Authorization to Submit FY25/PY24 Community DevelopmentCity of Dubuque
City Council
CONSENT ITEMS # 15.
Copyrighted
September 15, 2025
ITEM TITLE: Authorization to Submit FY25/PY24 Community Development
Block Grant CAPER
SUMMARY: City Manager recommending City Council adopt a resolution
authorizing submission to HUD of the Consolidated Annual
Performance and Evaluation Report (CAPER) for the period
of July 1, 2024, through June 30, 2025.
RESOLUTION Authorizing The Submission Of A
Consolidated Annual Performance And Evaluation Report
(CAPER) For The Period Commencing July 1, 2024 And
Concluding June 30, 2025
SUGGUESTED Receive and File; Adopt Resolution(s)
DISPOSITION:
ATTACHMENTS:
1. MVM Memo
2. Staff Memo
3. Resolution
4. FY25/PY24 Consolidated Annual Performance and Evaluation Report (CAPER)
Page 564 of 1171
THE CITY OF
Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Authorization to Submit FY25/PY24 Community Development Block Grant
CAPER
DATE: September 9, 2025
Interim Housing & Community Development Director Sandra Fowler is recommending
City Council adopt a resolution authorizing submission to HUD of the Consolidated
Annual Performance and Evaluation Report (CAPER) for the period of July 1, 2024,
through June 30, 2025. The report includes activities for the Community Development
Block Grant (CDBG) Program and is due September 30, 2025, 90 days after the end of
the reporting period.
Recommendation of approval was approved at the Public Hearing of the Community
Development Advisory Commission at their September 3, 2025 meeting.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Y
Mic ael C. Van Milligen
►VA140►TAWA
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Sandra Fowler, Interim Housing & Community Development Director
Page 565 of 1171
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TO: Michael C. Van Milligen, City Manager
FROM: Sandra L. Fowler, Interim Housing and Community Development Director
SUBJECT: Authorization to Submit FY25/PY24 Community Development Block Grant
CAPER
DATE: September 8, 2025
Introduction
The purpose of this memorandum is to request City Council approval of a resolution
authorizing submission to HUD of the Consolidated Annual Performance and Evaluation
Report (CAPER) for the period of July 1, 2024 through June 30, 2025. The report
includes activities for the Community Development Block Grant (CDBG) Program and is
due September 30, 2025, 90 days after the end of the reporting period.
Discussion
The U.S. Department of Housing and Urban Development (HUD) requires annual
submittal of the Consolidated Annual Performance and Evaluation Report (CAPER).
The CAPER includes a narrative and numerous reports detailing how the city used its
federal funds during the most recently completed program year. It provides a description
of each activity for which funds were budgeted as well as information on activity
accomplishments. The CAPER is submitted to the Community Planning and
Development program office of HUD through HUD's Integrated Disbursement and
Information System (IDIS). IDIS is a nationwide database the city is required to use to
provide HUD with current information regarding CDBG activities.
HUD regulations require the report be made available to citizens in time to comment
prior to submission to HUD. A public notice was published in the Telegraph Herald on
Friday, August 15th, 2025 announcing a public hearing for the CAPER. The public
hearing was held on Wednesday, September 3rd, 2025 at the Community Development
Advisory Commission meeting. Minutes noting that no public comments were received
at the meeting are required to be included as an attachment to the CAPER prior to
submission to HUD.
The CAPER was prepared from data supplied by various City departments,
organizations, and agencies who utilized CDBG funds over the twelve-month period
ending June 30, 2025. A copy is attached for your review. The report is submitted to
HUD in draft form until HUD approval is received.
Page 566 of 1171
Recommendation
I respectfully request that the City Council approve the attached resolution, directing
staff to submit the Consolidated Annual Performance and Evaluation Report (CAPER)
for July 1, 2024 to June 30, 2025 to the U.S. Department of Housing & Urban
Development Community Planning Division after recommendation of approval at the
public hearing at the Community Development Advisory Commission Meeting held on
September 3, 2025.
Page 567 of 1171
Prepared by: Mary Bridget Corken-Deutsch, Community Development Specialist
Page 568 of 1171
Prepared by Mary Bridget Corken-Deutsch Community Development Specialist 350 W. 6"' St Dubuque IA
52001, (563) 690-6094
Return to Adrienne N. Breitfelder, City Clerk, 50 W. 1311 St., Dubuque, IA 52001, (563) 589-4100
RESOLUTION NO. 298-25
RESOLUTION AUTHORIZING THE SUBMISSION OF A CONSOLIDATED ANNUAL
PERFORMANCE AND EVALUATION REPORT (CAPER) FOR THE PERIOD
COMMENCING JULY 1, 2024 AND CONCLUDING JUNE 30, 2025
Whereas, the City of Dubuque, Iowa, is an entitlement grant recipient under the
Community Development Block Grant (CDBG) Program of the U.S. Department of
Housing and Urban Development (HUD); and
Whereas, the CDBG regulations require each entitlement recipient must submit a
performance and evaluation report, Consolidated Annual Performance and Evaluation
Report (CAPER); and,
Whereas, the City has 1) prepared a CAPER for the program year commencing
July 1, 2024 and concluding June 30, 2025; 2) published notice of availability of the
CAPER in the Telegraph Herald and City of Dubuque website on August 15, 2025 and;
3) made copies of the CAPER available for public review; 4) held a public hearing
pursuant to required 15-days published notice before the Community Development
Advisory Commission on September 3, 2025.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF DUBUQUE, IOWA:
Section 1. That the Consolidated Annual Performance and Evaluation Report
(CAPER) for the period commencing July 1, 2024, and concluding June 30, 2025, is
hereby approved for submission upon the completion of the Public Hearing held on
September 3, 2025.
Section 2. That the City Manager is hereby authorized to direct staff to submit
the Consolidated Annual Performance and Evaluation Report (CAPER) along with any
public comment to the U.S. Department of Housing and Urban Development.
Passed, approved, and adopted this 15th day of September 2025.
Attest /J
Adrienne Breitfelder, City Clerk
Emalow-mom900000,111,
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IJ
HUD PY24
City of Dubuque Consolidated Annual
Performance and Evaluation Report
FISCAL YEAR
PREPARED B`'
CITY OF DUBUQU�, i i v �uuu L.
CR-05 - Goals and Outcomes
Progress the jurisdiction has made in carrying out its strategic plan and its action plan. 91.520(a)
This could be an overview that includes major initiatives and highlights that were proposed and executed throughout the program year.
The Consolidated Annual Performance and Evaluation Report (CAPER) provides an end -of -year performance report of federally -funded activities
and accomplishments to the U.S. Department of Housing and Urban Development (HUD) and the community. The City of Dubuque Consolidated
Plan Year 5 CAPER covers the City's progress in carrying out the Fiscal Year (FY) 2025 Annual Action Plan for the use of HUD Program Year 2024
Community Development Block Grant (CDBG) funds. This CAPER covers the period of July 1, 2024 through June 30, 2025. The City of Dubuque is
an entitlement City and is eligible to receive CDBG funds on an annual basis. The CAPER focuses on federally funded activities. When
appropriate, this report provides information on activities supported by local and federal funds.
The City of Dubuque expended $1,862,465.11 in CDBG entitlement funds in FY2025/PY2024. The City, the City of Dubuque Community
Development Advisory Commission, local not -for profit organizations and neighborhood associations partner to implement programs delivered
with the funds. In FY2025/PY2024, CDBG funds were used to make investments in economic development, public infrastructure, housing
rehabilitation, and neighborhood and public services. All funds were used to meet the priority housing, economic development, neighborhood,
and administration needs identified in the Consolidated Plan and Annual Action Plan for FY2025/PY2024 as amended. The City of Dubuque did a
substantial job in spending down funds and providing activities to our community. For example, during FY2025/PY2024, under Housing
Rehabilitation, the 5 homeowners received lead paint hazard reduction, 1 single family home that houses 4 individuals with disabilities received
rehabilitation, 2 first time homebuyers receive loans to support their dream of owning a home, and 1 multi -unit housing buildings received
rehabs. Under economic development, 8 small businesses were provided with microenterprise loans. Under neighborhood and public services,
3 recreation programs were supported. In addition to these services a substantial renovations occurred at public facilities including a massive
park renovation completed at Lincoln Outdoor Wellness Center. This park serves low and moderate areas of our community and have brought
new life to the area.
Comparison of the proposed versus actual outcomes for each outcome measure submitted with the consolidated plan and
explain, if applicable, why progress was not made toward meeting goals and objectives. 91.520(g)
Categories, priority levels, funding sources and amounts, outcomes/objectives, goal outcome indicators, units of measure, targets, actual
outcomes/outputs, and percentage completed for each of the grantee's program year goals.
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 571 of 1171
Goal
Category
Source /
Indicator
Unit of
Expected
Actual —
Percent
Expected
Actual—
Percent
Amount
Measure
—
Strategic
Complete
—
Program
Complete
Strategic
Plan
Program
Year
Plan
Year
Affordable
Housing
Homeless
AFH: Advance
Non -
Equity with
Homeless
CDBG:
Other
Other
5
5
2
2
Fair Housing
Special
$566,194
100.00%
100.00%
Activities
Needs
Non -Housing
Community
Development
Affordable
Public Facility or
Housing
Assist Special
Infrastructure Activities
Non-
CDBG:
Persons
Needs
other than
25000
0
0.00%
4500
0
Homeless
$1,981,292
Assisted
0.00%
Populations
Low/Moderate Income
Special
Housing Benefit
Needs
Affordable
Public Facility or
Assist Special
Housing
Infrastructure Activities
Households
Needs
Non-
CDBG: $
15
0
0.00%
for Low/Moderate
Assisted
Populations
Homeless
Income Housing Benefit
Special Needs
Affordable
Public service activities
Assist Special
Housing
other than
Persons
Needs
Non-
CDBG:$
26675
29187
5000
0
Low/Moderate Income
Assisted
109.42%
0.00%
Populations
Homeless
Housing Benefit
Special Needs
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 572 of 1171
Affordable
Assist Special
Housing
Public service activities
Households
Needs
Non-
CDBG: $
for Low/Moderate
100
0
0.00%
5
0
Assisted
0.00%
Populations
Homeless
Income Housing Benefit
Special Needs
Affordable
Assist Special
Housing
Businesses
Needs
Non-
CDBG: $
Businesses assisted
55
33
Assisted
60.00%
Populations
Homeless
Special Needs
Public Facility or
Assist the
Infrastructure Activities
Homeless and
CDBG:
Persons
Homeless
other than
0
0
5000
0
At -Risk of
$1,155,966
Assisted
0.00%
Low/Moderate Income
Homelessness
Housing Benefit
Assist the
Public Facility or
Homeless and
Infrastructure Activities
Households
Homeless
CDBG: $
10
2055
At -Risk of
for Low/Moderate
Assisted
20,550.00%
Homelessness
Income Housing Benefit
Assist the
Public service activities
Homeless and
other than
Persons
Homeless
CDBG: $
12500
0
0.00%
500
0
At -Risk of
Low/Moderate Income
Assisted
0.00%
Homelessness
Housing Benefit
Assist the
Homeless and
Homeless
CDBG: $
Other
Other
5
0
0.00%
At -Risk of
Homelessness
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 573 of 1171
Affordable
Housing
Develop New
Homeless
Public service activities
CDBG:
Households
Affordable
Non-
for Low/Moderate
0
0
10
0
$453,877
Assisted
0.00%
Housing units
Homeless
Income Housing Benefit
Special
Needs
Affordable
Housing
Develop New
Household
Homeless
Homeowner Housing
Affordable
CDBG: $
Housing
10
0
0.00%
Non-
Added
Housing units
Unit
Homeless
Special Needs
Affordable
Housing
Develop New
Household
Homeless
Homeowner Housing
Affordable
CDBG: $
Housing
45
29
Non-
Rehabilitated
64.44%
Housing units
Unit
Homeless
Special Needs
Direct Home
Public service activities
Affordable
CDBG:
Households
Ownership
for Low/Moderate
0
0
10
2
Housing
$349,416
Assisted
20.00%
Assistance
Income Housing Benefit
Direct Home
Direct Financial
Affordable
Households
Ownership
CDBG: $
Assistance to
95
35
Housing
Assisted
36.84%
Assistance
Homebuyers
Encourage
Public Facility or
Self-
Non -Housing
Infrastructure Activities
CDBG:
Persons
Sufficiency-
Community
other than
0
0
$22,788
Assisted
Public/Human
Development
Low/Moderate Income
Services
Housing Benefit
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 574 of 1171
Encourage
Public service activities
Self-
Non -Housing
Sufficiency-
Community
CDBG: $
other than
Persons
60
39999
Low/Moderate Income
Assisted
66,665.00%
Public/Human
Development
Housing Benefit
Services
Encourage
Self-
Non -Housing
Public service activities
Households
Sufficiency-
Community
CDBG: $
for Low/Moderate
0
0
Assisted
Public/Human
Development
Income Housing Benefit
Services
Encourage
Self-
Non -Housing
Facade
Sufficiency-
Community
CDBG: $
treatment/business
Business
0
0
Public/Human
Development
building rehabilitation
Services
Encourage
Self-
Non -Housing
Tenant -based rental
Households
Sufficiency-
Community
CDBG: $
assistance / Rapid
250
1
0.40%
Assisted
Public/Human
Development
Rehousing
Services
Encourage
Self-
Non -Housing
Sufficiency-
Community
CDBG: $
Businesses assisted
Businesses
0
30
10
8
Assisted
80.00%
Public/Human
Development
Services
Encourage
Self-
Non -Housing
Sufficiency-
Community
CDBG: $
Other
Other
5
0
0.00%
Public/Human
Development
Services
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 575 of 1171
Affordable
Maintaining
Housing
Public Facility or
Existing
Non-
CDBG:
Infrastructure Activities
Households
125
0
0.00%
Affordable
Homeless
$1,147,058
for Low/Moderate
Assisted
Housing
Special
Income Housing Benefit
Needs
Affordable
Maintaining
Public service activities
Housing
Existing
other than
Persons
Non-
CDBG: $
0
36
Affordable
Low/Moderate Income
Assisted
Homeless
Housing
Housing Benefit
Special Needs
Affordable
Maintaining
Housing
Public service activities
Existing
Households
Non-
CDBG: $
for Low/Moderate
0
0
50
0
Affordable
Assisted
0.00%
Homeless
Income Housing Benefit
Housing
Special Needs
Affordable
Maintaining
Housing
Household
Existing
Rental units
Non-
CDBG: $
Housing
0
181
Affordable
rehabilitated
Homeless
Unit
Housing
Special Needs
Affordable
Maintaining
Housing
Household
Existing
Homeowner Housing
Non-
CDBG: $
Housing
100
91
0
6
Affordable
Rehabilitated
91.00%
Homeless
Unit
Housing
Special Needs
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 576 of 1171
Affordable
Maintaining
Housing
Direct Financial
Existing
Households
Non-
CDBG: $
Assistance to
150
0
0.00%
Affordable
Assisted
Homeless
Homebuyers
Housing
Special Needs
Affordable
Maintaining
Housing
Existing
Homelessness
Persons
Non-
CDBG: $
0
67
Affordable
Prevention
Assisted
Homeless
Housing
Special Needs
Affordable
Maintaining
Housing
Household
Existing
Housing for Homeless
Non-
CDBG: $
Housing
0
0
Affordable
added
Homeless
Unit
Housing
Special Needs
Affordable
Maintaining
Housing
Household
Existing
Housing for People with
Non-
CDBG: $
Housing
0
0
Affordable
HIV/AIDS added
Homeless
Unit
Housing
Special Needs
Public Facility or
Neighborhood
Non -Housing
Infrastructure Activities
CDBG:
Persons
Youth Services
Community
other than
0
0
1000
0
$735,166
Assisted
0.00%
and Aftercare
Development
Low/Moderate Income
Housing Benefit
Public service activities
Neighborhood
Non -Housing
other than
Persons
Youth Services
Community
CDBG: $
37400
7125
5730
333
Low/Moderate Income
Assisted
19.05%
5.81%
and Aftercare
Development
Housing Benefit
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 577 of 1171
Neighborhood
Non -Housing
Facade
Youth Services
Community
CDBG: $
treatment/business
Business
1
0
0.00%
and Aftercare
Development
building rehabilitation
Provide
Housing Code
Household
Inspection
Affordable
CDBG:
Enforcement/Foreclosed
Housing
825
708
70
69
and Code
Housing
$93,550
85.82%
98.57%
Property Care
Unit
Enforcement
Support
Public Facility or
Neighborhood
Non -Housing
Infrastructure Activities
CDBG:
Persons
Development
Community
other than
42500
10978
3500
1520
$1,426,069
Assisted
25.83%
43.43%
and
Development
Low/Moderate Income
Improvements
Housing Benefit
Support
Public Facility or
Neighborhood
Non -Housing
Infrastructure Activities
Households
Development
Community
CDBG: $
45
0
0.00%
for Low/Moderate
Assisted
and
Development
Income Housing Benefit
Improvements
Support
Public service activities
Neighborhood
Non -Housing
other than
Persons
Development
Community
CDBG: $
50000
18945
Low/Moderate Income
Assisted
37.89%
and
Development
Housing Benefit
Improvements
Table 1- Accomplishments — Program Year & Strategic Plan to Date
Assess how the jurisdiction's use of funds, particularly CDBG, addresses the priorities and specific objectives identified in the plan,
giving special attention to the highest priority activities identified.
CDBG funds were used to address the priorities, needs, and goals identified in the Consolidated Plan. The proposed budget for the
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
Page 578 of 1171
FY2025/PY2024 Annual Action Plan was adopted into the City Budget by the Dubuque City Council.
The City's goals described in the Consolidated Plan are all high priority and were used as the basis for the budgetary priorities outlined in
the FY2025/PY2024 Annual Action Plan. Each funded activity must demonstrate it helps achieve a goal identified in the Consolidated Plan and
benefit low/moderate-income (LMI) persons and communities before it is recommended for approval. The City provides funding for some public
service activities through a yearly grant process. When preparing the Consolidated Plan, estimates are used to project the level of funding and
the number of persons or households to be served. Due to the varying nature and cost of administering different programs, estimating the cost
and number to be served for public service activities can be very challenging. For example, job training activities have different costs, space, and
time requirements than programs providing emergency shelter. The City distinguishes between four areas of program development: Housing
Development, Economic Development, Neighborhood and Community Development, and Planning and Administration. FY2025/PY2024 activities
addressed all of the goals identified in the Consolidated Plan.
CAPER
OMB Control No: 2506-0117 (exp. 09/30/2021)
10
Page 579 of 1171
CR-10 - Racial and Ethnic composition of families assisted
Describe the families assisted (including the racial and ethnic status of families assisted).
91.520(a)
CDBG
White
251
Black or African American
75
Asian
0
American Indian or American Native
0
Native Hawaiian or Other Pacific Islander
6
Total
332
Hispanic
12
Not Hispanic
320
Table 2 — Table of assistance to racial and ethnic populations by source of funds
Narrative
The City of Dubuque focuses on serving families through direct outreach for participation in programs
and funding non-profit organizations that provide services intended towards underserved populations.
Outreach through partners such as Neighborhood Recreation Programs, specifically School Area Support
Programs and Day Camp Program, allowed us to reach more racially diverse populations in the City.
CAPER
11
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Page 580 of 1171
CR-15 - Resources and Investments 91.520(a)
Identify the resources made available
Source of Funds
Source
Resources Made
Available
Amount Expended
During Program Year
CDBG
public - federal
3,084,635
1,862,465
Table 3 - Resources Made Available
Narrative
The CDBG resources available in FY2025/PY2024 include unexpended CDBG funds at the end of the
previous year, 1,795,364.83, entitlement funds of 1,035,721.00, and program income, 253,549.14.
Totally, 3,084,634.97. During FY2025/PY2024, the City expended $225,754.32 in program income,
$1,636,710.32 in Entitlement funds, for a total of $1,862,465.11. Funding was used to support housing,
neighborhood and community development, and administrative programs.
Identify the geographic distribution and location of investments
Target Area
Planned Percentage of
Actual Percentage of
Narrative Description
Allocation
Allocation
City Wide
87
Low/Moderate Area
Benefit
13
Table 4 — Identify the geographic distribution and location of investments
Narrative
A majority of the activities identified in the Annual Action Plan are targeted to LMI populations, which
could be city-wide, so specific geographical areas within the city were not identified for those activities.
The Low/Moderate Area Benefit activities were services that are available for all residents living in the
determined areas, which are all conducted in residential areas with 51% or greater low/moderate
income residents according to Census data. A listing of activities and their locations is found in the
attached PR-03 CDBG Activity Summary Report.
CAPER
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Page 581 of 1171
Leveraging
Explain how federal funds leveraged additional resources (private, state and local funds),
including a description of how matching requirements were satisfied, as well as how any
publicly owned land or property located within the jurisdiction that were used to address the
needs identified in the plan.
The City of Dubuque actively seeks out and leverages resources to meet goals identified in the
consolidated plan. Partnerships with local organizations working to provide additional
affordable housing, economic development, socioeconomic, and self-sufficiency resources
ensure investments have lasting impact.
Through a State grant, the City of Dubuque provides Home Advocates to those that participate
in CDBG funded programs and the Lead and Healthy Homes Program. These Home Advocates
assess social and physical barriers to sustainable living in each individual home/unit and
connects residents to agencies that can help eliminate the barriers ($11,232).
The City of Dubuque also started to leverage Housing Tax Increment Financing funds to further
the goals of rehabilitating dilapidated structures and making them available to low -moderate
income person for purchase. This program is paired with the Purchase/Rehab/Resale and First -
Time Homebuyer Programs to maximize access to homeownership for low -moderate income
residents ($198,199).
The City of Dubuque has a Lead and Healthy Homes grant which CDBG funds leveraged into the
community as match funding. Additional funding is leveraged from the Lead and Healthy
Homes grant, which assists households built before 1978 with children under the age of 6, with
controlling lead -based paint hazards in the home ($275,657.54).
The City of Dubuque uses other funds to accomplish the same goals as the CDBG Consolidated
Plan such as Section 8 Housing, Shelter Plus Care Program, and the Rental Rehabilitation
Program; however, they are not directly leveraged by CDBG fund support of those outcomes.
CAPER
13
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Page 582 of 1171
CR-20 - Affordable Housing 91.520(b)
Evaluation of the jurisdiction's progress in providing affordable housing, including the
number and types of families served, the number of extremely low-income, low-income,
moderate -income, and middle -income persons served.
One -Year Goal
Actual
Number of Homeless households to be
provided affordable housing units
60
0
Number of Non -Homeless households to be
provided affordable housing units
5
0
Number of Special -Needs households to be
provided affordable housing units
0
0
Total
65
0
Table 5 — Number of Households
One -Year Goal
Actual
Number of households supported through
Rental Assistance
0
0
Number of households supported through
The Production of New Units
0
0
Number of households supported through
Rehab of Existing Units
50
6
Number of households supported through
Acquisition of Existing Units
0
0
Total
50
6
Table 6 — Number of Households Supported
Discuss the difference between goals and outcomes and problems encountered in meeting
these goals.
The City of Dubuque has traditionally partnered with the Affordable Housing Network, Inc. and will
continue to do so. However, we are looking to expand our partnerships in order to keep production
moving. This year, the City of Dubuque did complete a multi -unit rehab for 87 units with Catholic
Charities. The building is located downtown and has 100% of residents are LMI.
The City's Lead and Healthy Homes Program provides lead hazard control activities and healthy homes
interventions in homes built before 1978. CDBG provides match funding to leverage these grant funds,
with a focus on owner -occupied homes with children under the age of 6 years old. Production for this
grant picked up during FY25/PY24 completing 5 rehabs ($89,395).
CAPER
14
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Page 583 of 1171
Additional homes were rehabilitated through Tax Increment Financing and sold to low to moderate
income first-time homebuyers.
Discuss how these outcomes will impact future annual action plans.
Affordable housing options continue to be limited within the City, and often restricted to certain
geographic areas. The CDBG down payment assistance sometimes is not enough to reduce the price of
the home to be affordable to low and moderate -income buyers, especially in the current housing
market. The City started partnering with developers to create new, affordable homeownership
opportunities outside of areas of high poverty concentration. The City's goals to increase income
diversity in neighborhoods has a need for additional funding and programming designed to support
these efforts. The production of Housing TIF to serve this purpose was created by the City of Dubuque,
and is currently being used to rehabilitate homes that are affordable and sell them to low/mod income
residents and paired with the First -Time Homebuyer Program to increase affordable housing access. This
is being done through a partnership with Affordable Housing Network Inc.
The City's Lead and Healthy Homes Program provides lead hazard control activities and healthy homes
interventions in homes built before 1978. CDBG provides match funding to leverage these grant funds,
with a focus on owner -occupied homes with children under the age of 6 years old. Production for this
grant will continue and increase in production as the supply chain and material costs stabilize. The City
also received another Lead Hazard Control grant, and a Healthy Homes Production grant that will assist
with rehabilitation of existing units in the City.
The City received funds secured from the Iowa Economic Development Authority to assist households
with Rapid Rehousing needs. The City also continues to provide resources for sheltering related to the
COVID-19 pandemic. This includes providing spaces for individuals to isolate and quarantine as needed,
as well as the opportunity to minimize overcrowding, particularly for homeless shelters that typically
have communal living arrangements.
Include the number of extremely low-income, low-income, and moderate -income persons
served by each activity where information on income by family size is required to determine
the eligibility of the activity.
Number of Households Served
CDBG Actual
HOME Actual
Extremely Low-income
1
0
Low-income
0
0
Moderate -income
5
0
Total
6
0
Table 7 — Number of Households Served
Narrative Information
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CDBG funds were used for eligible housing activities, such as homeowner and rental rehabilitation, lead
hazard reduction, rehabilitation services and staff costs, and direct financial assistance for homebuyers.
Income eligible households have access to additional financial assistance through the Housing Trust
Fund, funded by IFA, and other local sources. The First-time Homeowner program partners with the
City's Section 8 Homeownership Program to provide housing counseling and financial assistance for
voucher holders. The City encourages income diversity in neighborhoods by incentivizing purchase in
low -mod areas for higher income households and providing additional financial resources for extremely -
low, low, and moderate -income populations to increase affordability outside areas of high -poverty
concentration. By leveraging multiple sources of funding to increase resources for lower -income
households, more equitable outcomes are achieved. Program income generated from CDBG funded
housing activities represents nearly 98% of the City's entire loan portfolio.
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CR-25 - Homeless and Other Special Needs 91.220(d, e); 91.320(d, e); 91.520(c)
Evaluate the jurisdiction's progress in meeting its specific objectives for reducing and ending
homelessness through:
Reaching out to homeless persons (especially unsheltered persons) and assessing their
individual needs
Dubuque is in the Balance of State for Iowa's Continuum of Care (CoC). Not -for -Profit service providers
lead the coordination of services and housing for the homeless. The Community Development Specialist
and Urban Development Manager assist local Continuum of Care applicants with the environmental
review process and determining consistency with the Consolidated Plan. Staff from Housing &
Community Development attend Continuum of Care meetings to assist in identifying and responding to
the needs of homeless persons.
Over 50 individuals make up the membership of the Homeless Advisory Council, working to streamline
and coordinate services and resources to meet the needs of homeless and near homeless community
members. Non-profit organizations providing homeless services including but not limited to referrals,
outreach, point -in -time count, coordinated entry, emergency & transitional shelter, and permanent
supportive housing. Organizations providing family self-sufficiency, advocacy, employment, employment
services & job training, substance abuse services, health, wellness, domestic violence, sexual assault,
mental health and dental services are available, as well as representation from the City of Dubuque
Police Department, Housing Authority, and Dubuque County Commission of Veteran's affairs.
The Homeless Advisory Council coordinates point -in -time homeless counts in July and January to
evaluate capacity and need for services. Hillcrest Family Services provides outreach, in partnership with
other organizations coordinating access for unsheltered persons. The City partners with East Central
Development Corporation (ECDC) to provide permanent supportive housing, targeting homeless
populations with mental health, HIV/AIDS related illness, and/or substance abuse.
Addressing the emergency shelter and transitional housing needs of homeless persons
The City of Dubuque supports organizations providing human service activities through Purchase of
Services Grants. Not -for -profit organizations meeting a human service need in the community can apply
for CDBG and General Funds on an annual basis. The City also delivers the Phoenix Housing program.
Phoenix Housing provides permanent, supportive housing for homeless living with disabilities. Homeless
outreach, emergency, transitional, permanent, and support services are coordinated with local
providers. This is the City's only program serving the homeless using the housing first model for
permanent supportive housing.
The City, in partnership with Community Solutions of Eastern Iowa, identified 40 individuals reported as
being homeless in Dubuque County during the July 2025 point in time homeless count.
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Helping low-income individuals and families avoid becoming homeless, especially extremely
low-income individuals and families and those who are: likely to become homeless after
being discharged from publicly funded institutions and systems of care (such as health care
facilities, mental health facilities, foster care and other youth facilities, and corrections
programs and institutions); and, receiving assistance from public or private agencies that
address housing, health, social services, employment, education, or youth needs
The City of Dubuque and State of Iowa require publicly funded institutions and facilities to have
discharge plans that include adequate and stable housing; however, the follow-up on those plans is
difficult in many situations. The City of Dubuque is also working with many community non -profits and
business partners to establish a "one -stop shop" for assistance that is provided across multiple agencies,
but can easily be accessed under the umbrella of one entity to help this vulnerable population access
assistance.
The City of Dubuque also was awarded Family Unification Program housing assistance vouchers to serve
those aging out of foster care, and families who have children placed in foster care that do not have
stable housing with the goal of reunification.
Helping homeless persons (especially chronically homeless individuals and families, families
with children, veterans and their families, and unaccompanied youth) make the transition to
permanent housing and independent living, including shortening the period of time that
individuals and families experience homelessness, facilitating access for homeless individuals
and families to affordable housing units, and preventing individuals and families who were
recently homeless from becoming homeless again
A network of non-profit organizations provides a range of services from outreach to permanent
supportive housing. These organizations collaborated during the program year to define and align
resources for coordinated entry. Headed by the Iowa Continuum of Care, a network of local providers is
working to streamline services for homeless to allow better access to shelter, mental health, health,
dental, and substance abuse resources. The primary focus is to find people shelter or housing
immediately, in their community of choice.
The City participates as the permanent supportive housing provider and partners with a local non-profit
to coordinate outreach and manage the waiting list. The City continues to support requests to develop
and rehabilitate accessible and affordable housing, with emphasis on programs willing to accept
vouchers or provide subsidies for households under 30% AMI.
There are three permanent supportive housing programs offered in Dubuque. The City provides the
Continuum of Care funded Phoenix Housing program, serving homeless individuals and families with
disabilities. Hillcrest Family Services provides permanent supportive housing for children, and Opening
Doors (Francis Apartments) provides permanent supportive housing opportunities for families.
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CR-30 - Public Housing 91.220(h); 91.320(j)
Actions taken to address the needs of public housing
The City of Dubuque does not have public housing. The City monitors the number of affordable tax
credit units and Housing Choice Voucher units within the City. The affordable housing stock is not high
enough to meet needs of renters and homeowners at or below 80% of the area median income. This is
supported by data in the Consolidated Plan showing more renters earning under 80% Area Median
Income are cost burdened, meaning they pay more than 30% of their income for housing -related costs.
The American Community Survey estimates verify nearly half of all renters experience cost burden. The
City promotes CDBG funded programming to voucher participants in efforts to increase awareness and
participation in activities.
Actions taken to encourage public housing residents to become more involved in
management and participate in homeownership
The City uses the Section 8 Housing Choice Voucher program to provide affordable housing options. The
Housing & Community Development Department is the PHA for the City. The City has over 900 vouchers
but is unable to issue to capacity due to budgetary constraints. The Family Self -Sufficiency Coordinator
at City of Dubuque's Housing & Community Development works with Family Self -Sufficiency participants
to increase awareness about homeownership options.
All Housing Choice Voucher participants are invited to join the City's Family Self -Sufficiency (FSS)
program, which offers unique, person -centered coaching to support the individual's needs. Goal
planning, resource coordination, job readiness, and family supports are all provided. The Community
Development staff regularly visits with Family Self -Sufficiency Coordinator, and FSS-participating
families. The programs coordinate resources to help buyers establish bank accounts, Individual
Development Accounts (IDA), homeownership counseling, and resources to purchase a home.
Actions taken to provide assistance to troubled PHAs
This PHA is not troubled.
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CR-35 - Other Actions 91.220(j)-(k); 91.320(i)-(j)
Actions taken to remove or ameliorate the negative effects of public policies that serve as
barriers to affordable housing such as land use controls, tax policies affecting land, zoning
ordinances, building codes, fees and charges, growth limitations, and policies affecting the
return on residential investment. 91.220 (j); 91.320 (i)
The City of Dubuque has taken steps toward removing barriers to affordable housing, especially when
federal, state, or local funds are contributed toward housing improvements. All rental property owners
who receive funding through CDBG Rehab programs, Lead Hazard Control, Bee Branch Healthy Homes
(CDBG-NDR), are required to accept housing choice vouchers.
The City continues to work with community groups and stakeholders regarding adding source of income
as a protected class to our local ordinances. The Housing & Community Development, Human Rights,
and Planning Services Departments partnered with local stakeholders to better understand how source
of income impacts tenants, particularly Housing Choice Voucher holders. Recent rental licensing data
shows that only 33% of units in the City of Dubuque will accept Housing Choice Vouchers, and the
majority of those are in high -concentrated poverty areas. To address this, the, "Source of Income"
committee was formed. The Committee was made up of key city staff, board and commission members,
housing providers, and housing advocacy groups. The group analyzed data, information, and organized a
series of community dialogues to gain insight into the issues surrounding the impact of such an
ordinance and other options to increase housing choice for voucher holders.
The City of Dubuque also formed a fees and charges equity committee to evaluate the impact fees have
on low-income residents. The goal of this committee is to eliminate fees and charges that don't produce
the desired outcomes and affect low-income residents more than others.
Actions taken to address obstacles to meeting underserved needs. 91.220(k); 91.320(j)
The City's Planning & Zoning, Economic Development, and Housing Departments coordinate to receive
and process requests for development of affordable housing. The Housing & Community Development
Department works closely with the City's Legal, Human Rights Department, and Office of Economic
Mobility and Neighborhood Support to inform City staff, housing providers, developers, and the
community at large about the barriers to fair housing and the strategic steps the City is taking steps to
eliminate barriers as identified in the Analysis of Impediments. To encourage public support for
affordable housing development, the City partners with organizations wishing to develop affordable
housing to engage neighborhood residents about the proposed projects. Through a series of
informational meetings, housing developers and residents can discuss the community needs, obtain
facts about the need for affordable housing, and identify target populations and needs unique to the
proposed location within the Dubuque community. These meetings have proven successful for
developers proposing Low Income Housing Tax Credit projects.
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To help with the financial feasibility of these projects, the City offers developers the opportunity to
request support from the City for the project. If the project aligns with the City's goals, Consolidated
Plan, and Comprehensive Plan, the City facilitates a public engagement process where incentives for the
project are presented to City Council. Projects seeking support must apply to the City for a review and
the City Council makes final recommendations.
Actions taken to reduce lead -based paint hazards. 91.220(k); 91.320(j)
The Lead and Healthy Homes Program effectively delivers successful lead remediation activities for
income eligible households. The grant provides additional funds to address health and safety hazards in
the home, and coordinates with a Home Advocate to build social capacity for participating families.
The City of Dubuque has received another Lead and Healthy Homes Grant in 2024 for $5.21 million that
would continue lead hazard control efforts, and have a targeted focus on Dubuque's unique historic
properties that traditionally fall through the cracks due to the costs associated with historic
preservation. This grant will run from January 2025-January 2029 and complete interventions in 90 units
city-wide.
All CDBG funded activities use the required level of lead assessment when performing rehab on homes.
Homeowners and renters are provided information and resources about lead and lead poisoning, as well
as information on where and when children should be tested. Code enforcement activities identify
visible hazards from peeling paint and housing code to ensure the health and wellbeing of children living
in these units. CDBG funding provided financial assistance for six units assisted by the Lead & Healthy
Homes program during the program year.
Actions taken to reduce the number of poverty -level families. 91.220(k); 91.320(j)
The City of Dubuque funds, supports, and participates in a variety of projects that support goals to
increase economic opportunities through business retention, expansion, job creation, and financial
resources for low- and moderate -income small business owners. The City of Dubuque had a low
unemployment rate pre-COVID, and many of the local manufactures have a demand for skilled workers.
Project HOPE, which is supported by the City of Dubuque, coordinates with Dubuque Works,
Opportunity Dubuque, and the local community college, NICC, to identify under -skilled workers, train
them, and match them with employment opportunities.
Entitlement funds in the amount of $50,000 were committed to Microenterprise development and
expansion for low to moderate income business owners. These grants assisted microenterprise owners
with costs associated with beginning a business, or expanding services.
The City has also taken significant strides in the areas of supporting housing for all income levels
included working familiies. The lowest income households experience the most severe housing
problems, and those problems disproportionately impact renters. Much of the City's historic housing
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stock is in the downtown. Several units are in mixed -use structures, with vacant store fronts on the first
floor and deteriorated housing on the upper floors. The City has multiple programs to address the poor
housing conditions in this area, in conjunction with efforts to revitalize owner occupied, local business,
and infrastructure in the Central Avenue Corridor.
Actions taken to develop institutional structure. 91.220(k); 91.320(j)
Within the institution, steps are being taken to encourage and promote high -performing, fiscally
responsible government. This outcome -driven process is focused on data analysis, community
engagement, and strategic initiatives designed to support and retain Dubuque's population. Employers
in Dubuque are looking for a skilled workforce, and the Housing & Community Development
Department has strategically partnered with the private sector to connect unemployed and
underemployed populations to training and skills necessary to meet local employer's needs.
Multiple departments continue compiling a data library and develop uniform data collection and
tracking systems across departments to more effectively address neighborhood, housing, and economic
development concerns identified by citizens and staff. The work being completed by these departments
focuses on equity and identifying how the institution can provide more equitable services.
Actions taken to enhance coordination between public and private housing and social service
agencies. 91.220(k); 91.320(j)
The City has developed strategies to ensure housing developers relate to the community in which they
plan to provide housing, as well as local service providers. Programs seeking City support must
demonstrate active public engagement in the planning of the project and demonstrate what support
services will be available to residents. Locations of projects are carefully considered to ensure residents
will have access to areas of opportunity relevant to the target population being served. The City actively
seeks out federal, state, local, and private sector partners that can meet the range of housing needs
across the community.
The City continues its C.H.A.N.G.E. initiative (Comprehensive Housing Activities for Neighborhood
Growth and Enrichment) to identify and rehabilitate downtown housing units. The program is designed
to acquire, rehabilitate, and sell previously dilapidated properties to income eligible households,
coordinate local, state, and federal resources to have the greatest impact for occupied properties, and
support neighborhood and community development to ensure rich partnerships, programs, and
economic and social resiliency. Through a partnership with GT Investments, and Affordable Housing
Network, Inc., multiple single-family homes have been rehabilitated into affordable homeownership
opportunities.
Identify actions taken to overcome the effects of any impediments identified in the
jurisdictions analysis of impediments to fair housing choice. 91.520(a)
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• Any rental property participating in housing rehab activities through the City of Dubuque is
required to accept Housing Choice Vouchers as a condition of their participation.
• City of Dubuque has increased landlord education about the HCV program as well as created a
landlord education video to be shared among that specific group in hopes to dispel some of the
HCV rumors while also providing information as to why/how HCV benefits the entire
community. PHA also implemented a new, easier to use software that aides owners and tenants
in communication and document transmittal, allowing the HCV program to progress with the
times and provide ease of use. The City of Dubuque meets monthly with the Landlord
Association to further connection and collaboration efforts. FY24 was a focus on recruitment of
landlord participation through the Successful Property Maintenance Course and also through
the networking of individuals through the Landlord Association.
• Efforts continue to translate all necessary documents into Spanish and Marshallese in order to
break down communication barriers and allow easier accessibility to programs and information
for the entire community. PHA is focusing efforts on translation services and interpreter needs
and accessibility. Assessed & revised our HCV general forms for readability and adapted them
all to a 6-7th grade level. We are also working on reducing our applications/forms of asking for
unneeded information in order to make the processes less burdensome on participants.
• Efforts increased to create more social media presence to engage the community through
education and awareness. A landlord education video was released in Spring of 2022. City staff
are also researching the potential benefits of offering a tenant education course and other
possible ways to lessen the burden of moving and unit damage.
• Inspections cycle has been reduced to 4 year between routine inspections and recently
approved moving to a 2 year license inspection for propertities in good standing.
• Adoption of the International Property Maintenance Code to hold units to a higher standard
with the goal of providing quality, healthy, and safe environments for citizens to choose to live
in.
• Partnered with Iowa Legal Aid to start a Fair Housing Testing Program.
• Continued community efforts to remove barriers to quality, affordable childcare options in the
city.
• Updated the City website to make a reasonable accommodation request easier to find and more
accessible to any resident.
• FY26/PY25 Annual Action Plan includes a rehabilitation housing project complaint with the
accessibility requirements for covered housing.
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CR-40 - Monitoring 91.220 and 91.230
Describe the standards and procedures used to monitor activities carried out in furtherance
of the plan and used to ensure long-term compliance with requirements of the programs
involved, including minority business outreach and the comprehensive planning
requirements
Pre -funding Preparedness: The Community Development Specialist provides one-on-one preparatory
and program development meetings for new or expanded programs offered through the City of
Dubuque. Technical assistance is provided to develop programs that deliver eligible activities in a timely
manner. New subrecipients outside of the City are also provided one-on-one technical support prior to
project implementation ensure contracting, eligibility, reporting, and national objective requirements
are met. These are routinely completed virtually, but also have face to face meetings.
Contract Management: Most CDBG contracts are overseen by the Housing & Community Development
Department, but some are assigned to a City project manager responsible for the execution and
reporting related to the contract. Contracts include HUD, state, and local requirements, including
related requirements such as environmental reviews, URA, 2 CFR 200, and Lead Based Paint
requirements. Ongoing technical assistance is provided by the Community Development Specialist to
subrecipients and project managers throughout the contract period. Most subrecipients do monthly
draws where supporting documentation is verified.
Monitoring Compliance: The City completes monthly desk audits of reports and supporting
documentation, onsite monitoring reviews, phone contacts, written communications (letters and email)
and meetings. Each subrecipient has individualized reporting forms unique to their program, budgeted
expenses, and activities. These individualized reporting forms allows for convenient management and
monitoring for fraud, waste, mismanagement and other opportunities for potential abuse. Contract
provisions allow for suspension of payment or termination of contract and reimbursement at any time
during the program year based on performance deficiencies. Staff always works with subrecipients to
correct identified deficiencies through discussion, technical assistance prior to imposing any sanctions.
Subrecipients report on successes, challenges, and needs quarterly using an electronic form. City
Departments using CDBG funds are monitored by their respective Department Managers and the
Housing & Community Development Director.
Audit Review: Subrecipients are required to submit an audit prior to funding (if available) and as part of
the year-end requirements in the contract. Programs requiring a Single Audit are subject to a financial
desk review to the CDBG program if there is a finding noted in the audit, regardless if the finding is
related to CDBG funds.
The Housing and Community Development department maintains and updates the Section 3 plan for
applicable contracts.
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Citizen Participation Plan 91.105(d); 91.115(d)
Describe the efforts to provide citizens with reasonable notice and an opportunity to
comment on performance reports.
The Community Development Advisory Commission meets monthly and is open to the public. Meetings
are at 5:30 pm in a Housing Conference Room, located in Dubuque's downtown on a bus route, but have
been held both in person and may include a virtual platform. All public hearings have translation
services for individuals with limited English proficiency, vision, hearing, or speech impairments. Agendas
are posted in the Housing Department, City Hall, Public Library, Multicultural Family Center and
distributed to a list serve where anyone can receive notification when agendas and reports are posted
online. The commission provides citizens an opportunity to comment on proposed plans, performance,
and reports. The Commission also welcomes partners to the meetings in order to share out any relevant
information to the Commission. Comments can also be submitted in writing, by phone, or electronically
through the City's website.
The Community Development Advisory Commission reviews the Citizen Participation Plan
annual. Citizen Participation Plan was also amended in FY2025/PY2024 and describes the roles,
responsibilities, and contact information of entities involved in administering, reviewing, and approving
activities included in this report. The most impactful way to get this information out to the public has
been through social media.
CR-45 - CDBG 91.520(c)
Specify the nature of, and reasons for, any changes in the jurisdiction's program objectives
and indications of how the jurisdiction would change its programs as a result of its
experiences.
The City of Dubuque has been working hard to promote the use of the community development
programs to marginalized community members and those with significant barriers to navigating
systems. Targeted outreach was completed to test if that would encourage additional participants from
marginalized neighborhoods, but that was not an outcome. The City changed its focus to being part of
"in-group" activities and events to reach this community. This has been effective in increasing the
number of marginalized groups participating in programs and even providing input for planning
programs.
Through code enforcement efforts, it was discovered that many older rental units in the City, primarily
occupied by minority or low/moderate income community members, had windows in habitable rooms
that did not meet emergency escape and rescue opening requirements as identified by City Code. This
was a safety issue, so the City developed a program by which rental property owners could replace the
non -compliant windows with properly sized egress windows to keep occupants safe in case of
emergency.
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Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI)
grants?
No
[BEDI grantees] Describe accomplishments and program outcomes during the last year.
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CR-45 - CDBG 91.520(c)
Specify the nature of, and reasons for, any changes in the jurisdiction's program objectives
and indications of how the jurisdiction would change its programs as a result of its
experiences.
The City of Dubuque has been working hard to promote the use of the community development
programs to marginalized community members and those with significant barriers to navigating
systems. Targeted outreach was completed to test if that would encourage additional participants from
marginalized neighborhoods, but that was not an outcome. The City changed its focus to being part of
"in-group" activities and events to reach this community. This has been effective in increasing the
number of marginalized groups participating in programs and even providing input for planning
programs.
Through code enforcement efforts, it was discovered that many older rental units in the City, primarily
occupied by minority or low/moderate income community members, had windows in habitable rooms
that did not meet emergency escape and rescue opening requirements as identified by City Code. This
was a safety issue, so the City developed a program by which rental property owners could replace the
non -compliant windows with properly sized egress windows to keep occupants safe in case of
emergency.
Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI)
grants?
[BEDI grantees] Describe accomplishments and program outcomes during the last year.
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CR-58 — Section 3
Identify the number of individuals assisted and the types of assistance provided
Total Labor Hours
CDBG
HOME
ESG
HOPWA
HTF
Total Number of Activities
0
0
0
0
0
Total Labor Hours
Total Section 3 Worker Hours
Total Targeted Section 3 Worker Hours
Table 8 —Total Labor Hours
Qualitative Efforts - Number of Activities by Program
CDBG
HOME
ESG
HOPWA
HTF
Outreach efforts to generate job applicants who are Public Housing
Targeted Workers
Outreach efforts to generate job applicants who are Other Funding
Targeted Workers.
Direct, on -the job training (including apprenticeships).
Indirect training such as arranging for, contracting for, or paying tuition for,
off -site training.
Technical assistance to help Section 3 workers compete for jobs (e.g.,
resume assistance, coaching).
Outreach efforts to identify and secure bids from Section 3 business
concerns.
Technical assistance to help Section 3 business concerns understand and
bid on contracts.
Division of contracts into smaller jobs to facilitate participation by Section
3 business concerns.
Provided or connected residents with assistance in seeking employment
including: drafting resumes, preparing for interviews, finding job
opportunities, connecting residents to job placement services.
Held one or more job fairs.
Provided or connected residents with supportive services that can provide
direct services or referrals.
Provided or connected residents with supportive services that provide one
or more of the following: work readiness health screenings, interview
clothing, uniforms, test fees, transportation.
Assisted residents with finding child care.
Assisted residents to apply for, or attend community college or a four year
educational institution.
Assisted residents to apply for, or attend vocational/technical training.
Assisted residents to obtain financial literacy training and/or coaching.
Bonding assistance, guaranties, or other efforts to support viable bids
from Section 3 business concerns.
Provided or connected residents with training on computer use or online
technologies.
Promoting the use of a business registry designed to create opportunities
for disadvantaged and small businesses.
Outreach, engagement, or referrals with the state one -stop system, as
designed in Section 121(e)(2) of the Workforce Innovation and
Opportunity Act.
Other.
Table 9 — Qualitative Efforts - Number of Activities by Program
Narrative
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