCDOC will not fund or implement any stand-alone public service programs as part of this Action Plan.  However, NCDOC may opt to provide specific public services as part of the delivery of the three housing recovery programs identified in section 4.2.3. above. 

4.2.7 CDBG-DR Mitigation Set-Aside

Table 36: CDBG-DR Mitigation Set-Aside Programs Overview

The CDBG-DR Mitigation Set-Aside, pursuant to HUD’s Allocation Announcement Notice, is $186,277,000. These funds have been allocated to each of the five programs described through this section and will be integrated into projects and activities funded through those programs. NCDOC’s approach is consistent with HUD’s directive to ensure that funded projects and activities incorporate mitigation and resilience components. It is not NCDOC’s intention to operate a stand-alone mitigation program and, as a result, there are no individual mitigation programs. The table below reflects the spread of the Mitigation Set-Aside funding across housing, infrastructure, and economic revitalization programs.

Table 37: Grantee CDBG-DR Mitigation Set-Aside Programs Overview

5. General Information

5.1 Citizen Participation

NCDOC invites and encourages citizen participation in the Action Plan development process and subsequent amendments with a focus on outreach to LMI persons and disaster-impacted communities,. This approach is consistent with NCDOC’s existing citizen participation plans related to annual CDBG funding and prior CDBG-DR awards to the State related to Hurricanes Matthew and Florence. 

NCDOC will advertise opportunities for comment on the Action Plan through various State and local resources. Additionally, NCDOC will work with Councils of Government throughout western North Carolina to ensure that local voices are heard through local forums.  NCDOC is committed to ensuring that all populations impacted by the storm are aware of and have equal access to information about the programs to assist in the recovery from Hurricane Helene. Through in-person meetings, outreach events, and online and traditional media, NCDOC has publicized existing programs, will publicize changes to such programs, and has conducted outreach efforts throughout the storm impacted areas. 

NCDOC will post its full Citizen Participation Plan to the CDBG-DR website at Disaster Recovery | NC Commerce. 

5.1.1 Consultation in Developing the Action Plan

NCDOC has undertaken a broad outreach program to obtain feedback on unmet needs in the Helene-impacted area. Consistent with HUD’s guidance in the Revised Universal Notice, NCDOC developed a survey tool which was distributed to several hundred entities across the state in late January. This collection of interested parties spans not only the list identified by HUD (see Table 38: Action Plan Consultation Efforts below) but goes well above and beyond HUD’s expectations. The survey approach enabled NCDOC to gather broader and more valuable feedback than would have been possible with a series of in-person or teleconference meetings.  

The survey tool (included as Appendix 7.4 to this Action Plan) identified a series of issues to help frame unmet needs across western North Carolina and provided respondents with multiple responses as well as the opportunity to provide additional contextual feedback. NCDOC will retain the full set of responses and have them available for inspection by HUD and other interested parties. The survey indicates a low level of satisfaction among respondents regarding the current state of housing supply in their community following Hurricane Helene. On this point, 121 responses collectively yielded a satisfaction level of 3 out of 10 (with 10 being the highest level). Similarly, when respondents were asked about the current state of housing conditions in their communities, the satisfaction level crept up to 4 out of 10. When respondents were presented with a list of potential programs and asked to rank them in importance from 1 to 7 (1 being most important), housing reconstruction and rehabilitation were seen as the most important needs, but it is important to note that housing-oriented programs occupied the top four spots followed by an infrastructure improvement program. 

Overall, NCDOC’s proposed program is highly reflective of the feedback received during this consultation effort with more than $1.052 billion to be dedicated to housing needs and $193.5 million for infrastructure needs. These two areas account for 87% of the State’s CDBG-DR allocation of $1.428 billion.  

NCDOC’s approach to consultation is that it is a team effort and the agency has collectively sought information from across the full spectrum of Governor Stein’s team since he took office on January 1, 2025.  NCDOC does not see itself as operating in vacuum and seeks to leverage the multiple discussions of the Governor’s team on issues that will directly or indirectly impact the success of initiatives funded through CDBG-DR. The composite nature of this information has been invaluable in development of the Action Plan and look forward to sustaining these discussions as the program moves toward implementation.

Table 38: Action Plan Consultation Efforts

5.1.2 Public Comments

NCDOC takes seriously the need to collect and evaluate public comments offered on the draft Action Plan and subsequent amendments. Comments were received at public hearings (as described below in section 5.1.3) and through a form on the NCDOC website to collect feedback and comments from individuals and organizations who found that approach more convenient. Collected comments and responses are included as the last attachment to the Action Plan. Based on these comments, NCDOC made several changes to the draft Action Plan such as including a reimbursement option within the Housing R&R program and specifically permitting mixed use projects under the Multifamily and Commercial Revitalization programs. 

5.1.3 Public Hearings

Since the amount allocated by HUD to NCDOC exceeds $500 million, NCDOC was required to conduct at least three public hearings on the draft Action Plan in the HUD-Identified MID area as required by section I.C.2.b. of the Revised Universal Notice. NCDOC worked with Councils of Government (CoGs) throughout western North Carolina to facilitate these hearings. Each of the six CoGs sent out the public information session to the local governments and housing partners in their regions.  Others also published the information on their websites and at least one took advanced registration information. The details of these hearings are provided below:

Table 39: Hearing Details

Each of these hearings was conducted in accordance with the public hearing standards outlined in the Revised Universal Notice. 

5.1.4 Citizen Complaints

NCDOC shall provide a written response to every complaint relative to CDBG-DR within fifteen (15) working days of receipt. NCDOC will execute its Appeals Process in response to appeals received and will require subrecipients to adopt a similar process. The process will enable appeals and further review from another level. All subrecipients will be required to develop an appeals and complaint procedure to handle all complaints or appeals from individuals who have applied for or have an interest in CDBG-DR funding. 

A written appeal may be filed when an individual is dissatisfied with program policies, eligibility, level of service, or other issues. The appeal shall include a statement of facts and circumstances regarding the situation as well as any supporting documentation that substantiates the claim. Materials related to the appeal may be submitted to NCDOC via email at helene.recovery@commerce.nc.gov. NCDOC will review the submitted materials and provide the appellant with a written response, which may be by email. If NCDOC denies the appeal, the final step in the internal appeals process is to appeal to the Secretary of the NCDOC. In programs that serve individual applicants, applicants may appeal their award determinations or denials that are contingent on program policies. However, it should be noted that the NCDOC does not have the authority to grant an appeal of a statutory, regulatory, or HUD-specified CDBG-DR requirement.

5.1.5 Modifications to the Action Plan

5.1.5.1 Substantial Amendments

NCDOC identifies the following criteria which constitute a substantial amendment: 

• A change in program benefit or eligibility criteria;
• The addition or deletion of an activity or program;
• An allocation or reallocation of $28.562 million or more. This threshold represents 2% of the total CDBG-DR allocation;
• Any proposed reduction in the overall benefit requirement which currently requires that at least 70% of the full $1.428 billion CDBG-DR allocation must be expended for activities that benefit low- and moderate income persons; or  
• Any update to the Action Plan if the original submission was deemed incomplete by HUD.

Pursuant to section I.C.6.a of the Revised Universal Notice, NCDOC will make substantial amendments available for public comment for no less than 30 days. Amendments will be posted online at Disaster Recovery | NC Commerce. Following the public comment period, NCDOC will address comments received and then submit the substantial amendment for HUD’s review and approval. NCDOC will address any question and make any revisions sought by HUD and, once the amendment is approved, immediately act to implement the amendment. Every amendment to the Action Plan (substantial and non-substantial) will be numbered sequentially, cited in the Action Plan change log, posted on the NCDOC’s CDBG-DR website, and consolidated into the Action Plan.

5.1.5.2 Non-Substantial Amendments

A non-substantial amendment is an amendment to the plan that includes technical corrections and clarifications and budget changes that do not meet the threshold for substantial amendment thresholds noted above and does not require posting for public comment. NCDOC will notify HUD five (5) business days before the change is effective. All amendments will be numbered sequentially, cited in the Action Plan change log, and posted to the Action Plan as available on the CDBG-DR website.

6. Appendix

6.1 Certifications

NCDOC acknowledges that it will administer the CDBG-DR grant consistent with the following certifications required by Federal statute and regulation.

Certifications Involving Waivers and Alternative Requirement

• a. Uniform Relocation Act (URA) and Residential Anti-displacement and Relocation Plan (RARAP)—NCDOC certifies that it:
  1. will comply with the acquisition and relocation requirements of the Uniform Relocation Act, and implementing regulations at 49 CFR part 24, as such requirements may be modified by waivers or alternative requirements;
  2. has in effect and is following a RARAP in connection with any activity assisted with CDBG–DR grant funds that fulfills the requirements of Section 104(d), 24 CFR part 42, and 24 CFR part 570, as amended by waivers and alternative requirements.
• b. Authority of Grantee—NCDOC certifies that the Action Plan for disaster recovery is authorized under State and local law (as applicable) and that NCDOC, and any entity or entities designated by NCDOC, and any contractor, subrecipient, or designated public agency carrying out an activity with CDBG–DR funds, possess(es) the legal authority to carry out the program for which it is seeking funding, in accordance with applicable HUD regulations as modified by waivers and alternative requirements.
• c. Consistency with the Action Plan—NCDOC certifies that activities to be undertaken with CDBG–DR funds are consistent with its action plan.
• d. Citizen Participation—NCDOC certifies that it is following a detailed citizen participation plan that satisfies the requirements of 24 CFR 91.115 or 91.105 (except as provided for in waivers and alternative requirements). Also, each local government receiving assistance from a State grantee must follow a detailed citizen participation plan that satisfies the requirements of 24 CFR 570.486 (except as provided for in waivers and alternative requirements).
• e. Consultation with Local Governments – NCDOC certifies that it has consulted with all disaster-affected local governments (including any CDBG entitlement grantees), Indian Tribes, and any local public housing authorities in determining the use of funds, including the method of distribution of funding, or activities carried out directly by the State.
• f. Use of Funds—NCDOC certifies that it is complying with each of the following criteria:
  1. Purpose of the funding. Funds will be used solely for necessary expenses related to disaster relief, long-term recovery, restoration of infrastructure and housing, economic revitalization, and mitigation in the most impacted and distressed areas for which the President declared a major disaster pursuant to the Stafford Act (42 U.S.C. 5121 et seq.).
  2. Maximum Feasibility Priority. With respect to activities expected to be assisted with CDBG–DR funds, the Action Plan has been developed so as to give the maximum feasible priority to activities that will benefit low- and moderate-income families.
  3. Overall benefit. The aggregate use of CDBG–DR funds shall principally benefit low- and moderate-income families in a manner that ensures that at least 70 percent (or another percentage permitted by HUD in a waiver) of the grant amount is expended for activities that benefit such persons.
  4. Special Assessment. NCDOC will not attempt to recover any capital costs of public improvements assisted with CDBG– DR grant funds, by assessing any amount against properties owned and occupied by persons of low- and moderate-income, including any fee charged or assessment made as a condition of obtaining access to such public improvements, unless:
     • (a) disaster recovery grant funds are used to pay the proportion of such fee or assessment that relates to the capital costs of such public improvements that are financed from revenue sources other than under this title; or
     • (b) for purposes of assessing any amount against properties owned and occupied by persons of moderate income, NCDOC certifies to the Secretary that it lacks sufficient CDBG funds (in any form) to comply with the requirements of clause (a)
• g. Grant Timeliness—NCDOC certifies that it (and any subrecipient or administering entity) currently has or will develop and maintain the capacity to carry out disaster recovery activities in a timely manner and that NCDOC has reviewed the requirements applicable to the use of grant funds.
• h. Order of Assistance—NCDOC certifies that it will comply with the statutory order of assistance listed in Appendix C paragraph 9 and will verify if FEMA or USACE funds are available for an activity, or the costs are reimbursable by FEMA or USACE before awarding CDBG–DR assistance for the costs of carrying out the same activity.

Further, as required by Paragraph 64 of HUD’s March 19, 2025, memorandum revising Appendix B of HUD’s Universal Notice issued on January 8, 2025, NCDOC hereby provides assurance that it shall comply with the following certifications:

• a. General Certifications at 24 CFR 91.325(a)(1), (3), and (7)
• b. Community Development Block Grant Program Certifications at 24 CFR 91.325(b)(5), (6), and (7). 

6.2 Waivers

NCDOC does not request any waivers as part of the initial submission of this Action Plan for Disaster Recovery but may seek waivers in the future.

6.3 North Carolina Community Helene Questionnaire

Below are the questions that were used in collecting feedback from individuals and community level organizations as part of NCDOC’s consultation effort. 

1. What type organization do you represent?  
2. What County (or counties) does your organization represent? Select all that apply.
3. On a scale from 0 to 10, How would you rate the current state of housing supply in your community following Hurricane Helene? 0 being extremely poor, 10 being the excellent.
4. On a scale from 0 to 10, How would you rate the current state of housing conditions in your community following Hurricane Helene? 0 being extremely poor, 10 being excellent.
5. On a scale from 0 to 10, How would you rate the economy in your community following Hurricane Helene? 0 being extremely poor, 10 being excellent.  
6. Have any particular populations in your community been underserved in the recovery process from Hurricane Helene?  
7. Please rank these programs 1-7, 1 being the most important to your community, 7 being the least:
   • Homeowner Repair/Reconstruction Program: Direct repair to Helene damaged homes as well as reconstruction of homes that were completely destroyed.  
   • Workforce Housing for Ownership.  
   • Small Rental Repair: Reconstruction/rehabilitation of small rental properties with seven or fewer units.  
   • Multi-Family: Program to reconstruct, rehabilitate or construct new rental housing stock.  
   • Community infrastructure program: Fund projects that are necessary to address identified unmet disaster recovery needs in communities and counties that are not funded by other federal recovery programs.  
   • Business Sustainment Grants: The Business Sustainment Grant (BSG) Program addresses the distinct needs of the thousands of small businesses and microenterprises by rapidly providing funding that will enable them to retain employees and sustain operations as the western North Carolina economy recovers from the aftermath of Hurricane Helene.  
   • Commercial District Revitalization: Assist small and rural communities in addressing recovery needs in local commercial districts in effort to retain jobs and shopping/service opportunities for residents.  
8. Not-including state and nationally-led programs, are there any ongoing locally-organized disaster recovery initiatives in your community?  
9. Are there any additional unmet needs resulting from Hurricane Helene?

6.4 Standard Form 424

Application for Federal Assistance Standard Form 424 (SF-424)

6.5 Public Comments and Responses on Draft Action Plan

As required under the terms of Revised Universal Notice, NCDOC is providing a full accounting of public comments received between February 18, 2025, and March 20, 2025, on the draft Action Plan. Comments were collected via several means pursuant to the NCDOC citizen participation plan for its CDBG-DR funding. NCDOC has provided a response to each comment.

Table 40: Public Comments and Responses

¹ HUD issued a revised Universal Notice Action Plan Guide and Template on March 20, 2025,and NCDOC has altered its presentation of this table as referenced in the Guide and Template for clarity while still providing key information sought by HUD.

² Estimated aggregate percentages for LMI benefit are weighted based on funding allocations and program projections.

³ Much of the damage and unmet need information reflected in this Action Plan was initially developed as part of a December 2024 report for the North Carolina Office of State Budget and Management (OSBM). The complete report can be viewed at Hurricane Helene Damage and Needs Assessment. The content of the OSBM report has greatly assisted in the rapid preparation of the Action Plan and is gratefully acknowledged.

⁴ A more refined estimate for housing damage and needs appears in the housing portion of the unmet needs analysis in section 2 of the Action Plan.

⁵ While OSBM has been in communication with the Eastern Band of Cherokee Indians, they had not yet completed damage assessments as of December 2024. Further, OSBM has not included direct damage to federal lands in this assessment, as assessment and recovery work will be completed by the federal government.

⁶ December 2024 Report for the NC OSBM, Page 32

⁷ This table is a reiteration of Table 1.

⁸ The HUD-Identified MID includes five zip codes: 28645 (Caldwell County), 28150 (Cleveland County), 28753 (Madison County), 28214 (Mecklenburg County), and 28782 (Polk County). Source: HUD ACS 5-year 2016-2020 Low- and Moderate-Income Summary Data.

⁹ Source: Combined MID area omits Charlotte/Mecklenburg and Winston-Salem/Forsyth CoCs.  PIT and HIC Data 2007 – 2023 

¹⁰ Source: Combined MID area omits Charlotte/Mecklenburg and Winston-Salem/Forsyth CoCs.  PIT and HIC Data 2007 – 2023 

¹¹ Source: 2023 ACS 5-year Estimates DP04

¹² Sources: Housing Choice Vouchers; LIHTC Properties; Public Housing Units

¹³ LIHTC refers to Low Income Housing Tax Credits, a federal tax incentive that promotes development of affordable housing.

¹⁴ December 2024 Report for the NC Office of State Budget and Management (OSBM) Page 47

¹⁵ December 2024 Report for the NC OSBM, Page 48

¹⁶ December 2024 Report for the NC OSBM, Page 49

¹⁷ December 2024 Report for the NC OSBM Page 56

¹⁸ December 2024 Report for the NC OSBM, Page 19

¹⁹ NPR. “A tiny town just got slammed by Helene. It could massively disrupt the tech industry.” October 1, 2024. 

²⁰ Of the 39 FEMA-designated counties, Lee and Nash are excluded from this analysis as they were only impacted by tornadic activity.

²¹ Sourced from OSBM Report table referenced in section 1.2.1.3 of the Action Plan. Infrastructure amount is sum of Strengthening and Mitigation amounts for Utilities and Natural Resources plus Transportation.  Economic Revitalization amount is sum of amounts indicated for Economy plus Agriculture. 

²² December 2024 Report for the NC OSBM, Page 52