Radford Road Amended Urban Revitalization Area Plan_InitiateCopyrighted
April 4, 2022
City of Dubuque Items to be set for Public Hearing # 2.
City Council Meeting
ITEM TITLE: Set Public Hearing for Radford Road Amended Urban Revitalization
Area Plan
SUMMARY: City Manager recommending City Council set a Public Hearing for April
18, 2022, regarding the proposed Radford Road Urban Revitalization
Area designation.
RESOLUTION Setting a public hearing for the proposed amendment to
the Radford Road Urban Revitalization District Area Plan
SUGGESTED Receive and File; Adopt Resolution(s), Set Public Hearing for April 18,
DISPOSITION: 2022Suggested Disposition:
ATTACHMENTS:
Description Type
Proposed Amendment to the Radford Road Urban City Manager Memo
Revitalization Area Plan-MVM Memo
Staff Memo Staff Memo
Resolution Setting Hearing Resolutions
Notice of Public Hearing Supporting Documentation
Proposed Amendment to Radford Road Urban Supporting Documentation
Revitalization Plan
Exhibit A - Boundary Areas Supporting Documentation
Concentrated Areas of Poverty Map Supporting Documentation
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Set Public Hearing for Radford Road Amended Urban Revitalization Area
Plan
DATE: March 31, 2022
Housing and Community Development Director Alexis Steger is recommending City
Council set a Public Hearing for April 18, 2022, regarding the proposed Radford Road
Urban Revitalization Area designation.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
v
Mic ael C. Van Milligen
MCVM:sv
Attachment
CC' Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Alexis Steger, Housing and Community Development Director
THE CITY OF
DUB EE
Masterpiece on the Mississippi
TO: Michael C. Van Milligen, City Manager
FROM: Alexis Steger, Housing and Community Development Director
DATE: March 31, 2022
Dubuque
*America City
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ZU07 • 2012 • 2013
RE: Set Public Hearing for Radford Road Amended Urban Revitalization Area
Plan
Introduction
This memorandum presents information necessary for the April 18, 2022 public hearing
regarding the proposed Radford Road Urban Revitalization Area designation.
Background
A Petition for Radford Road Amended Urban Revitalization Area Designation was
received by the City on March 31, 2022 to support a new development of low-income
housing being proposed by Horizon Development Inc. The attached proposed plan will
amend an existing Urban Revitalization District and provide for a ten-year residential
exemption on the value of improvements, including new construction, for the proposed
affordable housing development.
The development plan received provides for the construction of a 60-unit planned
affordable residential housing development. Horizon Development Group, Inc. is
proposing a $12.9-million-dollar project utilizing private financing, Tax Credit Equity,
and Tax Exemption incentives to finance the project. The Urban Revitalization tax
exemption will show local support for the project, which will strengthen Horizon
Development Group, Inc.'s Low Income Housing Tax Credit application to the Iowa
Finance Authority.
City staff has been informed that there will be a second petition for an amendment to
the Radford Road Urban Revitalization Area Designation, but it has not been received
to date. The potential development is within the proposed district area being
presented, and therefore will not need another amendment to the area if received.
Urban Revitalization Chapter 404 of the Iowa Code (Urban Revitalization Act)
authorizes cities to designate areas as urban revitalization areas. Improvements to
qualified real estate within these designated areas may receive a total or partial
exemption from property taxes for a specified number of years. The exemptions are
intended to stimulate private investment by reducing tax increases that usually
accompany property improvements. This additional private investment provides a long-
term increase or stabilization in the area's tax base, enhances the visibility of
revitalization areas and/or supports important city objectives such as historic
preservation, economic development and affordable housing development.
In order to implement the provisions of Chapter 404, the City must determine the area
is eligible for exemption, prepare a revitalization plan for each designated area, and
hold at least one public hearing after proper notice. The law mandates specific criteria
and procedures must be followed.
Discussion
Chapter 404 provides for a public comment period prior to amending an urban
revitalization plan. Based upon these requirements, the Council would hold a public
hearing on April 18, 2022 that provided a comment period on the proposed plan.
Consistency with City Council Goals & Priorities
The City of Dubuque reviews applications for city support to ensure the request is
consistent with the City Council Goals & Priorities. The Amended Radford Road Urban
Revitalization Area Designation furthers City Council goals of having "Livable
Neighborhoods and Housing: Great Place to Live" and "Partnership for a Better
Dubuque: Building our Community that is Viable, Livable, and Equitable".
This project also furthers the "Management in Progress" efforts to support Low Income
Housing Tax Credits Program/Projects.
Consistency with the Consolidation Plan
The U.S. Department of Housing and Urban Development (HUD) requires communities
who receive Community Development Block Grant (CDBG) funds to complete a five-
year Consolidated Plan that identifies general areas of need in the community and how
to address them, particularly in the areas of housing, economic opportunity, and
community development.
The City of Dubuque reviews applications for city support to ensure the request is
consistent with the needs identified in the current Consolidated Plan.
The Amended Radford Road Urban Revitalization Area meets the objectives identified
in the Consolidated Plan Needs Assessment to "Provide opportunities to maintain,
improve, obtain and develop affordable housing", and "Provide for implementation of fair
housing opportunities".
Source of Income Committee
In December 2014, the City Council approved formation of a Source of Income
Committee to conduct a two-year study examining the HCV program and its relationship
to fair housing, with a goal of identifying ways to enhance fair housing in Dubuque (see
Attachment C).
In February 2017, the Source of Income Committee ultimately recommended a
collective impact approach to adopt and implement a mix of educational, outreach, and
financial programs to increase housing provider participation in the HCV program.
These recommendations are found in the Comprehensive Plan:
Adopt and implement a mix of educational / outreach programs to increase
participation in HCV program.
Adopt and implement a mix of financial incentives / policies for creation of HCV
units throughout community.
Based on the Source of Income Committee recommendations, the City now requires
housing developers to accept HCV participants in conjunction with approval of an
affordable housing development agreement related to an urban revitalization plan.
Location
Affordable housing projects are given a priority for city support if they are located
outside an area of concentrated poverty based on the recommendations of the
Voluntary Compliance Agreement and U.S. Department of Housing and Urban
Development. The Amended Radford Road Urban Revitalization Area is outside the
area of concentrated poverty and therefore meets this objective.
Opportunity Areas
Iowa's LIHTC program calculated the "high" and "very high" opportunity areas as part of
the State of Iowa's Analysis of Impediments to Fair Housing Choice. IFA and the Iowa
Economic Development Authority are required to conduct such an analysis because
both agencies administer HUD funding. One of the components of the Analysis is to
identify Opportunity Areas.
HUD adapted the Communities of Opportunity model to calculate opportunity index
scores for each census block group on six separate dimensions: Prosperity, Labor
Market Engagement, Job Access, Mobility, School Proficiency, and Community Health.
Each dimension analyzed for Iowa's Analysis of Impediments to Fair Housing
Choice includes a collection of variables describing conditions for each census tract in
the State.
The Radford Road Urban Revitalization Area is in a designated "high" opportunity
area.
Community Input
All projects requesting city support are required to hold a community meeting, where at
a minimum, residents within a 200-foot radius of the project receive an invitation.
Horizon Development Group, Inc. will hold a community meeting on April 4, 2022.
Comments received will be presented at the Public Hearing.
Relocation
The Amended Radford Road Urban Revitalization Area would be new construction,
therefore no persons, families, business or others would be displaced for this project.
3
Recommendation
Staff recommends the City support these efforts to promote quality, affordable housing,
with attention to the needs of families. The Amended Radford Road Urban
Revitalization Plan provides affordable family housing outside the area of concentrated
poverty, and is in a location with proximity to key community services and living wage
job opportunities.
Action Requested
I respectfully request the City Council set a public hearing for April 18, 2022.
12
Prepared by Alexis Steger Housing & Community Devel 350 W. 61" St Suite 312 (563) 690-6072
Return to Adrienne N. Breitfelder, City Clerk, 50 W. 131h St., Dubuque, IA 52001, (563) 589-4100
RESOLUTION NO. 111-22
RESOLUTION SETTING A PUBLIC HEARING FOR THE PROPOSED AMENDMENT
TO THE RADFORD ROAD URBAN REVITALIZATION DISTRICT AREA PLAN
Whereas, the City Council of the City of Dubuque approved the Radford Road
Urban Revitalization District on January 7, 2019; and
Whereas, Horizon Development Inc. has proposed to construct a 66-unit
residential housing development for low-income residents and requests an amendment
of the Radford Road Urban Revitalization District Area Plan; and
Whereas, the area proposed for designation under the Urban Revitalization Act
there is need for public improvements related to housing; and the encouragement of
housing and residential development as defined by Section 404.1(5) of the Iowa Code;
and
Whereas, Chapter 404 of the Code of Iowa provides that a public hearing shall
be held on any proposed Amended Urban Revitalization Area Plan; and
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF DUBUQUE, IOWA:
Section 1. That the Radford Road Urban Revitalization Plan as proposed meets
the eligibility criteria of Chapter 404.1(5) of the Code of Iowa.
Section 2. That the proposed Amended Radford Road Urban Revitalization Area
Plan attached hereto, shall be a matter of record and shall be available for public
inspection in the office of the City Clerk at City Hall, 50 West 13th Street, Dubuque,
Iowa.
Section 3. That the City Clerk is directed to publish notice of a public hearing on the
Amended Radford Road Urban Revitalization Area Plan to be held on April 18th, 2022
at 6:30 p.m. in the City Council Chambers, 350 West 6th Street, Dubuque, Iowa 52001.
Passed, approved and adopted this 4th day of April, 2022.
Attest:
CI°�/�cPinm e //Y &Vul,
Adrienne N. Breitfelder, City Clerk
CITY OF DUBUQUE, IOWA
OFFICIAL NOTICE
NOTICE is hereby given that the Dubuque City Council will conduct a public hearing on
the 18th day of April, 2022, at 6:30 p.m., and conducted virtually, at which meeting the
City Council will review and approve an amendment to the Radford Road Urban
Revitalization Plan.
Due to the ongoing COVID-19 pandemic, the City Council will meet virtually through
GoToMeeting. The official agenda will be posted the Friday before the meeting and will
contain listening, viewing, and public input options. The City Council agenda can be
accessed at https://cityofdubuque.novusagenda.com/AgendaPublic/ or by contacting
the City Clerk's Office at 563-589-4100, ctyclerk(cr cityofdubug ue.org.
Copies of supporting documents for the public hearings are on file in the City Clerk's
Office, City Hall, 50 W. 13th St., Dubuque, Iowa, and may be viewed during normal
working hours. To comply with social distancing mandates, documents can be viewed
at nttps://www.cityofdubugue.org/Agendas or by contacting the City Clerk's Office at
563-589-4100.
Written comments regarding the above public hearings may be submitted to the City
Clerk's Office, 50 W. 13th St., Dubuque, IA 52001, on or before said time of public
hearing. At said time and place of public hearings all interested citizens and parties will
be given an opportunity to be heard for or against said proposal.
Individuals with limited English proficiency, vision, hearing or speech impairments
requiring special assistance should contact the City Clerk's Office at (563) 589-4100,
TDD (563) 690-6678, ctyclerk@cityofdubuque.org as soon as feasible. Deaf or hard -of -
hearing individuals can use Relay Iowa by dialing 711 or (800) 735-2942.
Adrienne N. Breitfelder
City Clerk
Amended Radford Road Urban Revitalization Plan
Established, November 2018; Amended February 2020 and
April 2022
1.0 Introduction
The following plan describes certain provisions of the Iowa Urban Revitalization
Act and proposes the amendment of the Radford Road Urban Revitalization Area.
The State of Iowa, under Iowa Code Chapter 404, allows cities to designate areas
as urban revitalization districts. Under this Act, improvements to qualified areas
may receive a total or partial exemption from property taxes for a specified number
of years. The exemptions are intended to stimulate private investment by the
reduction of tax increases related to property improvements.
Once an area is deemed to meet the requirements established in Chapter 404, a
plan must be established which identifies the district boundaries, property owners,
existing conditions, proposed plans and the basic abatement provisions for the
revitalization area.
Iowa Code Chapter 404.1 lists five reasons for which a city or county may establish
urban revitalization plans. These include:
1. The existence of numerous buildings that are dilapidated or deteriorated,
detrimental to the public health, safety, or welfare of the area
2. An area challenged by the presence of a substantial number of deteriorated
or deteriorating structures along with additional other defective or unsafe
conditions impairing the provision of housing
3. An area in which there is a predominance of buildings or improvements
which by reason of age, history, architecture or significance should be
preserved or restored to productive use.
4. An area which is appropriate as an economic development area as defined
in section 403.17.
5. An area designated as appropriate for public improvements related to
housing and residential development, or construction of housing and
residential development, including single or multifamily housing.
The Amended Radford Road Urban Revitalization Plan will be based upon the
need for the encouragement of housing and residential development.
2.0 The Area
2.1 Location
Exhibit A identifies the location of the Revitalization District in the City of
Dubuque. The area encompasses undeveloped or underdeveloped parcels
situated on Wolff Road, Pennsylvania Avenue and Radford Road.
Amcndcd Radford Road Urban Rcvitalization Plan
February 2020
Pagc 2 of 7
2.2 Zoning
1895 Radford Road or Lot 1-1 Wolff Place No. 2 was re -zoned per ordinance
33-18 as OC Office Commercial District on November 17, 2018 to
accommodate a multi -residential structure. 1865 Radford Road or Lot 2-1 Wolff
Place No. 2 was rezoned OC Office Commercial District on February 17, 2020
to accommodate a multi -residential structure.
Other parcels in the area are zoned as Light Commercial, General
Commercial, Neighborhood Shopping Center District and Planned
Commercial. For development of low-income housing, parcels will need to be
re -zoned to OC Office Commercial District or OR Office Residential District to
be considered for tax abatement in this Urban Revitalization District.
2.3 Existing and Proposed Land Use
The subject properties have been used as farmland with no structures on the
site, undeveloped greenspace, temporary parking for adjoining properties, and
commercial space with structures.
The proposed land use is OC Office Commercial District for low -moderate
income multi -residential structures.
2.4 Assessed Valuations and Owners of Records
Parcel #
Legal Description
Zoning
LOT 1-2-1-1-A BLK 2 NORTHRANGE INDUSTRIAL
1020378019
PARK
C-3
General Commercial
Commercial Service with
CSc/C-
Conditions/General
1020378015
LOT 1 WOLFF PLACE NO 3
3
Commercial
Commercial Service with
CSc/C-
Conditions/General
1020378010
LOT 2-2 NORTHRANGE INDUSTRIAL PARK #2
3
Commercial
LOT 2-2-1-1 BLK 2 NORTHRANGE INDUSTRIAL
1020378011
PARK
C-3
General Commercial
1020406088
LOT 2 PIZZA RANCH PLACE
PC
Planned Commercial
Light Industrial with
1020376004
LOT 1-1 NORTHRANGE INDUSTRIAL PARK #3
Llc
Conditions
LOT 2-1-PT-1-1-1 BLK 2 NORTHRANGE
1020377001
INDUSTRIAL PARK
LI
Light Industrial
1020377011
LOT 2-1 WOLFF PLACE NO. 2 EXC LOT A-2-1
OC
Office Commercial
1020452033
LOT 2-1-A NORTHRANGE SUB #1
C-3
General Commercial
Commercial Service with
CSc/C-
Conditions/General
1020378016
LOT 2 WOLFF PLACE NO 3
3
Commercial
Amcndcd Radford Road Urban Rcvitalization Plan
February 2020
Pagc 3 of 7
Neighborhood Shopping
1020406037
LOT 1 BLK 11 SUNNYSLOPE ESTATES
C-2
Center
1020451001
LOT 2 BLK 1 NORTHRANGE INDUSTRIAL PARK
C-3
General Commercial
1020376005
LOT 2-1 NORTHRANGE INDUSTRIAL PARK #3
C-3
General Commercial
1020377010
LOT 1-1 WOLFF PLACE NO 2
OC
Office Commercial
BAL LOT 1-2-1-1 BLK 2 NORTHRANGE INDUSTRIAL
1020378018
PARK EXC LOT 1-2-1-1-A
C-3
General Commercial
BAL LOT 2-1-1-1 BLK 1 NORTHRANGE INDUSTRIAL
1020452031
PARK EXC LOT 2-1-1-1-A
C-3
General Commercial
1020452034
BAL LOT 2-1 NORTHRANGE SUB #1 EXC LOT 2-1-A
C-3
General Commercial
UNIT #A RADFORD COURT SHOPPING CENTER
CONDOMINIUMS LOCATED ON LOT 4 BLK 11
1020406085
SUNNYSLOPE ESTATES
PC
Planned Commercial
UNIT #B RADFORD COURT SHOPPING CENTER
CONDOMINIUMS LOCATED ON LOT 4 BLK 11
1020406086
SUNNYSLOPE ESTATES
PC
Planned Commercial
2021 Valuation for Existing Parcels, 2022 Valuations for Amended/Added Parcels
1020378019
64,280
0
0
64280
1020378015
173,250
103,080
0
276330
1020378010
138,150
85,280
0
223430
1020378011
140,380
160,800
0
301180
1020406088
404,800
0
0
404800
1020376004
262,290
0
0
262290
1020377001
351,210
1,060
0
352270
1020377011
202,500
0
0
202500
1020452033
49,650
0
0
49650
1020378016
156,820
106,340
0
263160
1020406037
87,250
273,500
0
360750
1020451001
150,910
559,860
0
710770
1020376005
131,730
510,300
0
636430
1020377010
199,500
0
0
199500
1020378018
106,280
32,080
0
138360
1020452031
159,300
147,310
0
306610
1020452034
224,250
0
0
224250
1020406085
80,760
279,090
0
359850
1020406086
80,760
394,920
0
475680
Amended Radford Road Urban Revitalization Plan
February 2020
Page 4 of 7
2.5 City Services
This area is served by city services.
3.0 Relocation
No relocation should occur due to the rehabilitation of the parcels identified for
expansion of this district. Should relocation occur because of rehabilitation in
the proposed district, the person(s) causing a qualified tenant to be displaced
shall pay all the relocation costs of the tenant as a condition for receiving a
tax -exemption under Iowa Code Section 404.3. "Qualified tenant" shall mean
the legal occupant of a residential dwelling unit which is located within this
designated revitalization area and who has occupied the same dwelling unit
continuously for one year prior to the city's adoption of this plan pursuant to
Iowa Code Section 404.2.
4.0 Qualification of Areas
This revitalization area is for new construction on undeveloped or
underdeveloped parcels, of low-income housing units. Only parcels properly
zoned and providing low-income housing units are eligible.
Parcels in the Amended Radford Road Urban Revitalization Area that are not
in need of economic development for the purposes of new construction, low-
income housing as provided for in this plan are excluded from eligibility for tax
incentives provided for in this plan.
The housing in the area consists of single-family homes.
Exhibit B shows the Revitalization Area in comparison to areas of
concentrated poverty. This Revitalization Area supports the initiative to create
affordable housing units outside the area of concentrated poverty.
The Revitalization Area is adjacent to Eleanor Roosevelt Middle School and
Carver Elementary School. Within one mile of the Revitalization Area there is
a childcare center, county library, grocery store, pharmacy, retail
establishments, local transit, and restaurants.
Additionally, there are several employment opportunities within one mile of the
Revitalization Area, which include the establishments listed above as well as
many industrial and commercial employers such as Kendall Hunt Publishing,
Amended Radford Road Urban Revitalization Plan
February 2020
Page 5 of 7
Geisler Brothers, Rite Hite, Weber Paper, A.Y. McDonald, and the Dubuque
Regional Humane Society, among numerous others.
4.1 Historic Significance
The Amended Radford Road Urban Revitalization Area has been used as
farmland. There have been no buildings constructed on the qualifying parcels
to date.
5.0 Revitalization Program
5.1 Tax Exemption
a) New construction low-income residential property, assessed as residential
or assessed as commercial property, if the commercial property consists of
three or more separate living quarters with at least seventy-five percent of
the space used for residential purposes, will be eligible for property tax
exemption. The property tax exemption will be in accordance with the Code
of Iowa, Chapter 404.3(4), providing for a ten-year, 100% exemption of the
actual value added by the improvements.
b) "Qualified real estate" means real property, other than land, which is located
in a designated revitalization area and to which improvements have been
added, during the time the area was so designated, which have increased
the actual value by at least fifteen percent, or at least ten percent in the case
of real property assessed as residential, or which have, in the case of land
upon which is located more than one building and not assesses as
residential property, increased the actual value of the buildings to which the
improvements have been made by at least fifteen percent.
c) Property tax exemption shall be available only for `new construction'. "Actual
value added" means the actual value added as of the first year for which
the exemption was received.
d) Any construction or improvements that were assessed before the area was
officially designated will not be eligible for exemption. Construction begun
prior to one year prior to the area becoming designated will not be eligible
for exemption. All exemptions existing at the time of the repeal of the
Amended Radford Road Urban Revitalization District shall continue until
their expiration.
e) New Construction must result in a structure meeting applicable building,
plumbing, mechanical, electrical, and other code requirements of the City
of Dubuque.
Amended Radford Road Urban Revitalization Plan
February 2020
Page 6 of 7
f) The actual value of the improvements must result in an increase in
assessed value as stated above in (b). Each year that an application is
made for tax exemption, the assessed value must have increased in that
year by the required percentage.
g) The area became a Revitalization Area commencing upon the adoption of
the ordinance approving this Revitalization Area by the City Council on
January 7, 2018. The designation of the Amended Radford Road Urban
Revitalization Plan Area will remain in effect until the desired level of
revitalization has been attained. Upon repeal of the ordinance establishing
this revitalization area, all existing exemptions would continue until their
previously established expiration date.
5.2 Availability of funding
There are two active programs, which may provide a source of funding for
residential and commercial improvements to the proposed district. These
include; Community Development Block Grant Funds (CDBG), Housing Tax
Increment Financing.
6.0 Application Procedure
This area, upon designation, will follow the procedures for application and granting
of the property tax exemption within the City of Dubuque.
a) The property owner must apply for an exemption by February 1st of the
assessment year for which the exemption is first claimed, but not later than
the year in which all the improvements included in the project are first
assessed for taxation, or the following two assessment years, in which case
the exemption is allowed for the total number of years in the exemption
schedule. Upon the request of the owner, the governing body of the City
may provide by resolution that the owner may file an application no later
than February 1 of the tenth assessment year.
b) The application must contain, at a minimum, the following:
a. The nature of the improvements,
b. The cost of the improvements,
c. The actual or estimated date of completion, and
d. The tenants occupying the property as of the date of the City's
resolution adopting this plan.
c) The City reviews all applications to determine whether the improvement
project conforms to the revitalization plan, is within a designated area, and
if the improvements were made during the appropriate time period. If the
project meets all three criteria, the City shall forward the application to the
assessor by March 1st, with a statement as to which exemption applies.
Amended Radford Road Urban Revitalization Plan
February 2020
Page 7 of 7
Applications for exemptions for succeeding years on approved projects
shall not be required.
d) The local assessor shall review each application by making a physical
review of the property, to determine if the improvements made increased
the actual value of the qualified real estate by at least fifteen percent or ten
percent in the case of real property assessed as residential property. If the
assessor determines that the actual value of that real estate has increased
by at least the requisite percent, the assessor shall certify the property
valuation, determined pursuant to the tax exemption schedule, to the
County Auditor at the time of transmitting the assessment rolls. The
assessor shall notify the applicant of the determination, and the assessor's
decision may be appealed to the local board of review at the time specified
in Iowa Code. The property owner may also refile an application in a
subsequent year after additional improvements have been made.
e) After the tax exemption is granted, the assessor shall continue to grant the
tax exemption, with periodic physical review by the assessor, for the ten-
year time period specified in the tax exemption schedule.
f) An application for exemption received by February 1 in any year after the
year in which the improvement was completed and first assessed for
taxation, is a late application. Late application may be made in any year up
to the tenth year following completion of the improvement. The exemption
period will be the remainder of the ten-year period, which began upon
completion of the improvement, except the total number of years in the
exemption schedule will be allowed if a claim for exemption is filed within
two years of the February 1 filing deadline.
7.0 Conclusion
The proposed urban revitalization district will encourage new construction to
provide needed housing units. After the ten-year abatement period lapses, the
full assessed value of the property will go on the tax rolls to the benefit of the
entire community.
EXHIBIT A & B (Maps)
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Legend N
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of Dubuque, IA
Concentrated Areas of Poverty by Census Tract
City of Dubuque, IA
Proposed Affordable Housing Projects
ARM
102.01
101.04
Dubuque City Li its
Census Tracts
12.02
all
9
.03
7.02
8.02 8.01
101.01
101.05
Highest povert tracts: 26.7% - 29.5% of population below poverty measure
N Source: American C mmunity Survey 2020 5-Year Estimate (2016-2020)
11 IT �I 1 -111 LI 111 11",UL, 111
-111LI, .11
0 1 2 4
Miles