Letter to Legislators - I owa Property Tax System HF773 Copyrighted
May 6, 2019
City of Dubuque Consent Items # 8.
ITEM T IT LE: Letter to Legislators - I owa Property Tax System HF773
SUM MARY: City Manager providing a copy of correspondence to
Legislators in opposition to HF773 regarding amendments
to the lowa property tax system.
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File
ATTACHMENTS:
Description Type
Letter to Legislators re HF 773 Supporting Documentation
HF 773 Unnecessary Attack on Local Control Supporting Documentation
TH Editorial Keep Local Choices a Local Matter Supporting Documentation
State and Federal Mandates Supporting Documentation
��(� City Manager's Office
THE CTPY OF �. City Hall
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D V L E ' � �� Dubuque,IA 52001-4845
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Masterpiece on the Mississippi yy�3•yp77 ctymgr@cityofdubuque org
www.cityofdubuque.org
April 15, 2019
«CompleteOFFICIALName_Address»
Dear «Title» «Last»,
House File 773 includes unnecessary amendments to the current lowa property tax system.
Although the bill amendments are suggested to have been created to increase transparency,
there are already systems in place for residents to dispute budgets and promote government
transparency.
In House File 773, Section 384.12A allows cities authority to levy beyond maximum property
tax dollars. A City must publish a resolution that is subject to petition which contains a
statement of the amount and purpose of the proposed additions. Petitions are received up to
twenty days after the meeting is held. "If a petition is filed with the city clerk signed by eligible
electors of the city equal in number to the lesser of two thousand or twenty percent of the
persons in the city who voted for the office of president of the United States at the last
preceding general election that had such office on the ballot, but not less than ten eligible
electors, asking that the question of levying an additional amount be submitted to the
registered voters of the city, the city council shall either by resolution declare the proposal to
be abandoned or shall direct the county commissioner of elections to call a special election
upon the question."
A protest process already exists in the current lowa Code relating to budgets and budget
amendments. lowa Code Chapter 384.19 allows written protests from residents on both the
adopted budget and budget amendments. "Within a period of ten days after the final date that
a budget or amended budget may be certified to the county auditor, persons affected by the
budget may file a written protest with the county auditor, specifying their objections to the
budget or any part of it. A protest must be signed by qualified electors equal in number to
one-fourth of one percent of the votes cast for governor in the last preceding general election
in the city, but the number shall not be less than ten persons and the number need not be
more than one hundred persons. Upon the filing of any such protest, the county auditor shall
immediately prepare a true and complete copy of the written protest, together with the budget
to which the objections are made, and shall transmit the same forthwith to the state appeal
board, and shall also send a copy of the protest to the council. The state appeal board shall
proceed to consider the protest in accordance with the same provisions that protests to
budgets of municipalities are considered under chapter 24. The state appeal board shall
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April 15, 2019
Page 2
certify its decision with respect to the protest to the county auditor and to the parties to the
appeal as provided by rule, and the decision shall be final. The county auditor shall make up
the records in accordance with the decision and the levying board shall make its levy in
accordance with the decision. Upon receipt of the decision the council shall correct its
records accordingly, if necessary. "
Residents of various cities in lowa have filed written protests with their county auditors. The
following table shows the cities in lowa that have had a written protest filed against their
budget or budget amendment:
. �
2017 Mount Union Bud et Protest
2016 Cedar Ra ids Bud et A eal
2017 Mount Union Bud et Protest
2014 Silver Cit Bud et A eal
2011 Eldora Bud et Amendment A eal
2011 Lacona Bud et A eal
2010 Riverdale Bud et A eal
2010 Waverl Bud et A eal
2008 Conesville Bud et A eal
2007 Silver Cit Bud et Amendment A eal
2006 Denison Bud et A eal
2005 Daven ort Bud et A eal
2005 Jamaica Bud et A eal
2005 Keokuk Bud et A eal
2004 Mount Auburn Bud et A eal
2004 Walker Amended Bud et A eal
2001 A enc Bud et A eal
2000 Daven ort Bud et A eal
2001 Daven ort Bud et A eal
2000 Davenport Budget Appeal Request for
Rehearin
2001 Larchwood Bud et A eal
2000 Massena Bud et A eal
2000 Sioux Cit Bud et A eal
2000 Waukee Bud et A eal
2017 Mount Union Bud et Protest
2016 Cedar Ra ids Bud et A eal
Source: https://dom.iowa.qov/citv budqets appeals
lowa Code Chapter 384.16 requires a notice of public hearing on the budget estimate and
amendments to be published "not less than 10 days nor more than 20 days before the date of
the hearing". The day on which the hearing is held is not used in the 10- and 20-day
calculation. If the notice of publication does not meet this statutory requirement, the notice
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April 15, 2019
Page 3
and hearing must be re-done, no exception. The budget is not compliant with lowa Code
section 384.16 unless this process is completed.
The requirement to publish a notice of public hearing allows notification to residents that cities
budgets and budget amendments are being considered and gives the time and place for
residents to address city council if they are opposed to what is being considered. This is a
prime opportunity for residents to be heard by their City Council on budget matters.
In addition to the required public hearing for the budget adoption, many cities including the
City of Dubuque, provide additional public input meetings on the budget with City Council.
During the Fiscal Year 2020 budget process, Dubuque staff gave 14 budget presentations to
various community groups, held an informal budget public input meeting with the City
Manager, held 6 public budget input sessions with City Council, and held a public hearing to
adopt the budget.
In September, the City of Dubuque launched a new interactive budget simulation tool called
Balancing Act. The online simulation invites community members to submit their own version
of a balanced budget under the same constraints faced by City Council, respond to high-
priority budget input questions, and leave comments. The Budget Office conducted
community outreach with the new tool via print and digital marketing and presentations.
A total of 380 community members attended the budget presentations. There have been
1 ,329-page views of the Balancing Act budget simulator tool and 163 budgets were submitted
by the public.
It has also been mentioned that House File 773 was created to address concerns of
reassessments increasing the value of property and cities pocketing the additional money.
Assessors are not employees of the cities, nor are they governed by City Council. Assessors
are appointed to their position by a Conference Board consisting of the members of the
Board of Supervisors, the city, and school board members. A city with a population of ten-
thousand or more may elect to have their own assessor. Assessors are required, by statute,
to pass a state examination and complete a Continuing Education Program consisting of 150
hours of formal classroom instruction with 90 hours tested and a passing grade of 70°k
attained. The latter requirement must be met in order for the assessor to be re-appointed to
the position every six years. The Deputy Assessor also must pass a state examination as
well as successfully complete ninety hours of classroom instruction of at least sixty hours are
tested. The Conference Board approves the assessor's budget and after a public hearing
acts on adoption of same. The assessor is limited, by statute, depending upon the value of
the jurisdiction, to a levy limitation for his budget. The primary duty and responsibility of the
assessor is to measure, list and value all real property within his/her jurisdiction except that
which is otherwise provided for by law. The assessor's responsibilities fall under the
direction of the lowa Department of Revenue. The statutory date of assessment is
January 1st.
The lowa Department of Revenue is responsible for "equalizing" assessments every two
years. Also, equalization occurs on an assessing jurisdiction basis, not on a statewide basis.
«Title» «First» «Last»
April 15, 2019
Page 4
The assessor determines a full or partial value of new construction, or improvements
depending upon the state of completion as of January 1 st. Each year any property owner
who is dissatisfied with their assessment may appeal to the Assessor in an informal appeal
April 2nd through April 25th and/or petition the Board of Review against that assessment
between April 2nd and April 30th. The Board of Review members are appointed by the
Conference Board and may have three or five members. As per state statute, one member
must be a farmer, one a licensed realtor and one who has knowledge in the building or
construction field. This is an independent board to which property owner(s may appeal if
they feel their assessment is excessive or inequitable. The Board of Review has broad
powers including the right to increase or decrease any assessment. If a property owner is not
satisfied with the board's decision, they can file an appeal with the Property Assessment
Appeal Board or Distrid Court.
Cities are not "pocketing" the additional money from property assessment increases. It is
important to look at the full picture when reviewing city tax levies as compared to taxable
valuations. If a tax levy increases in a year that there was also an increase in taxable
valuations, most likely there were significant expense increases for that city. It is possible the
expense increases were outside the control of the city (IPERS, MFPRSI, health, etc..
The following chart shows the history of State of lowa taxable valuations by class of property
for the assessment years 1977-2017 (FY 1979 — FY 2019:
% Change in Taxable Valuation
10%
8% 8% 8%
6% 6% 6%
5% 5 5% 5 5% %
4% 4% 4%
3% 3%
2% 2% Za� a 3%
1 a/Za�p 1 a/o 2/o �' 2%
0% 1%
-2% -2%
-3%
-4%
��` �`� e^ �'� e`� e�` o°j a^ a'� a`� �� a� o^ o`� 05 0� o°� �^ �`� �5 ��
�� �g �� �� �9 �� �� �� ^� �� �g �� ti� ti� ti� ti� ti� ti� ti� ti� ti�
Fiscal Year
Source: https://dom.iowa.aov/documenUindividual-tau-levies-all-cities-2002-2019
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April 15, 2019
Page 5
The City of Dubuque has minimized property tax increases over the years by diversifying
revenues and by being fiscally responsible. The City of Dubuque has minimized expense
increases by being proactive and bidding costs, including the third-party administrator for the
self-insured health plan which reduced costs by 19.42°k in the first year and the benefit
provider for the prescription drug plan which is estimated to reduce costs by $244,000.
However, there are many revenue and expense changes that are out of the City's control,
which has included the end of State shared revenues in 2003, property tax reform which lead
to revenue loss for cities, increase in city contribution rates for the Municipal Fire and Police
Retirement and lowa Public Employee Retirement Systems, and the State of lowa
underfunding the Homestead Property Tax Credit from Fiscal Years 2004-2013
As you look at the lowa property tax system, I hope that you also take into consideration that
cities must diversify funding in order to minimize future property tax rate increases but are
limited by what is available by State law (local option sales tax is capped at 1°k, hotel/motel
tax is capped at 7°k, and an entertainment tax is not available. In addition, please be aware
of the many past changes implemented by the State of lowa that have had a negative impact
on cities and counties across the state. The complexity of the property tax system will
certainly lead to unintended consequences if additional property tax reform is adopted.
Sincerely,
�.1'.. " ' �Wq�������
(
Michael C. Van Milligen
City Manager
MCVM:jml
cc: Mayor Buol and City Council Members
Teri Goodmann, Assistant City Manager
The Honorable Pam Jochum The Honorable Carrie Koelker The Honorable Lindsay James
Senate Chamber Senate Chamber House Chamber
lowa Capitol Building lowa Capitol Building lowa Capitol Building
Des Moines. IA 50319 Des Moines. IA 50319 Des Moines. IA 50319
The Honorable Chuck Isenhart The Honorable Andy McKean The Honorable Shannon
House Chamber House Chamber Lundgren
lowa Capitol Building lowa Capitol Building House Chamber
Des Moines. IA 50319 Des Moines. IA 50319 lowa Capital Buildina
HF 773 : An Unnecessary Attack
on Local Control
House File 773 (HF 773), formerly HSB 165, includes
unnecessary amendments to the current lowa property .
tax system. Although the bill amendments are suggested � •
to have been created to increase transparency, there are ' •
already systems in place to promote local government
transparency and opportunities for residents and � - • -� �
stakeholders to dispute local budgets, tax rates, and •�� ' � ' � '
assessments. ' " ' ' "" • '
.. . .. . .
Many past property tax changes implemented by the '
State of lowa have had negative impacts on cities and
- . . . .. .
counties across the state. If this additional property tax � , � � _ � �
reform is adopted, it will likely lead to unintended , , ,
consequences that harm lowa communities. , .,- , .
. .. .
The tax rates set by cities in lowa are impacted by many � - - � - • •
factors, such as the change in taxable value, change in • • ' - � • • "
property class rollbacks, state equalization orders, state • " • " ' • "
funding level of the homestead credit, changes in other ' ' '
revenue streams such as local option sales tax, � � - � � �
hotel/motel tax, gas and electric franchise fees, gaming � � " ��� � � "
revenues, and state-mandated changes such as the
. - - - :.. . . . .
.- . . ... .
elimination of state shared revenues, city contribution to � , , � , �� ,�, ,
the Municipal Fire and Police Retirement and lowa Public
Employees Retirement Systems, and creation of the new - . .. - . .. . . .
property tax class of multi-residential. Additionally, if the . - . . ..-
State of lowa discontinues the backfill payment to cities �� • � �� -
for the rollback on commercial and industrial property, � �
that will also impact property tax rates set by cities. ' '• "' ' • • ' "
. .
. . . . - . - -. . . .
. . .
- . . . - . . - . . . . - .
. . - . .
. . .-
-. . . . . . . . It would � �
impose an arbitrary annual cap on the growth of property ,. �, _ _ ,_ _
taxes, regardless of rising costs or the needs and wishes - . ,- - . . .
of residents and stakeholders.
.- . . . . .
Home Rule: An lowa Tradition - � ��- � � �-
In 1968, the Home Rule Amendment was passed by the '• '• ' ' • ' ""
citizens of lowa and constitutionalized local control in the ' ' " • ' ' ' "" ' ' "
state. . . - . `' " ' '
. . . . . . . . - -
. . . . .
. - . . - . . . . . . . . - The unique needs
of our communities are best served through self-governance and home rule and local
control enable local governments to do just that. Pre-emption measures at the state level
limit the abilities of cities and counties to adapt to local needs.
Local control enables communities to best res ond to local issues, es eciall emer encies.
. . . . . . . . . . - . . .
. - . . . - . - job retention and creation opportunities, major infrastructure
failures, public safety improvements, mental health services, and many other quality-of-life
issues. Even improvement projects like a new swimming pool, library, or recreation center
that are supported by residents who want to pay for them may not be possible under an
arbitrary property tax cap as proposed in HF 773.
. . . that would have the greatest potential to negatively impact
the few areas in lowa that are growing. Those localities that are growing significantly are
likely facing demands for additional services for their growing populations. An arbitrary limit
makes it difficult for cities and counties to accommodate growth.
. . . Every local government has different
needs in different years that cannot be dealt with by an arbitrary property tax cap. Voters
elect local government officials and trust them to act in the best interest of their
communities. HF 773 will hamper the ability of local officials to provide quality services and
opportunities to their residents. If local governments have less flexibility due to additional
property tax reform, problems faced by local government will be worse and opportunities will
be missed. It would be especially detrimental to struggling communities that are trying to
revitalize themselves and reverse the population loss that most of the cities and counties in
lowa are experiencing.
. . - - . . - A protest process already exists in the current lowa Code
relating to budgets and budget amendments. lowa Code Chapter 384.19 allows written
protests from residents on both the adopted budget and budget amendments. Upon the
filing of any such protest, the county auditor shall immediately prepare a true and complete
copy of the written protest, together with the budget to which the objections are made, and
shall transmit the same forthwith to the state appeal board, and shall also send a copy of
the protest to the council. The state appeal board shall proceed to consider the protest in
accordance with the same provisions that protests to budgets of municipalities are
considered under chapter 24. The state appeal board shall certify its decision with respect
to the protest to the county auditor and to the parties to the appeal as provided by rule, and
the decision shall be final. lowa Code Chapter 384.16 requires a notice of public hearing on
the budget estimate and amendments to be published "not less than 10 days nor more than
20 days before the date of the hearing."
THE CITY OF
DuB E
Masterpiece on Ehe Mississippi
TELEGRAPH HERALD -April 14, 2019
Our opinion: Keep local choices a local matter
Telegraph Herald Editorial Board
http://www.teleqraphherald.com/news/opinion/article 829e6a97-eef9-578b-8fb7-
fceb0e080139.html
where we stand
A bill before the lowa Legislature to impose revenue caps and extra requirements on
local governments is a legislative overreach.
IYs not always easy to know where the lines of authority among legislative levels of
government should be drawn. In general, we believe iYs best to place decision-making
at the lowest — as in most local — level, where decision-makers are closest to those
impacted by their choices.
With that stated, there are cases, especially those impacting the well-being of the
public, where it makes sense for the higher level of government to mandate uniformity in
laws, policies and procedures.
However, a particular proposal before the lowa Legislature is not one of those cases.
A legislative committee has advanced a bill introduced by a northeast lowa
representative, Lee Hein, R-Monticello, that would limit local governments' annual
increases in tax revenue to 2°k, or require them to jump through hoops before collecting
more than that percentage.
Nobody likes paying higher taxes. A revenue jump of more than 2°k should spark
questions. But nobody should like state lawmakers deciding whaYs best for local
government.
Hein notes that local government officials might tout that they are holding the line on
property tax rates but conveniently fail to mention the increase in property assessments
and thus the larger tax bills that property owners receive.
ThaYs true. It can happen. It does happen. But iYs nothing new. And state legislators
should give citizens more credit for knowing that game.
The legislation, which the other day passed the House Ways and Means Committee,
which Hein chairs, on a 14-11 party-line vote, imposes other requirements on local
1
governments that are looking for more than 2 percent or carrying "too high" a carryover
balance.
It also provides for a means to force a public referendum on the tax asking.
While we endorse responsible budgeting, taxation and communication, we don't
endorse the State of lowa's determination that local officials and local constituents can't
sort this out.
If citizens think their taxes are too high, there already is a referendum process in place:
IYs called the general election. If voters don't agree with decisions of their local officials,
they can vote them out.
Further, local governments already hold public meetings at which budgetary matters are
discussed, and budgets and tax askings are approved in a public vote.
In fact, when you get down to it, it can be argued that local governments are more
transparent in their proceedings than the state Legislature, which conveniently exempts
itself from the lowa Open Meetings law.
State lawmakers have their hands full with statewide issues. (For a positive example,
Hein's committee advanced a bill that helps families by doubling the income limitation
for the lowa child and dependent care tax credit.)
Local property taxes are a local issue. Let local officials make those decisions, and be
accountable to local voters on any consequences.
Editorials reflect the consensus of the Telegraph Herald Editorial Board.
Copyright, Telegraph Herald. This story cannot be published, broadcast, rewritten or
redistributed without prior authorization from the TH.
2
City of Dubuque
Unfunded Federal and State Mandates
1. State-mandated Municipal Fire and Police Retirement System City contribution.
2. State-mandated lowa Public Employees' Retirement System City contribution.
3. State-mandated requirement to allow employees who retired before reaching 65 to
continue in the group health insurance plan until the employee reaches 65.
4. State-mandated requirement to publish weekly Council minutes and ordinances.
5. State-mandated Rollback on commercial, industrial, residential and multi-residential
property assessment.
6. State-mandated $8.10 General Fund Limit. Cities are limited by the levy rate of$8.10
per thousand of assessed valuation to pay for many services that are not covered under
another fund.
7. State-mandated property tax exemptions. These exemptions include Military Service Tax
Exemption and beginning in 1994, computers and industrial machinery equipment were
phased out of taxation.
8. State-mandated mobile home taxation. Mobile or manufactured housing located within a
mobile home park or manufactured housing community are taxed on a square footage
rate.
9. State-mandated Right-of-Way Rental Charge. In 1998, the State removed cities right to
grant telephone franchises and only allows a city to collect those costs attributed to
managing the public right-of-way.
10. State-mandated municipal infractions. A municipal infraction is a civil offense punishable
by a civil penalty of not more than $500 for each violation or if the infraction is a repeat
offense, a civil penalty not to exceed $750 for each repeat offense.
11. State DNR requirements. The U.S. Environmental Protection Agency (EPA) has issued
certain requirements forcing cities to comply with certain environmental laws. The lowa
Department of Natural Resources (IDNR) acting as the state monitor for compliance with
these laws has either included stricter compliance regulations or filing fees. State should
prohibit IDNR form imposing any greater compliance regulation that the federal
government requires from cities. In addition to this, the provision should also prohibit the
state from charging cities for compliance with federal laws.
12. State-mandated Water fees. Code of lowa 455B.183A established various fees that
public water supply systems are required to pay. Certain fees are related to construction,
installation, or modification of a public water supply system. This section also includes
the requirement that a public water supply system pay a filing fee to the lowa
Department of Natural Resources based on a per capita amount that equals $350,000.
State should remove the filing fees to IDNR. These fees actually double the mandates in
that cities are required to pay fees to the state in order to ensure that they are in
compliance with federal rules.
13. State-mandated Landfill Waste Reduction Goals. Municipal landfills must meet certain
waste reduction goals in order to remit less tonnage fees to the lowa Department of
Natural Resources. State should lift restrictions on cities and allow cities to retain the
entire amount collected from tipping fees. Municipal landfills should meet their own goals
in waste reduction.
14. State-mandated Civil Service Requirements. Code of lowa Chapter 400 requires cities to
follow a stringent and complicated civil service hiring practices. State should eliminate
Code of lowa Chapter 400 and give cities the option of adopting their own hiring
practices.
1
City of Dubuque
Unfunded Federal and State Mandates
15. State-mandated Probationary Period for Law Enforcement Personnel. Code of lowa
400.8(2) requires civil service cities to provide a nine-month probationary period for law
enforcement personnel. State should allow cities to determine the probationary period of
city employees.
16. State-mandated Civil Service-Filling a Higher-Grade Position. Code of lowa Section
400.11 the last sentence reads "Any person temporarily filling a vacancy in a position of
higher grade for twenty days or more, shall receive the salary paid in such higher grade."
State should remove this provision in civil service legislation.
17. State-mandated Park Impact Fees. In a 2002 decision in Home Builders Association of
GreaterDes Moines v. CityofWestDes Moines, the lowa Supreme Court ruled that
charging developers for park development is a tax not expressly authorized by the Code
of lowa. State should allow cities to enact legislation that authorizes impact fees to be
used for street, traffic control and infrastructure improvements needed to support
developments and for other public facilities including parks and other recreation,
convention, cultural and entertainment facilities.
18. State-mandated ILEA Police Training. When a city hires a police officer, the city is
required to have the police officer certified by sending the officer through the lowa Law
Enforcement Academy. State should allow cities to send their officers to the ILEA for
certification at no cost. Since the state requires certification and no reimbursement
money is provided, this requirement is an unfunded mandate. Allow individuals to attend
ILEA at their own cost.
19. State-mandated Enforcement of Private Handicap Parking. Code of lowa 321 L.4(3)
requires law enforcement officers enforce handicapped parking requirement on private
property. State should remove requirement that law enforcement officers be required to
enforce this requirement on private property since it is the decision of the property owner
to have these handicapped parking spaces.
20. State-mandated Financial Audit Filing Fee. Cities are required to pay a fee when they file
their Certified Financial Audit with the Auditor of the State. This fee is in addition to the
cost of having the audit performed. State should eliminate filing fees for audits.
21. State-mandated lowa One Call Utility Location program.
22. State-mandated Building Code Enforcement of handicapped accessibility standards,
energy conservation standards, and manufactured structure installation standards.
23. State-mandated Health inspections of restaurants, tanning/tattoo parlor, hotels, and
swimming pools.
24. State-mandated rental licensing and regular inspection of rental properties.
25. State-and Federal-mandated Water Backflow Control Devices, which protect public
water supplies from potential contamination.
26. State-mandated reports: Annual Financial Report, Street Financial Report, Outstanding
Debt Report, State Tax Increment Financing Report.
27. State-mandated Pay-As-You-Throw Program.
28. State-mandated yard waste collection program.
29. State-mandated Airport State Department of Natural Resources —wildlife and water run-
off management.
30. Federally-mandated American's with Disabilities Act implementation rules.
31. Federally-mandated Affordable Health Care Act.
32. Federally-mandated EPA Consent Decree
33. Federally-mandated National Pollution Discharge Elimination System (NDPES)
2
City of Dubuque
Unfunded Federal and State Mandates
34. Federally-mandated public safety software licensing.
35. Federally-mandated street sign minimum retro-reflectivity requirements.
36. Federally-mandated certification process for the levee and floodwall system.
37. Federally-mandated Section 106 review compliance for housing rehabilitation projects.
38. Federally-mandated operating procedures for Water& Resource Recovery Center
mandated by the Resource Conservation and Recovery Act, Superfund legislation and
Superfund Amendments Reauthorization Act, and EPA. This results in increased level of
testing at the plant.
39. Federally-mandated industrial pretreatment program for sanitary sewer (W&RRC).
40. Federally-mandated all emergency radio systems become P25 compliant.
41. Federally-mandated vulnerability assessment for the water system.
42. Federally and State-mandated monitoring and evaluating system chlorine residuals for
compliance levels within the water distribution system.
43. Federally-mandated Voluntary Compliance AgreemenUFair Housing Training.
44. Federally-mandated Para-Transit Service (rate/fare setting, trip length, eligibility
application and third-party verification, trip scheduling and no-show policy)
45. Federally-mandated Transit Asset Management subject to review by FTA.
46. Federally-mandated Airport Transportation Security Regulations Part 1542.
47. Federally-mandated Airport Safe, Efficient Use, and Preservation of the Navigable
Airspace Part 77.
48. Federally-mandated Airport Subpart C —Airport Certification Part 139
49. Federally-mandated Airport Subpart D — Operations (safety areas, marking, signs,
lighting, snow and ice control, aircraft rescue and firefighting, handling of hazardous
substances and materials, traffic and wind direction indicators, emergency plan, self-
inspection program, pedestrians and ground vehicles, obstructions, protection of
NAVAIDS, public protection, wildlife hazard management, airport condition reporting,
unserviceable areas).
50. Federally-mandated Airport FAR Part 150— Noise Compatibility Planning.
51. Federally-mandated Airport Compliance — FAA Order 5190.6b
3