Delegation of Authority for Environmental Certifying Officer in accordance with 24 CFR Part 58 Copyrighted
June 2, 2025
City of Dubuque CONSENT ITEMS # 10.
City Council
ITEM TITLE: Delegation of Authority for Environmental Certifying Officer in
accordance with 24 CFR Part 58
SUMMARY: City Manager recommending that City Council approve the
delegation of the responsibilities of the Certifying Officer
under HUD regulations to the acting Housing and Community
Development Director.
RESOLUTION Delegating Authority For Environmental
Certifying Officer
SUGGUESTED Receive and File; Adopt Resolution(s)
DISPOSITION:
ATTAC H M ENTS:
1. MVM Memo
2. HCDD Delegation and Authorization of Certifying Officer - Staff Memo
3. HCDD Delegation and Authorization of Certifying Officer - Resolution
Page 519 of 2490
Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Delegation of Authority for Environmental Certifying Officer in accordance
with 24 CFR Part 58
DATE: May 28, 2025
Assistant City Manager and Interim Housing & Community Development Director Cori
Burbach is recommending that City Council approve the delegation of the
responsibilities of the Certifying Officer under HUD regulations to the acting Housing
and Community Development Director. This delegation would remain until revoked by
Mayor Brad Cavanagh or the end of his term.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
�
Mic ael C. Van Milligen
MCVM:sv
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager & Interim Housing & Community
Development Director
Maddy Haverland, Urban and Housing Rehabilitation Project Manager
Page 520 of 2490
Dubuque
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TO: Michael C. Van Milligen, City Manager
FROM: Cori Burbach, Assistant City Manager and Acting Housing and Community
Development Director
SUBJECT: Delegation of Authority for Environmental Certifying Officer in accordance
with 24 CFR Part 58
DATE: May 27, 2025
Introduction
The City of Dubuque Housing and Community Development Department is a recipient
of multiple streams of funding from the U.S. Department of Housing and Urban
Development (HUD). These funds are subject to environmental review, decision-
making, and action responsibilities under the National Environmental Policy Act (NEPA)
and 24 CFR Part 58, "Environmental Review Procedures for Entities Assuming HUD
Environmental Responsibilities".
Discussion
The Certifying Officer (CO) is an important role for environmental review and
compliance and defaults to the highest-ranking official in a jurisdiction, which in the City
of Dubuque, is Mayor. The CO authorizes requests for release of funds upon
completion of Environmental Reviews under 24 CFR Part 58, as well as accepting on
behalf of the City of Dubuque the jurisdiction of the federal courts for the enforcement of
all these responsibilities. Therefore, it is essential that the CO understands the
responsibilities provided in 24 CFR Part 58, its related Federal authorities listed in
Sections 58.5 and 58.6, as well as Section 102 of NEPA and its related provisions in 40
CFR Parts 1500-1508.
Delegation of the CO role from the Mayor to the Housing and Community Development
Department Director, Alexis Steger, was authorized in January 2022 to provide a
safeguard to the City, as the Housing and Community Development Department
(HCDD) Director is familiar with HUD's regulations governing environmental
compliance. Additionally, the HCDD Director is readily available to certify Environmental
Review Records, Requests for Release of Funds, and other documents requiring
certification. This expedites approval timelines and allows for faster service delivery to
the community.
Page 521 of 2490
Due to the time-sensitive nature of Environmental Reviews and their importance to
project progress, it is necessary to assign this responsibility to the individual acting in
the role of the Housing and Community Development Department Director.
Recommendation
I respectfully request the authority to carry out the responsibilities of the Certifying
Officer under the HUD regulations be delegated to the individual acting as the Housing
and Community Development Director, and that this delegation shall run until revoked
by Mayor Brad Cavanagh, or until the end of his term in office.
Prepared by: Maddy Haverland, Urban Development and Housing Rehabilitation Project
Manager
Page 522 of 2490
Prepared by Maddy Haverland Housing & Community Devel. 350 W. 6'h St., Suite 312 Telephone: (563) 690-6072
Return to Adrienne N. Breitfelder, City Clerk, 50 W. 13"' St., Dubuque, IA 52001, (563) 589-4100
RESOLUTION NO. 182-25
RESOLUTION DELEGATING AUTHORITY FOR ENVIRONMENTAL CERTIFYING
OFFICER
Whereas, the City of Dubuque Housing and Community Development
Department receives multiple sources of funding from the Federal Department of
Housing and Urban Development; and
Whereas, these funds are subject to environmental review, decision -making and
action responsibilities under the National Environmental Policy Act, and 24 CFR Part
58; and
Whereas, the Certifying Officer is responsible for authorizing the release of
funds, certifying environmental records, and representing the City of Dubuque in federal
courts for the enforcement of these responsibilities; and
Whereas, the Certifying Officer role is typically held by the highest-ranking official
in the City of Dubuque, Mayor Brad Cavanagh, and this responsibility may be delegated
by formal resolution. The Certifying Officer role was delegated by formal resolution on
January 2, 2022 from Mayor Brad Cavanagh to Housing and Community Development
Director, Alexis Steger; and
Whereas, it is necessary to designate the individual acting in the role of the
Housing and Community Development Department Director as the Certifying Officer.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF DUBUQUE, IOWA:
Section 1. That the individual acting as the Housing and Community
Development Director is delegated the authority to act as the Certifying Officer for the
City of Dubuque for all HUD funding and environmental review requirements.
Section 2. This delegation shall be effective immediately and remain effective
until revoked by Mayor Cavanagh or until the end of his term in office.
Passed, approved, and adopted this 2nd day of June 2025,
Brad a anagh, Mayor
Attest
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Adrienne Breitfelder, City Clerk