Amendment to Bee Branch Healthy Homes Administrative Plan Copyrighted
November4, 2019
City of Dubuque Action Items # 4.
ITEM TITLE: Amendmentto Bee Branch Healthy HomesAdministrative
Plan
SUMMARY: City Manager recommending approval of anAmendmentto
the Bee Branch Healthy Homes Administrative Plan to
require rental property owners that participate in the
program to accept Housing Choice Vouchers from qualified
prospective tenants for the duration of their forgivable loan
agreement with the City of Dubuque. It is further
recommended that staff be directed to submit the
amendment to the lowa Economic DevelopmentAuthority
for adoption and approval of the changes.
SUGGESTED DISPOSITION: Suggested Disposition: Receiveand File;Approve
ATTACHMENTS:
Description Type
Amendmentto Bee Branch Healthy Homes City Manager Memo
Administrati� Plan-MVM Memo
Staff Memo Staff Memo
DraftAdministrative Plan Supporting Documentation
Dubuque
THE CITY OF �
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Amendment to Bee Branch Healthy Homes Administrative Plan
DATE: October 31, 2019
Housing & Community Development Director Alexis Steger recommends City Council
approval of an Amendment to the Bee Branch Healthy Homes Administrative Plan to
require rental property owners that participate in the program to accept Housing Choice
Vouchers from qualified prospective tenants for the duration of their forgivable loan
agreement with the City of Dubuque. It is further recommended that staff be directed to
submit the amendment to the lowa Economic Development Authority for adoption and
approval of the changes.
Dubuque Area Landlord Association Executive Board met with the Housing &
Community Development Director on October 30t", 2019 to discuss this
change. Several questions were posed in regards to what would constitute
"required acceptance" of a Housing Choice Voucher. After the meeting, Jerry
Maro, President of Dubuque Area Landlord Association, reported that the
board will support the wording of this memo, with no changes. He also
reiterated their continued commitment to work together, stating;
"Most felt more comfortable with it (the proposed change) after our
meeting with you this morning. Our goal; to work with you to better the
housing problems in Dubuque and to be part of the solution"
The Housing & Community Development Department greatly relies on this organization
to help develop sustainable strategies to make Dubuque housing affordable and safe.
The insights they provide are extremely important and this partnership will continue to
provide significant value as we move forward.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
�
Mic ael C. Van Milligen
MCVM:jh
Attachment
cc: Crenna Brumwell, City Attorney
Teri Goodmann, Assistant City Manager
Cori Burbach, Assistant City Manager
Alexis M. Steger, Housing & Community Development Director
2
Dubuque
THE CITY OF �
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Masterpiece on the Mississippi 2oi�*2o�9
TO: Michael C. Van Milligen, City Manager
FROM: Alexis M. Steger, Housing & Community Development Director
DATE: October 31, 2019
RE: Amendment to Bee Branch Healthy Homes Administrative Plan
Information
This memo is a request to amend the Bee Branch Healthy Homes Administrative Plan
to require rental property owners that participate in the program to accept Housing
Choice Vouchers from qualified prospective tenants for the duration of their forgivable
loan agreement with the City of Dubuque.
Discussion
In December 2014, the City Council approved formation of a Source of Income
Committee to conduct a two-year study examining the HCV program and its relationship
to fair housing, with a goal of identifying ways to enhance fair housing in Dubuque (see
Attachment C).
In February 2017, the Source of Income Committee ultimately recommended a
collective impact approach to adopt and implement a mix of educational, outreach, and
financial programs to increase housing provider participation in the HCV program.
These recommendations are found in the Comprehensive Plan:
• Adopt and implement a mix of educational / outreach programs to increase
participation in HCV program.
• Adopt and implement a mix of financial incentives / policies for creation of HCV
units throughout community.
Based on the Source of Income Committee recommendations, the City now requires
housing developers to accept HCV participants in conjunction with approval of an
affordable housing development agreement related to an urban revitalization plan.
The Housing & Community Development Department is continually reviewing policies
for programs that provide financial support to community members to find opportunities
to create additional choice of units for HCV holders. The Bee Branch Healthy Homes
programs is helping create sustainability in rental units for low/moderate income
residents, of whom most would qualify for housing assistance in the form of a Housing
Choice Voucher. To deny access to units that were assisted through the program to
voucher holders contradicts the direction given from the Source of Income Committee
and adopted by the City Council to implement financial incentives / policies for creation
of HCV units throughout the community and increase participation in the HCV program.
Therefore, an administrative plan amendment is being proposed for the program so that
Section 5.3 would state:
"The Rental Property Owner/Property Manager will be required to
maintain the income qualification of their rental property and accept
Housing Choice Vouchers (HCV) provided by the U.S. Department of
Housing and Urban Development (HUD) from qualified prospective
tenants for the duration of the forgivable loan agreement...Failure to
comply with the LMI tenant occupancy or accept HCVs from qualified
prospective tenants will result in the forgivable loan agreement
becoming immediately due and payable"
Dubuque Area Landlord Association (DALA) Executive Board met with the
Housing & Community Development Director on October 30�h, 2019 to discuss
this change. Several questions were posed in regards to what would constitute
"required acceptance" of a Housing Choice Voucher. After the meeting, Jerry
Maro, President of DALA, reported that the board will support the wording of
this memo, with no changes. He also reiterated their continued commitment to
work together, stating;
"Most felt more comfortable with it (the proposed change) after our
meeting with you this morning. Our goal; to work with you to better the
housing problems in Dubuque and to be part of the solution"
The Housing & Community Development Department greatly relies on this organization
to help develop sustainable strategies to make Dubuque housing affordable and safe.
The insights they provide are extremely important and this partnership will continue to
provide significant value as we move forward.
Consistency with City Council Goals & Priorities
This amendment furthers the City Council goal of having "Livable Neighborhoods and
Housing: Great Place to Live", and supports the current management agenda for the
CHANGE Program and the Multi-Tiered Inspection Program that help create safe,
affordable housing options for all residents.
Consistency with the Consolidation Plan
The U.S. Department of Housing and Urban Development (HUD) requires communities
who receive Community Development Block Grant (CDBG) funds to complete a five-
year Consolidated Plan that identifies general areas of need in the community and how
to address them, particularly in the areas of housing, economic opportunity, and
community development.
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The City of Dubuque reviews administrative plan changes using CDBG funding as a
match to the grant, to ensure the changes are consistent with the needs identified in the
current Consolidated Plan. This amendment is consistent with the needs identified in
that plan helps meet the objective to "Provide for implementation of fair housing
opportunities".
Consistency with Comprehensive Plan
This amendment is also consistent with Comprehensive's Plan recommendations for
implementing a mix of programs to increase housing provider participation in Housing
Choice Voucher program, and encouraging a mix of housing affordable for all
segments of Dubuque's population throughout the community as found in Chapter 3, 6
& 9 of the Comprehensive Plan.
Recommendation
Staff recommends the City Council approve the draft amendment to the Bee Branch
Healthy Homes Administrative plan to require rental property owners using that program
to accept Housing Choice Vouchers from otherwise qualifying tenants. This
recommendation is based on guidance from the Source of Income Committee, the City
Council and consistency from plans adopted by the city to address the housing needs in
the City.
If approved, the draft amendment will be sent to the lowa Economic Development
Authority for approval of the amendment. Once approved, the change would be
implemented.
Action Requested
I respectfully request City Council approves the draft amendment to the Bee Branch
Healthy Homes Administrative Plan and direct staff to submit the draft to the lowa
Economic Development Authority for adoption and approval of the changes.
3
City of Dubuque
HUD Resiiiency Prvgram
Contract #'13-NDRli-��'I
Administrati�e Plan
2a�s
i
TABLE OF CONTENTS
Section Paqe Numb�r
1.0 Program Overview..................................................................................... 1
2.0 Goals and Objectives..................................•---�--�....................................... 1
3.0 Definitions..................................................................................................
2
3.1 Adjusted (Gross) Household Income............................................ 2
3.2 Annual (Gross) Household Income.............................................. 2
3.3 Certified Lead Professional............................................................. 2
3.4 Chewable Surfaces................................................................................. 2
3.5 City.....................................................................................................................2
3.6 De Minimis Levels ............................................................................. 2
3.7 Disaster Assisted Unit....................................................................... 3
3.8 Disaster Event..........................................................................�--�---.. 3
3.9 Dust-Lead Hazard .......................................................................................3
3.10 Flood Insurance ................................................................................ 3
3.11 Friction Surfaces ....................................................................... 3
3.12 Hardship............................................................................................ 3
3.13 Hazardous Lead-Based Paint ........................................................... 4
3.14 Household ......................................................................................... 4
3.15 Impact SurFaces ........................................................................ 4
3.16 Interim Controls................................................................................. 4
3.17 lowa Economic Development Authority (IEDA) ................................. 4
3.18 lowa Department of Public Health (IDPH)......................................... 4
3.19 Lead-Based Paint Abatement ........................................................... 4
3.20 Lead-Based Paint.............................................................................. 4
3.21 Lead-Based Paint Hazard............................................................... 5
3.22 Lead Hazard Reduction..................................................................... 5
3.23 Lead Hazard Reduction Carrying Costs............................................ 5
3.24 Lead Safe ......................................................................................... 5
3.25 Lead Safe Housing Regulations........................................................ 5
3.26 Leveraged Funds .............................................................................. 5
3.27 Median Household Income................................................................ 6
3.28 Paint Stabilization ............................................................................. 6
3.29 Paint Testing ..................................................................................... 6
3.30 Prohibited Methods of Paint Removal ............................................... 6
3.31 Program Funds ................................................................................. 6
3.32 Resiliency Standards......................................................................... 6
3.33 Safe Work Practices.......................................................................... 6
3.34 Standard Treatments ........................................................................ 6
3.35 Soil-Lead Hazards............................................................................. 7
3.36 Target Housing.................................................................................. 7
3.37 US Department of Housing and Urban Development (HUD) ..........., 7
3.38 "Worksite" or "work area" .................................................................. 7
4.0 Program Scope.......................................................................................... 7
4.1 Eligible Expenditures......................................................................... 7
4.2 Resiliency Costs................................................................................ 7
4.3 Resiliency Standards................................ ..................................... 8
4.4 Project Delivery Costs....................................................................... 8
5.0 Eligibility Requirements ............................................................................. 8
5.1 Applicant Requirements .................................................................... 8
5.1a Owner-Occupied Properties.................................................... 8
5.1 b Renter/Tenant-Occupied Properties........................................ 9
5.2 Tenure............................................................................................... 9
5.3 Income Eligible.................................................................................. 9
6.0 Property Requirements............................................................................ 10
6.1 Location of Property......................................................................... 10
6.2 Mortgage Payments.......................... �----........................................ 10
6.3 Property Taxes ................................................................................ 10
6.4 Utilities ............................................................................................. 10
6.5 Property Insurance .......................................................................... 11
6.6 Condition of Property....................................................................... 11
6.7 Manufactured Homes ...................................................................... 11
6.8 Ability to Conform to Standards ...................................................... 12
7.0 Maximum Amount of Program Assistance .............................................. 12
8.0 Form of Assistance ................................................................................. 12
8.1 Five-Year Receding Forgivable Loan ..................................... 12
8.2 Owner-0ccupied Properties............................................................... 14
8.3 Rental Properties............................................................................. 14
8.4 Unsecured Program Funds Assistance ........................................... 14
9.0 Program Mechanics ...................................................................................................15
9.1 Marketing the Program ....................................................................................15
9.1 a Marketing to Applicants ......................................................................15
9.1 b Marketing to Contractors ....................................................................16
9.2 Applicant Selection Process ..........................................................................17
9.2a Ranking System ...................................................................................17
9.2b Application Selection Criteria Formula ..........................................17
9.3 Applicant Eligibility Determination and Verification Process ................17
9.4 Duplication of Benefits (DOB).......................................................... 18
9.5 Initial Property Inspection ................................................................ 19
9.6 Work Write-up (Project Specifications) ............................................ 20
9.7 Cost Estimate .................................................................................. 20
9.8 Historical Clearance ........................................................................ 20
9.9 Infeasible Structures........................................................................ 20
9.10 Level of Benefit / Financial Commitment ......................................... 21
9.11 Target Housing - Lead Hazard Reduction ....................................... 21
9.12 Contractor Requirements................................................................. 24
9.13 Contractor Procurement .................................................................. 24
9.14 Contract Execution .......................................................................... 25
9.15 Pre-construction Conference........................................................... 26
9.16 Target Housing — Occupancy .......................................................... 27
9.17 Eight Daytime Hours or Five Calendar Days ................................... 2$
9.18 Temporary Relocation ..................................................................... 28
9.19 Construction Supervision ................................................................. 29
9.20 Change Orders ................................................................................
29
9.21 Contractor Payment Procedures ..................................................... 3�
9.22 Project Completion /Acceptance..................................................... 31
10.0 Program Administration ........................................................................... 33
10.1 Responsibilities of Parties................................................................ 33
10.1a City ....................................................................................... 33
10.1 b Housing Resiliency Committee ............................................ 34
10.1c Resiliency Coordinator.......................................................... 34
10.1d Resiliency Inspector.....................................................
........................35
10.1 e Home Advocate........................................................................................36
10.1f GrantAdministrator..................................................................................3fi
10.1g East Central Intergovemmental Association (ECIA).............................37
10.1 h Intake Person............................................................................................37
11.0 Grievance and Dispute Resolution .......................................................... 37
12.0 Temporary Relocation Policy...................................................................... i
Exhibit A: Temporary Relocation Policy and Contracts
Exhibit B: Target Area Map
Exhibit C: Bee Branch Healthy Homes Resiliency Project— Construction Scope
of Work
Exhibit D: 24CFR35.115 Listing of Exemptions to Lead Abatement requirements
Exhibit E: Elderly Waiver for Relocation
Exhibit F; Attachment D: Bee Branch Healthy Homes Resiliency Program Guidelines
CDBG-NDR (National Disaster Resiliency) Funds
Exhibit G: HUD CPD Green Building Checklist
Exhibit H: Homeowner Application
Exhibit I: Rental Property Owner Application
Exhibit J: Tenant Application
Exhibit K: BBHHRP Process
Exhibit L: Dubuque Organizational Chart
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i
City of Dubuque HUD ResiN�ency Program
Bee Branch Healthy Homes Resiliency Program
1.0 Program Overview
• The Bee Branch Healthy Homes Resiliency Program (BBHHRP) is designed
to support residential properties with flood damage from the 2011 storms in
the low- to moderate-income areas of Dubuque that are strategically aligned
with and extending to and from the Bee Branch Creek Restoration Project,
within the Bee Branch Creek Watershed, in accordance with the application
for and award of U.S. Department of Housing and Urban Development (HUD)
National Disaster Resiliency (NDR) Funds.
• The BBHHRP is eligible for NDR funding as a result of the presidentially
declared Disaster DR-4018, Severe Storms and Flooding with an Incident
Period of July 27-29, 2011.
• All activities funded through this program shall comply with this City of
Dubuque Administrative Plan, Attachment D of the Contract, and IEDA's
Management Guide and any other guidance provided by IEDA.
• Participating properties will be located within the Flood Resiliency Eligible
Area (see Exhibit B — target area map; census tracts), will be flood impacted,
and will be determined eligible to participate by the City of Dubuque. There
are three eligible areas for the BBHHRP program. In general descriptive
terms, the three areas include: 1) an area bounded on the east by Windsor
Ave, Schiller St., and Kerper Blvd.; on the south by West 8th, Hill and West 5tn
Streets; on the west by Alta Vista, University Ave., Cox St., Woodworth St,
Kane St., Berkley PI., and Meadow Wood and Wild Wood Drives; on the north
by West 32"d St. with an area extending north between Central Ave. and
Jackson St to Aquin Ave. and then generally east crossing and including
portions of Brunswick O'Neill St., Burden Ave. and Davis Avenue; 2) an area
bounded on the east by Carter Rd.; on the south by Asbury Rd.; on the west
by Kennedy Rd., on the north by Kaufmann Ave.; 3) an area bounded on the
east by St. Ambrose St. North Grandview Ave. and Wood St.; on the south by
Loras Blvd. and University Ave., on the west by Asbury and Bunker Hill Rds.;
and on the north by Fairway and Sunnyview Drives, and North Grandview and
Rosedale Avenues. The above street narrative are for descriptive purposes
only and all properties adjoining named streets may not be in the eligible area.
Specific property addresses must be entered into the City's online interactive
map to determine if the property lies in the eligible area. The link to the map
is: www.cit ofdubu ue.or /bbhh
2.0 Goals and Objectives
The primary goals and objectives of the BBHHRP are:
• To preserve and/or stabilize the City's housing stock in the Bee Branch Creek
Watershed that is affordable to low- and moderate-income persons;
• To make resiliency and improvements to housing of the City's residents who
1
do not have the financial means to make repairs and improvements to their
own dwellings or rental properties.
3.0 Definitions
3.1 Adjusted (Gross) Household Income: The definition of adjusted (gross)
household income, as used for the BBHHRP, is the same as the definition used
in HUD's Section 8 Housing Assistance Payments programs (24 CFR, Part 813).
Adjusted income is annual (gross) household income reduced by certain
deductions for dependents, elderly households, medical expenses, childcare,
and expenses related to assistance for persons with disabilities. Adjusted (gross)
household income is used o�to determine the level of benefit available to the
City's applicants. (Refer to Section 9.3 for more detail on how an applicant's
adjusted (gross) household income is used in the BBHHRP).
The Household Income of the property owner/occupants is used to determine
income eligibility for owner-occupied properties. The income of the tenant
households residing in the rental properties is used to determine income eligibility
for the property for rental properties.
3.2 Annual (Gross) Household Income: The definition of annual (gross)
household income, as used for the BBHHRP, is the same as the definition used
in HUD's Section 8 Housing Assistance Payments programs (24 CFR (Code of
Federal Regulations), Part 813). Annual (gross) household income is used in the
determination of income eligibility. (Refer to Section 7.3 for more detail on how
an applicant's annual (gross) household income is used in the BBHHRP).
3.3 Certified Lead Professional: Certified Lead Professional means a person
who has been certified by the lowa Department of Public Health as a Lead
Inspector/ Risk Assessor, Elevated Blood Level (EBL) Inspector/ Risk Assessor,
Lead Abatement Contractor, Lead Abatement Worker, Project Designer,
Sampling Technician, or Lead-Safe Renovator pursuant to 24 CFR 35.1340.
3.4 Chewable Surfaces: Means interior or exterior surFaces painted with lead-
based paint or presumed to be painted with lead-based paint that a young child
could mouth or chew (previously known as accessible surFaces).
3.5 City: City, as used in this document, means the City of Dubuque, the
recipient of the HUD Resiliency Grant (i.e., NDR funds awarded for the
Resiliency program).
3.6 De Minimis Levels: The application of safe work practices to rehabilitation
projects by the participating contractors and subcontractors is not required when
rehabilitation work and/or lead hazard reduction activities do not disturb painted
surFaces that total more than:
■ Twenty (20) square feet on exterior surfaces;
2
• Two (2) square feet in any one interior room or space, or
• Ten percent (10%) of the total surFace area of an interior or exterior
component with a small surFace area (e.g., windowsills, baseboards, trim,
etc.).
3.7 Disaster Assisted Unit: A residential unit occupied by a household, either
single family as a single unit or multiple units included in a multi-family complex.
The unit must be eligible to participate in the BBHHRP, must be located within
the eligible area, and must be occupied by an LMI (low-to-moderate income)
qualifying household or at least 51% of LMI qualifying households in a rental
complex. The owner of the property (either single family owner-occupied or
landlord) is not required to have been the owner of record at the time of the 2011
disaster, as all resiliency need will be documented as of 2016, all work will be
completed in a way that both recovers the unit(s) from disaster impact and
makes the unit(s) more resilient against future flooding, and all invested funds will
be secured by a lien on the property documenting the terms of the forgivable
loan.
3.8 Disaster Event: The BBHHRP is eligible for National Disaster Resiliency
funding as a result of the presidentially declared Disaster DR-4018, Severe
Sforms and Flooding with an Incident Period of July 27-29, 2011.
3.9 Dust-Lead Hazard: Dust-lead hazard means surFace dust in residential
dwellings that contains a mass-per-area concentration of lead equal to or
exceeding 40 micrograms per square foot on floors, 250 micrograms per square
foot on interior windowsills, and 400 micrograms per square foot on window
troughs based on dust wipe samples. A dust-lead hazard is present in a
residential dwelling when the weighted arithmetic mean lead loading for all
single-surface or composite samples of floors and interior windowsills is equal to
or greater than 40 micrograms per square foot on floors, 250 micrograms per
square foot on interior windowsills, and 400 micrograms per square foot on
window troughs based on dust wipe samples.
3.10 Flood Insurance: Insurance that protects the property in the event of a
flood event whereby the owner may be reimbursed for damages resulting from
the flood. Properties located in a 100-year floodplain must have a flood
insurance policy for the duration of the forgivable loan agreement with the
minimum coverage amount equal to the amount of the HUD Resiliency Grant
funds invested in the property and having the minimum owner deductibles
allowed in the flood insurance program.
3.11 Friction Surfaces: Friction surFaces mean interior or exterior surFaces that
are subject to abrasion or friction, including, but not limited to, certain window,
floor and stair surFaces.
3.12 Hardship: Owner-occupied households are considered to have a Hardship
status if their property is located in the 100-year floodplain, thereby requiring the
owner to purchase and maintain a flood insurance policy and the flood insurance
3
premiums exceed 1.5% of the household income based on income at the time of
the application verification.
3.13 Hazardous Lead-Based Paint: Hazardous Lead-Based Paint means lead-
based paint (known or presumed to be lead-based paint) that is present on a
friction surFace where there is evidence of abrasion or where the dust-lead level
on the nearest horizontal surFace underneath the friction surface (e.g., the
window sill or floor) is equal to or greater than the dust-lead level; lead-based
paint that is present on an impact surface that is damaged or otherwise
deteriorated from impact; lead-based paint that is present on a chewable surFace;
or any other deteriorated lead-based paint in the residential dwelling or on the
exterior of the residential dwelling.
3.14 Household: Household means one or more persons occupying a dwelling.
3.15 Impact Surfaces: Impact surFaces mean interior or exterior surFaces that
are subject to damage by repeated sudden force, such as certain parts of
doorFrames.
3.16 Interim Controls: Interim controls means a set of ineasures designed to
temporarily reduce human exposure to lead-based paint hazards, including
repairing deteriorated lead-based paint, specialized cleaning, maintenance,
painting, and temporary containment. For the purpose of this program, interim
controls must address all lead-based paint hazards in the assisted housing. The
lead-based paint hazards must be identified by an lowa certified lead inspector/
risk assessor or an lowa certified elevated blood lead (EBL) inspector/ risk
assessor through paint testing and a risk assessment.
3.17 lowa Economic Development Authority (IEDA): The IEDA is the primary
funding source for the BBHHRP through its federally (HUD) financed program
known as the HUD Resiliency Program.
3.18 lowa Department of Public Health (IDPH): In lowa, the IDPH is the
regulatory agency overseeing, in part, the Lead-Based Paint Activities Training
and Certification program. The IDPH also establishes minimum work practice
standards for lead professional activities.
3.19 Lead-Based Paint Abatement: The process of safely removing and
permanently eliminating all lead-based paint hazards.
3.20 Lead-Based Paint: Lead-based paint means paint or other surFace
coatings that contain lead greater than or equal to 1.0 milligram per square
centimeter or greater than 0.5 percent by weight. Lead-based paint is present on
any surface that is tested and found to contain lead greater than or equal to 1.0
milligram per square centimeter or greater than 0.5 percent by weight and on any
surFace like a surface tested in the same room equivalent that has a similar
painting history and that is found to be lead-based paint.
4
I 3.21 Lead-Based Paint Hazard: Lead-based paint hazard means hazardous
lead- based paint, a dust-lead hazard, or a soil-lead hazard.
3.22 Lead Hazard Reduction: Lead hazard reduction means the reduction of
lead-based paint hazards through interim controls or standard treatments. For
purposes of this program, lead hazard reduction activities temporarily reduce
lead- based paint hazards.
3.23 Lead Hazard Reduction Carrying Costs: Lead hazard reduction carrying
costs are basically administrative in nature. Lead hazard reduction carrying costs
are the additional costs incurred by the community's lead professional staff to
ensure that target housing is lead safe at the completion of the rehabilitation
project following required clearance testing and final visual risk assessment.
Lead hazard reduction carrying costs include, but are not limited to, required
notifications and reports (preparation and/or conveyance), required paint testing
and risk assessment (including laboratory analysis costs) or presumption of lead-
based paint and/or lead-based paint hazards, visual risk assessment following
the presumption of lead-based paint and/or lead-based paint hazards, revising
project work write- ups to include lead hazard reduction activities and
methodologies, construction oversight to ensure that safe work practices are
used by participating contractors and subcontractors, and clearance testing and
final visual assessment (including laboratory analysis costs).
3.24 Lead Safe: "Lead safe" is the temporary condition of assisted housing
immediately following the application of interim controls, paint stabilization, or
standard treatments to temporarily reduce lead-based paint hazards and upon
passing clearance testing and final visual assessment that meets the lowa
Department of Public Health (IDPH) standards. Lead hazard reduction measures
incorporated into the City's target housing Resiliency projects (including paint
stabilization, interim controls, and standard treatments) only tempara�iix reduces
exposure by the occupants of the dwelling to lead-based paint hazards. Lead
hazard reduction activity does not result in the assisted property being
permanentiv free of lead-based paint and/or lead-based paint hazards.
Additionally, rehabilitation projects receiving $5,000 or less in federal funding
assistance (from all potential funding sources for the hard costs of rehabilitation)
are not considered lead safe, only those areas (components) of the dwelling
specifically addressed with, or affected by, the rehabilitation work and/or lead
hazard reduction activity and has passed clearance testing and final visual
assessment are considered "lead safe", not the entire dwelling.
3.25 Lead Safe Housing Regulations: The Lead Safe Housing Regulations are
technically known as the "Requirements for Notification, Evaluation, and
Reduction of Lead Based Paint Hazards in Federally Owned Residential Property
and Housing Receiving Federal Assistance; Final Rule" found at 24 CFR Part 35
et.al.
3.26 Leveraged Funds: Leveraged Funds are funds used to pay for costs that
are not directly attributable to the resiliency work being perFormed. Examples of
5
such funds would include lead-based paint or other rehabilitation work within the
eligible Bee Branch Watershed on properties where BBHHRP funds are or are
not being utilized.
3.27 Median Household Income: Median household income means the area
median household income established annually by HUD, by county, and based
on household size.
3.28 Paint Stabilization: Paint Stabilization means repairing any physical defect
in the substrate of a painted surFace that is causing paint deterioration, removing
loose paint from surfaces to be treated, and applying new paint or other
protective coating pursuant to 24 CFR Part 35.
3.29 Paint Testing: Paint Testing means the process of determining, by a
certified lead inspector/ risk assessor or certified elevated blood lead (EBL)
inspector/ risk assessor, the presence or absence of lead-based paint on
deteriorated paint surFaces or painted surfaces to be disturbed or replaced
pursuant to 24 CFR Part 35 et. al.
3.30 Prohibited Methods of Paint Removal: The following methods shall not be
used to remove paint that is, or presumed to be, lead-based paint:
• Open flame burning or torching;
• Machine grinding or sanding without high efficiency particulate air (HEPA) local
exhaust control;
• Abrasive blasting or sandblasting without HEPA local exhaust control;
. Heat guns operating above 1,100 degrees Fahrenheit;
• Dry sanding or dry scraping (except dry scraping in conjunction with heat guns
or within one foot of electrical outlets, or in areas that fall within the de minimis
levels); or
• Paint stripping in poorly ventilated space using volatile strippers.
3.31 Program Funds: Program funds, as used in this document, means HUD
funds awarded to the community from the IEDA's HUD Resiliency Grant, even
though there may be other HUD funds or other federal funds used in the
BBHHRP.
3.32 Resiliency Standards: Resiliency standards, for the purpose of the
community's HUD Resiliency Grant Program, are detailed in Exhibit C, Bee
Branch Healthy Homes Resiliency Project— Construction Scope of Work. In
addition, any identified life/safety issues and/or violations of City ordinances will
be addressed in the program.
3.33 Safe Work Practices: Safe Work Practices include: a) prohibited methods
of paint removal, b) occupant protection, c) work site preparation, d) worker
protection, e) specialized cleaning, and fl the de minimis levels.
3.34 Standard Treatments: Standard treatments means a series of hazard
reduction measures designed to reduce all lead-based paint hazards in a
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residential dwelling without the benefit of a lead-based paint inspection and a risk
assessment. Standard treatments consist of the stabilization of all deteriorated
interior and exterior paint, the provision of smooth and cleanable horizontal
interior hard surfaces, the correction of dust-generating conditions (i.e.,
conditions causing rubbing, binding, or crushing of surfaces presumed to be
coated with lead-based paint), and the treatment of bare soil to control presumed
soil-lead hazards.
3.35 Soil-Lead Hazard: Soil-Lead Hazard means bare soil on residential real
property that contains total lead in excess of 400 parts per million for the dripline,
mid-yard, and play areas. A soil-lead hazard is present in a dripline, mid-yard, or
play area when the soil-lead concentration from a composite sample of bare soil
is equal to or greater than 400 parts per million.
3.36 Target Housing: Target housing generally means any housing constructed
prior to January 1, 1978. Refer to the Lead Safe Housing regulations found at
24 CFR Part 35 for exemptions.
3.37 U.S. Department of Housing and Urban Development (HUD): HUD is
the funding source for the IEDA's HUD Resiliency Grant Program.
3.38 "Worksite" or "work area" means an interior or exterior area where lead-
based paint hazard reduction activity or renovation or resiliency work takes
place. There may be more than one worksite in a dwelling unit
4.0 Program Scope
4.1 Eligible Expenditures: Program funds are intended to be used to cover the
hard costs of resiliency work (materials, labor, and the contractor's overhead and
profit) and the administrative (program implementation) costs associated with the
resiliency work in residential dwellings in the City that meet the eligibility
requirements detailed in Section 4.0.
4.2 Resiliency Costs: Resiliency costs are considered eligible expenditures
where the net result of such expenditures is the provision of Resiliency scope of
work standards referenced in Section 4.3, and as applicable, results in housing
that is more resilient to flooding and able to withstand flood events with minimal,
if any, resulting damages and any repair work required as a result of being
identified as a City code, standard, or ordinance violation. BBHHRP funds will be
utilized in a manner that results in green-rehab sustainable structures for all
resiliency work. All projects must utilize the HUD CPD Green Building Checklist
as enhanced by IEDA. All construction work is expected to be of good quality
and be reasonably priced.
The HUD Resiliency Grant funding is subject to the requirements of the Federal
Lead Safe Housing regulations, impacting all dwelling units that were
constructed prior to January 1, 1978. As a result, in housing units constructed
prior to January 1, 1978, the total amount of federal assistance provided to
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individual housing units will be tracked by program administrators to assure
compliance with the Lead Safe Housing regulations.
If less than $25,000 in federal assistance is invested in the hard costs of
resiliency/rehabilitation work, the portions of the dwelling where work is
performed will utilize Lead Safe Interim Controls and be made temporarily "lead
safe" following clearance testing and final visual assessment that meets IDPH
standards.
If$25,000 or more in federal assistance is invested in the hard costs of
resiliency/rehabilitation work, a full lead abatement of the property will be
completed in accordance with the Federal Lead Safe Housing regulations,
unless the property qualifies for an exemption under 24CFR35.115. See Exhibit
D for the 24CFR35.115 listing of exemptions.
4.3 Resiliency Standards: Upon completion, all dwellings financed entirely, or
partially, with the community's HUD Resiliency Grant funds must conform to the
City of Dubuque Resiliency Grant Construction Scope of Work. (See Exhibit C.)
In addition, the property will comply with all City codes, standards and
ordinances, as applicable.
4.4 Project Delivery Costs: The Project Delivery Costs associated with the HUD
Resiliency Grant will consist of a variety of activities, all of which must be
attributable to a specific housing unit within the housing activities undertaken per
uniUaddress and accounted for in this manner. Overall, project delivery costs
must be reasonable, documented and cannot exceed $15,000 per housing unit.
All project delivery costs must be supported with backup documentation to justify
their expenditure. Generally project delivery costs include the work associated
with the following activities within the grant program.
• Site Specific Environmental Review, such as Section 106 documentation
• Relocation Expenditures per unit as applicable
• Lead testing and Lead hazard control
• Staff time for inspecting participating units, developing work scopes, bidding
of projects, ongoing and final inspections
• Home Advocate
• Intake Verification of applicants
• Lien Development and Filing
5.0 Eligibility Requirements
5.1 Applicant Requirements:
5.1a. Owner-Occupied Properties: In order for an applicant to be eligible for
program assistance, the applicant must occupy the property to be assisted as
their principal place of residence and must own the property (i.e., be the
owner of record). Ownership means:
• Holding fee simple title to the property; or
• Maintaining a 99-year leasehold interest in the property; or
+ Holding a Land Sales Contract identifying the Applicant as the Owner
s
(Buyer) of the property to be assisted and the document is duly recorded
with the City Assessor's office. For the owner of a property with a Land
Sales Contract to be assisted, the Seller of the property must also agree to
and sign a Five-Year forgivable loan agreement and repayment
stipulations required in the event of a foreclosure, sale, or transfer of the
property within the five-year time period. All Land Sales Contract
properties will be reviewed on a case-by-case basis and approved by
IEDA prior to participating in the program.
5.1b Rental/Tenant-Occupied Properties: In order for a Rental Property
Owner applicant to be eligible for program assistance, the applicant must
own the property to be assisted with the rental property being 100%
residential in nature, be the owner of record, and be a registered landlord of
the property to be assisted with the City of Dubuque. Buildings with eight or
more units will require compliance with Davis-Bacon and Related Acts;
including the required wage rate minimums and weekly payroll reports.
Ownership means:
• Holding fee simple title to the property; or
• Maintaining a 99-year leasehold interest in the property.
5.2 Tenure: In addition to the ownership and occupancy requirements detailed
above in Section 5.1.a, the owner-occupant applicant must remain the owner of
record and continue to reside in the assisted property for the duration of the
forgivable loan agreement. See Section 8.0.
In addition to the ownership requirements detailed above in Section 5.1, the
owner of a rental property applicant must remain the owner of record of the
assisted property and continue to rent the property to maintain a minimum of
51% of the households being of low- to moderate-income based on the number
of units in the structure for a minimum of the duration of the forgivable loan
agreement. See Section 5.3 for the minimum number of income-qualified
households per structure.
5.3 Income Eligible: In order for an owner-occupied housing applicant to be
eligible for program assistance, the applicant must also be income eligible.
Specifically, the applicant must have an annual (gross) household income that
does not exceed eighty percent (80%) of the current area (county) median
household income (MHI), based on the applicant's household size, as
established by HUD. The procedure for determining that an applicant meets the
income eligibility requirement is detailed in Section 9.3.
In order for a rental property owner to be eligible for program assistance, the
tenants residing in the rental property must be income eligible. Specifically, the
tenant(s) must have an annual (gross) household income that does not exceed
eighty percent (80%) of the current area (county) median household income
(MHI), based on the applicant's household size, as established by HUD. The
procedure for determining that an applicant meets the income eligibility
requirement is detailed in Section 9.3.
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To meet the CDBG National Objective of"Primarily benefits persons of low and
moderate income" in rental housing properties, this means that at least 51% of
the units in an assisted property must be occupied by persons or households
whose incomes are at or below 80% of the area median income limits (LMI).
• In a one unit project—the one unit must be made available to and occupied
by a LMI tenant.
• In a two unit project —one of the two units must be made available to and
occupied by a LMI tenant.
• Projects of three or more units — 51% of all units in the project (rounded up
to the nearest whole number) must be made available to and occupied by a
LMI tenant (e.g., in a four unit project, three units must be made available to
and occupied by LMI tenants).
The Rental Property Owner/Property Manager will be required to maintain the
income qualification of their rental property and accept Housing Choice
Vouchers (HCV) provided by the U.S. Department of Housing and Urban
Development (HUD) from qualified prospective tenants for the duration of the
forgivable loan agreement. In the event of a vacancy in a unit occupied by an
LMI tenant, the Rental Property Owner/Property Manager must verify the tenant
income on non-HCV tenants to assure compliance with the terms of the
forgivable loan agreement. The City will verify HCV tenant income. Failure to
comply with LMI tenant occupancy or accept HCVs from qualified prospective
tenants will result in the forgivable loan agreement becoming immediately due
and payable.
6.0 Property Requirements:
6.1 Location of Property: In order to be eligible for program assistance, the
assisted property must be located within a low-income census tract in the Bee
Branch Creek Watershed as defined in the City's approved application and
contract with the lowa Economic Development Authority (IEDA). The property
will initially be checked against the eligible area project map and subsequently
verified utilizing the City's GIS department interactive map.
Properties located within a 100-year floodplain are eligible for assistance,
subject to the purchase and maintenance of a flood insurance in the minimum
amount of the BBHHRP investment for the duration of the forgivable loan
agreement.
6.2 Mortgage Payments: In order to be eligible for program assistance, the
assisted property owner must be current with regard to their mortgage
payments.
6.3 Property Taxes: In order to be eligible for program assistance, the assisted
property owner must be current with regard to payment of their real estate
property tax liability.
6.4 Utilities: In order to be eligible for program assistance, the assisted property
owner must be current with regard to their utility payments associated with that
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property. Utilities (natural gas, liquid petroleum gas, fuel oil, and electric) must be
current. City utilities (water, sanitary sewer, storm water and solid waste
disposal) must not be in a collection status.
Utilities not included under this requirement are telephone (landline or cellular),
cable television (including satellite television), or internet service providers.
6.5 Property Insurance: In order to be eligible for program assistance, the
assisted property must be covered by property insurance (homeowner's hazard
and liability insurance) in an amount equal to, or greater than, the current
assessed value of the property (land and buildings). For housing located in the
100-year floodplain, the assisted property must be covered by flood insurance in
an amount equal to, or greater than, the HUD Resiliency Grant investment in the
property. The City shall be named (included) on the assisted property owner's
insurance policy(ies) as an additional party insured for the duration of the
forgivable loan agreement. The City may utilize HUD Resiliency Grant funds to
pay the flood insurance premiums for the duration of the forgivable loan
agreement for property owners (owner-occupied properties only) who are
determined to suffer a hardship as a result of the cost of the flood insurance
premiums. The City payment of premiums will be limited to the cost of the flood
insurance premiums for a policy in the amount of the HUD Resiliency Grant
investment, or minimum coverage amount allowed by the National Flood
Insurance Program, with the lowest deductible option available in the program.
See Section 3.12 for Hardship determination.
6.6 Condition of the Property: In order to be eligible for program assistance,
the property must be free of garbage; debris; refuse; building materials (those
not used for the resiliency project); abandoned, non-operational or junk vehicles;
etc. Additionally, the property must not be in violation of any local nuisance
ordinances.
The dwelling itself must be reasonably clean and sanitary; free of garbage,
debris and refuse; uncluttered; and in such a state that permits reasonable
access by the City's Resiliency Technician to conduct the initial inspection and,
as applicable, conduct paint testing and a risk assessment of the property, and
to the contractor(s) working on the property owner's project.
6.7 Manufactured Homes: Manufactured homes may be assisted with
BBHHRP funds only if all of the following criteria are met:
• The age of the manufactured home is 1976 or newer;
• The manufactured home is permanently affixed to a site-built, permanent
foundation and has had its towing hitch and running gear (including tongues,
axles, brakes, wheels, lights and any other parts of the chassis that operate
for the purpose of transportation) removed;
The manufactured home is installed on land also owned by the property
owner to be assisted; and
• The manufactured home (dwelling and site) is taxed as real estate (real
property) by the City.
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6.8 Ability to Conform to Standards: In order to be eligible for program
assistance, the dwelling (and the property as a whole) must be capable of
withstanding rehabilitation. In other words, program funds may not be used
unless the dwelling (and the property) can be brought into conformance with the
City's BBHHRP Standards, as applicable. (Refer to Section 9.9 for the details
regarding structurally or financially infeasible dwellings).
7.0 Maximum Amount of Program Assistance
There is no maximum amount of assistance to an individual resiliency project
from the community's program funds. The assistance level is on the hard costs
of rehabilitation (materials, labor and the contractor's overhead and profit) onlv,
not the administrative costs, or temporary relocation costs necessary to
complete the project.
Project costs (the hard costs of resiliency work) in excess of$24,999 from all
sources of federal funds will require the structure to have all lead-based paint
hazards abated from the property, unless the property qualifies for an exemption
in the lead regulations.
8.0 Form of Assistance
8.1 Five-Year Receding Forgivable Loan: The form of assistance for the hard
cost of rehabilitation under the City's BBHHRP is a five-year receding forgivable
loan. The five-year receding forgivable loan is technically a conditional grant,
whereby the full amount of the five-year receding forgivable loan is completely
waived (or released) over time.
In order for all assisted property owner(s) to receive a five-year receding
forgivable loan, he or she must sign a promissory note and mortgage lien to
secure the full amount of the five-year receding forgivable loan. The start date of
the forgivable loan period will be concurrent with the date of the BBHHRP
construction contract. The document will include a section whereby any change
orders are accounted for and a total forgivable loan amount will be identified.
The mortgage lien will be recorded at the Dubuque County Courthouse following
the completion of the Resiliency project. The five-year receding forgivable loan
bears no interest.
The term of the promissory note and mortgage lien is five years, remaining at
one hundred percent of the loan amount for the first full year and decreasing
twenty percent each year thereafter. The anniversary date of the promissory
note and mortgage lien is the date of the construction contract execution by all
parties. Collection of the note and mortgage lien (as may be necessary) will be
accomplished according to the following schedule:
■ If the assisted property is sold, rented, transferred, vacated or abandoned
prior to the first anniversary of the construction contract execution date, one-
hundred percent (100%) of the note and mortgage lien becomes due.
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• If the assisted property is sold, rented, transferred, vacated or abandoned
between the first and second anniversary of the construction contract
execution date, eighty percent (80%) of the note and mortgage lien becomes
due.
• If the assisted property is sold, rented, transferred, vacated or abandoned
between the second and third anniversary of the construction contract
execution date, sixty percent (60%) of the note and mortgage lien becomes
due.
• If the assisted property is sold, rented, transferred, vacated or abandoned
between the third and fourth anniversary of the construction contract
execution date, forty percent (40%) of the note and mortgage lien becomes
due.
■ If the assisted property is sold, rented, transferred vacated or abandoned
between the fourth and fifth anniversary of the construction contract execution
date, twenty percent (20%) of the note and mortgage lien becomes due.
+ At the fifth anniversary date, one-hundred percent (100%) of the note and
mortgage lien is forgiven. The community will release the assisted property
owner's note and mortgage lien, upon written request, following completion of
the five-year term.
All applicants, owner-occupants and rental property owners, must be given the
opportunity to rescind the assistance offered due to the fact that a lien, mortgage
or other security interest will be filed against their property as a result of the
assistance, if accepted and executed.
A five-year receding forgivable loan from the City to applicants will result in a
lien, mortgage or other security interest filed against their properties. Where
there are existing liens, mortgages or other security interests already on file
against assisted properties (e.g., the applicant's primary mortgage), the
community's BBHHRP assistance security interest may be filed (recorded) in a
junior position to existing liens, mortgages or security interests.
In the event of future liens, mortgages or security interests filed on an assisted
property owner's property (e.g., a refinancing), the City may, at its discretion,
subordinate its mortgage lien to any future liens, mortgages or other security
interests.
Payback of HUD Resiliency Grant (CDBG-NDR) funds remaining, or the total of
the net proceeds of the sale, whichever is less, will be required if the assisted
property owner sells, vacates, rents or abandons the property any time within the
5 year period. The City may, at its option, release the mortgage lien (and
subsequent conditions of the assistance) against the assisted property when
there are extenuating circumstances that would warrant or justify the
community's decision to do so, regardless of the age of the forgivable loan.
The City's release of a mortgage lien would be handled on a case-by-case basis
with consideration given to the individual circumstances of that assisted property
owner, or their representative, seeking the release. The City will gather sufficient
13
information necessary to support and to document the assisted property owner's
inability to pay the amount owed to the City and the reason(s) for such a request.
Consideration will be given to such issues as:
• The value of the property at the time of the request to release the mortgage
lien and its impact on the settlement of any primary mortgage debt that may
exist;
. Who will inherit the property (should the request to release the mortgage
lien be related to the death of an assisted property owner), including other
estate settlement issues; and
• Any insurance settlements.
8.2 Owner-Occupied Properties: The conditional part of this form of assistance
is that the property assisted with program funds must remain the assisted
property owner's principal place of residence for a five-year period following the
completion and acceptance date of the rehabilitation project in order to be fully
forgiven.
If the assisted property becomes other than the assisted property owner's
principal place of residence at any time during the five-year term (through sale,
transfer, rental, or vacating or abandonment of the property), repayment of the
principal amount, based on the Section 8.1 schedule, is immediately repayable to
the City.
The City may, at its option, release the mortgage lien (and subsequent conditions
of the assistance) against the assisted property when there are extenuating
circumstances that would warrant or justify the community's decision to do so,
regardless of the age of the forgivable loan.
8.3 Rental properties: The conditional part of this form of assistance is that the
property assisted with program funds must remain a residential rental property
for a minimum of the duration of the five-year period following the completion and
acceptance date of the rehabilitation project in order to be fully forgiven.
If the assisted property becomes other than a residential rental property at any
time during the five-year term through sale, transfer, vacating, abandonment or
rental to an ineligible tenant or combination of tenants of the property (see
Section 5.3 regarding the combination of tenants), repayment of the principal
amount, based on the Section 8.1 schedule, is immediately repayable to the City.
8.4 Unsecured Program Funds Assistance: The City's five-year receding
forgivable loan discussed in Section 8.1 above is a direct form of assistance
financially secured through a mortgage lien filed on / against the assisted
property.
The City may apply additional program funds toward individual rehabilitation
projects undertaken that will not be secured against the assisted property owner's
properties.
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The City may incur costs for the administration of its BBHHRP (general administrative
costs and direct, project specific administrative costs). BBHHRP funds may also be
used for costs incurred in the temporary relocation of the occupants of assisted target
housing, including their belongings, if interior rehabilitation that disturbs painted
surFaces, known or presumed to be lead-based paint, and/or interior lead hazard
reduction takes place.
9.0 Program Mechanics
9.1 Marketing the Program: The City will market its BBHHRP to potential
owner-occupied and rental property owner applicants and to contractors.
9.1a Marketing to Applicants: Marketing to potential applicants can be
accomplished in a variety of ways. The City will market its program in order to
provide sufficient information about its resiliency program and to generate
further interest from potential applicants. Marketing may be conducted using
any and all of the following methods:
• Newspapers of general circulation and other local publications;
� Radio and/or television (such as local cable television channels);
• Public informational meetings held in the community;
• Mailings;
• Postings at strategic locations accessible to the general public (e.g., City
website, the Post Office, City Hall or County Courthouse, grocery stores,
schools, churches, libraries, etc.); and by
■ Personal contact to potential applicants by community leaders, civic
groups, etc.
If marketing to potential applicants occurred prior to a funding commitment
from the IEDA and the City has on file the names and addresses of a number
of potential applicants, re-contacting such persons is appropriate to
regenerate their interest.
Marketing to potential applicants should convey basic requirements for
participation in the City's program (i.e., eligibility criteria, the form of
assistance available, information about how, where and when to apply for the
assistance as well as what information will be needed, and restrictions they
need to be aware ofl. Marketing efforts should also address the requirement
of making any target housing temporarily lead safe as well as the potential for
temporary relocation during such work.
The City's marketing efforts will not discriminate in any way and the City is
committed to Fair Housing and making this program accessible to all
populations. The City will track the demographics of all applicants and all
assisted households to assure a reasonably representative demographic of
the community is being served. Fair Housing brochures will be provided with
all applications.
15
Additional marketing efforts may be necessary at some point during the
administration of the City's program. One of the most effective means of
marketing the program during the course of its operation is to cover a
"success story" about a completed project that went well and produced a
finished product with a satisfied beneficiary. Information about a successful
project already completed can be disseminated using the same media
sources identified above. A success story marketing strategy would be used
only when the affected property owner has given their permission to the City
to do so.
9.1 b Marketing to Contractors: Marketing to contractors is essential to the
success of any resiliency or rehabilitation program. The City must conduct a
sufficient amount of marketing specifically to contractors to generate and to
secure their interest in participating in the City's resiliency program.
Where there is an adequate number of contractors participating in the City's
program, fair and open competition for projects is maximized and overall
costs are generally more reasonable because of the competition inherent with
a larger pool of participating contractors.
Marketing to contractors can be accomplished using the same media
resources used for marketing to potential applicants. In addition to using
those resources, the community might also:
• Contact local homebuilders associations, construction trades
organizations, unions, etc.;
• Contact the Chamber of Commerce;
• Contact the lowa Department of Public Health to obtain information on
contractors that have been trained in safe work practices;
■ Scan local telephone books (business directories, yellow pages, etc.);
• Contact the IEDA's recommended plan review rooms and clearinghouses;
• Obtain information on contractors based on the City's building permit
issuance data;
• Contact local construction materials and equipment suppliers;
• Contact local lenders active in construction financing.
With the City's efforts to solicit and attract contractors for participation in the
program, nondiscrimination, equal opportunity and fair housing issues cannot
be overlooked. The City will also make a good faith effort to solicit and attract
the interest of minority and female owned businesses that might participate in
the City's resiliency program. Invitations to bid on the community's projects
need to be sent to the eastern lowa clearinghouses and plan review rooms.
When marketing to contractors, the City will be aware of certain issues
specifically of interest or concern to contractors and tailor its marketing efforts
to address these issues to the extent practical. This may include, but not be
limited to:
• The contractor's ability to make a profit;
• The contractor's location and/or proximity to the City;
16
• Federal, state or local requirements and/or restrictions that will affect them
(e.g., licensing; training, including safe work practices as applicable;
insurance coverage; OSHA requirements; contract conditions; warranties;
etc.); and
• Their ability to be paid in a timely fashion.
From the City's contractor marketing efforts, a list of potential contractors can
be compiled and referenced as individual projects are undertaken. (Refer
also to Sections 9.12 through Section 9.22 for other issues impacting
participating contractors).
9.2 Applicant Selection Process: The City, through its marketing efforts to
attract potential applicants, will indicate how to access the program (i.e., forms
they need to fill out, where to get them, etc.), any time constraints for application
submission, and where completed forms need to be submitted and who will be
responsible for receiving them.
9.2a Ranking System: Program eligibility is determined on a first-come, first-
qualified basis. A household qualifies for assistance after a complete
application is processed and the applicant household is determined eligible
for program participation. Applications are considered "complete" when all
required supporting documentation is submitted. The City will maintain a
waiting list of households eligible for the program. The order of the waiting list
will be based on date and time the complete application was received.
9.2b Application Selection Criteria Formula: Applicants will be accepted on
a first-come, first-serve basis, however, housing units will be scheduled for
inspection and work-write up to assess the readiness of the unit to begin work
within the production schedule and with consideration of costs and funding
availability. The City will maintain a written summary of the order in which
applications are approved.
9.3 Applicant Eligibility Determination and Verification Process: As stated in
Section 5.1, owner-occupant applicants must be able to show proof of ownership,
reside in an eligible dwelling, and most importantly, they must be income eligible.
Rental property owners must show proof of ownership, be a City registered
landlord of the eligible property, and have a tenant mix that is primarily LMI
tenants.
Ownership, occupancy, and tenure will all be verified and documented by the
community through City, County and/or other public records. Such records
include, but are not limited to the City Assessor and City utility billings and rental
property registrations.
The income verification process is more detailed and entails a specific procedure
to be followed. Basic income eligibility is based on the applicant's annual ra oss
�ousehald incame with no adjustments or deductions subtracted. An applicant's
annual gross household income is "anticipated" for the future twelve-month
17
period based on current circumstances or known upcoming income changes, all
of which must be verifiable and documented in the City's program files.
For purposes of determining an applicant's annual gross household income,
there are certain income inclusions (e.g., income from certain assets) and there
are certain income exclusions (e.g., payments received for the care of foster
children) that are taken into account. (Refer to HUD's "Technical Guide for
Determining Income and Allowances for the HOME Program" for more detail.
Recipients should refer to MFH 2O14-15 for instructions on using a new
passbook rate for income verification, found at:
https:llpartal.hud.gav/hudportal/documents/huddoc?id=14-15h_sgn.pd fl
The City will allow applicants to self-certify (self-declare) their income to the
City. Applicants will be required to sign an affidavit certifying their annual
income based on all sources of income per HUD guidelines. The City will
required a copy of the most recent income tax return and copies of the two most
recent pay stubs for all adults residing in the property. The City will compare the
submitted documentation to determine consistency of documents and certified
income for eligibility and reserves the right to complete a third party verification
if deemed necessary for any reason.
The City will create and have available for use the necessary forms for verifying
and documenting an applicant's annual gross household income (including
verification forms for allowable income inclusions and exclusions), verification
forms for documenting property eligibility requirements, and verification forms for
documenting allowable deductions for determining adjusted gross household
income.
The most current HUD income limitations, by county and by household size,
must be used for determining and verifying income eligibility.
Additional documentation may also be obtained by the City to further substantiate
an owner-occupied unit applicant and tenants in a rental property's annual
(gross) household income (e.g., obtain a copy of the applicant's federal and/or
state income tax forms from the previous tax year).
Once an applicant's income has been verified, the verification is valid for twelve
months only. The income verification must be updated if more than twelve
months transpires from the initial verification and the actual commitment of the
City's program funds.
In addition to documenting that an applicant meets the ownership, occupancy,
tenure and income eligibility requirements, sufficient documentation must be
obtained to clearly indicate that the applicant's property also meets all applicable
property eligibility requirements as described in Section 4.2.
9.4 Duplication of Benefits: All applicants will complete a Duplication of
Benefits (DOB) form with the submission of their application for assistance. The
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DOB form will request information on any and all assistance that was provided to
the property owner(s) as a result of damage of the July 2011 flood event or other
assistance for mitigation work. Owners will provide copies of invoices for
purchases of services, equipment, personal items, temporary housing, and/or
any other item the assistance was utilized for as a result of the flood. Completed
DOB forms and any supporting documentation will be uploaded into the
iowagrants system and IEDA verification and determination of any DOB
payments. Any undocumented DOB payments will be deducted from the
BBHHRP assistance to be provided.
9.5 Initial Property Inspection: Following eligibility determination and
verification, the City's Intake Person will arrange with the property owner a date
and time in which the Housing Resiliency Inspector will conduct an initial
inspection of the property to be assisted.
The purpose of the initial inspection is to determine the scope of resiliency work
to be accomplished with that property (i.e., the hard costs of construction). The
initial inspection will be conducted in order to verify the presence and condition of
all components, systems and equipment of the property owner's dwelling and
property, and to identify any and all resiliency items that require repair and/or
improvements to make the dwelling resilient to water intrusion.
Typically, the initial inspection is the first opportunity to meet face-to-face with the
property owner(s). If the property to be assisted is target housing (pre-1978
construction), meeting with the property owner(s) at their property for the purpose
of conducting the initial inspection is an ideal time to discuss lead-based paint
issues likely to impact their own project. Prior to conducting the initial inspection,
the City's program administrator or Resiliency Inspector needs to convey the first
of several required lead-based paint related notices (if this has not transpired
prior to the initial inspection) to the property owner(s), and in addition, the
tenant(s) in rental properties.
The first notification requirement for target housing is to convey general
information to the property owner about the dangers of lead-based paint. The
community may use either the Environmental Protection Agency's (EPA's)
standard pamphlet entitled "Renovate Right: Important Lead Hazard Information
for Families, Child Care Providers, and Schools" or the lowa Department of
Public Health's (IDPH's) standard pamphlet entitled "Lead Poisoning - How to
Protect lowa's Families" for this purpose.
Project files must be documented indicating that the property owner(s) has
received this required notice. The City will use either the EPA Pamphlet -
"Acknowledgement of Receipt" form or the IDPH Pamphlet - "Acknowledgement
of Receipt" form for this purpose. Both acknowledgement of receipt forms require
the property owner's signature and date of their receipt.
Project files must be documented with a copy of the initial inspection report,
signed (or initialed) and dated by the Resiliency Inspector who perFormed the
initial inspection.
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9.6 Work Write-Up (Project Specifications): From the data and information
gathered by the Resiliency Inspector during the initial inspection, a work write-up
(or project specifications as they are often referred to) will be generated. The
work write-up is first used by the City in the formulation of a cost estimate. The
work write-up eventually becomes a part of the bid documents needed for the
procurement of a contractor(s).
All work write-ups will be written so that participating contractors that bid on the
City's projects will submit itemized bids (i.e., an individual line- item cost for each
individual line-item of the work write-up).
9.7 Cost Estimate: The City will prepare a written cost estimate of the hard costs
of resiliency work for each project following the initial inspection and formulation
of a work write-up. The City's cost estimate will also be depicted in itemized form.
The City's cost estimate will be identified as such, be signed (or initialed) by the
Resiliency Inspector who prepared it, and dated. The City's cost estimates must
be included in individual project files.
The City's written cost estimate is formulated to initially determine if that project is
financially feasible to undertake, and secondarily to ensure the cost
reasonableness of contractor's bids that will be received for that project. The
primary purpose for the City's written cost estimate is to establish the probable
cost of construction (i.e., the hard costs of construction) as well as determine the
basis for what needs to be accomplished to that dwelling (if target housing) from
a lead hazard reduction standpoint. Lead hazard reduction requirements are
based on the City's estimated cost of construction, including other potential
programs and sources of federal funding. ( Refer to Sections 3.19 - 3.30 for
more detail on lead hazard reduction requirements).
9.8 Historical (Section 106) Clearance: Assisted properties may be of historical
significance. Historic preservation requirements may have an impact on the
City's work write-up (the original work write-up and/or the final, revised work
write-up following any lead hazard reduction need determination if target
housing). Individual projects assisted under the City's Resiliency Grant Program
are covered under the Programmatic Agreement among the IEDA, SHPO (State
Historic Preservation Office) and ACHP (Advisory Council on Historic
Preservation) and must be submitted individually to IEDA for Section 106 review
and compliance.
9.9 Infeasible Structures: Depending on the extent of the resiliency work (the
hard costs of construction) necessary to make a dwelling resilient (and the
property as a whole into conformance with City's HUD Resiliency Grant
standards (including any lead remediation, code violations, etc. as applicable),)
the City may find a dwelling that is structurally and/or financially infeasible to
make resilient. The City will apply the following formula to all projects in order to
determine if that project is feasible for rehabilitation.
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If the City's estimated cost of the resiliency work (the hard cost of construction
(including resiliency work, lead remediation, code violation repairs, etc. as
applicable and required by HUD and resiliency program rules) is at, or greater
than, ninety percent (90%) of the Assessed Dwelling Value per the Dubuque
County Assessor's valuation at the time of application, the proposed project will
be considered infeasible to rehabilitate.
NOTE 1: The estimated cost of resiliency would include all sources of funds, not
just the City's BBHHRP funds.
Where a dwelling is determined infeasible for the resiliency program using the
above formula, the City reserves the right to withdraw its offer of financial
assistance toward that project and to its property owner.
9.10 Level of Benefit/ Financial Commitment: The level of benefit available to
eligible applicants can best be described as the City's preliminary projection of
BBHHRP funds to be applied toward a resiliency project (i.e., the hard costs of
construction portion of the overall project only, and not including the direct
administrative costs, lead hazard reduction costs, lead hazard reduction carrying
costs, or temporary relocation costs that may be applied toward the total project).
In effect, the City can make a tentative financial commitment to the applicant for
the resiliency work (the hard costs of construction) necessary to bring that
dwelling into conformance with the applicable resiliency standards. (See Section
4.3.) The actual costs of construction, and from what sources of funds
resiliency/rehabilitation costs will be covered, may need to be reevaluated
following the procurement of a contractor(s) when the actual construction cost of
the project is known. The City's focus at this point is only on the resiliency costs
(i.e., those that will be funded by the HUD Resiliency Grant and secured against
the assisted property owner's property).
9.11 Target Housing—Lead Hazard Reduction: All target housing properties
assisted with the community's BBHHRP funds must comply with HUD's Lead
Safe Housing Regulations. All lead based paint hazards must be identified and
subsequently addressed (reduced) in target housing assisted with the
community's BBHHRP funds. Lead hazard reduction activity will be conducted in
conjunction and/or in combination with the resiliency work determined from the
community's initial inspection and included in a final, revised work write-up prior
to the procurement of a contractor(s). All assisted target housing (i.e., the entire
dwelling and the property as a whole) with federally funded assistance
investments up to $24,999 must be made at least temporarily "lead safe" at the
conclusion of clearance testing and final visual assessment.
The determination of lead hazard reduction need is based on (and directly tied
to) the City's estimated cost of resiliency work for that project (the hard costs of
construction). This determination is first based on the amount of BBHHRP funds
(and/or other federal funds) to be used for construction, and secondly, based on
the actual approach the City takes to physically determine the lead hazard
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reduction need (i.e., paint testing and risk assessment or the presumption of
lead-based paint).
In the unlikely event that the program encounters a target housing project where
the estimated cost of construction is $5,000 or less in federal funds, painted
surfaces found to contain or are presumed to contain lead-based paint that will be
disturbed during construction must be repaired if deteriorated paint or lead-based
paint hazards are present. The work items specified in the City's final, revised
work write-up (resiliency and lead hazard reduction activity combined) for the
repair of such painted surfaces to be disturbed will include, or compensate for,
the lead hazard reduction activity needed.
The City may presume that assisted target housing in this estimated construction
cost range contains lead-based paint. Where lead-based paint is presumed to be
present, testing of painted surFaces is not required. Where lead-based paint is
presumed to be present, all painted surfaces disturbed during construction must
be repaired and the lead hazard reduction need determined accordingly by the
City's Resiliency Inspector/certified lead professional.
For target housing projects where the estimated cost of construction is between
$5,001 and $24,999 in program funds (and/or other federal funds), lead hazard
reduction need is determined by the testing of painted surfaces to be disturbed
by the rehabilitation activity and conducting a risk assessment of the entire
property. From the paint testing and risk assessment results, all painted surfaces
containing lead-based paint that will be disturbed during construction will be
identified and all lead-based paint hazards (including dust-lead hazards and soil-
lead hazards) will be identified.
Work items specified to reduce the lead-based paint hazards identified from the
required paint testing and the risk assessment will be considered as "interim
controls". The interim controls specified in the City's final, revised work write-up,
in addition to the resiliency work items, will include, or compensate for, the lead
hazard reduction activity (interim controls) needed.
The City may also presume that assisted target housing in this estimated
construction cost range contains lead-based paint. Where lead- based paint is
presumed to be present, testing of painted surFaces and conducting a risk
assessment is not required. Work items specified to reduce lead-based paint
hazards presumed to contain lead-based paint will be considered as "standard
treatments". The standard treatments specified in the final, revised work write-up,
in addition to the rehabilitation work items, will include, or compensate for, the
lead hazard reduction activity (standard treatments) needed.
The determination of all lead hazard reduction activity needed to make a project
lead safe following clearance testing results and final visual assessment that
meet IDPH standards is first based on the amount of program funds (and/or other
HUD funds) to be applied toward the hard cost of rehabilitation, and secondly,
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based on the approach the community takes for making this determination (i.e.,
paint testing and risk assessment or the presumption of lead-based paint).
Once all lead hazard reduction activity to be accomplished has been determined
by the City's certified lead professional, the City will compare these work items to
its original initial inspection and work write-up that defines the rehabilitation work
items to be accomplished. It is possible that one or more of the construction work
items specified will effectively reduce or eliminate an identified (known or
presumed) lead-based paint hazard(s). Where lead-based paint hazards will not
be addressed with the specified rehabilitation work items, additional lead hazard
reduction work items (i.e., interim controls or standard treatments) will need to be
added to the construction work items. A final, revised work write-up is then
generated that incorporates all rehabilitation work items and all lead hazard
reduction work items. This final, revised work write-up will then be used for the
procurement of a contractor(s) to do the work.
In properties where the total federal assistance will be $25,000 and above
invested in the hard costs of resiliency/rehabilitation work, abatement of the lead
hazards will be completed in accordance with the Federal Lead Safe
Housing regulations, unless the property qualifies for an exemption under
24CFR35.115. See Exhibit D for the under 24CFR35.115 listing of exemptions.
The City must retain all original work write-ups and cost estimates and include
them in the respective project files. Individual project cost estimates of the
construction work items specified in the original work write- ups are the basis for
determining what needs to be accomplished from a lead hazard reduction
standpoint for each project.
The determination of lead-based paint hazards, regardless of the estimated cost
of rehabilitation, can only be accomplished by certain lowa-certified lead
professionals. Paint testing and risk assessments can only be accomplished by
lead professionals certified in lowa as Lead Inspectors / Risk Assessors or
Elevated Blood Lead (EBL) Inspectors / Risk Assessors. The determination of
presuming that lead-based paint is present in target housing may be made by
lead professionals certified in lowa as Sampling Technicians or Lead Inspectors /
Risk Assessors or Elevated Blood Lead (EBL) Inspectors / Risk Assessors. The
required clearance testing and final visual assessment that follows completion of
projects where lead hazard reduction activity occurred (regardless of the
estimated hard cost of construction) may be conducted by any of the certified
lead professionals referenced above. The City will utilize only lowa-certified lead
professionals.
There are notification requirements associated with the identification of lead-
based paint hazards in target housing assisted with program funds (and/or other
HUD funds). Where the City conducts paint testing and risk assessments to
determine the lead hazard reduction need, the City must convey to the assisted
property owner the "Notification of Lead- Based Paint Inspection and Risk
Assessment" form. This notification must be conveyed to the assisted property
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owner no later than fifteen days after the testing results have been received by
the City (if applicable) and the evaluation (risk assessment) has been completed.
A Lead Based Paint and Risk Assessment report must be prepared in
accordance with the requirements found in the IDPH's 641-Chapter 70 IAC.
Where the City presumes that lead-based paint and/or lead-based paint hazards
exist in assisted target housing, the City must convey to the assisted property
owner (and tenants if applicable) the "Notification That Lead-Based Paint or
Lead-Based Paint Hazards are Presumed to be Present" form. This notification
must be conveyed to the assisted property owner no later than fifteen days after
the presumption determination was made. A Visual Risk Assessment report must
be prepared in accordance with the requirements found in the IDPH's 641-
Chapter 70 IAC.
Any construction work that disturbs painted surFaces (i.e., paint that is known or
presumed to be lead-based paint) and any other lead hazard reduction activity
not accomplished with the rehabilitation work items (excluding the allowable de
minimis areas) can onlv be accomplished by contractors who have been trained
in safe work practices.
In projects where lead abatement is required, all identified lead hazards will be
removed. The owners (and tenants if applicable) will be provided notices and
occupants relocated throughout the abatement process. The abatement work
may only be done by certified abatement contractors.
9.12 Contractor Requirements: In order to participate as a contractor in the
City's BBHHRP program, the following minimum requirements must be met. All
contractors must:
• Be registered with the State of lowa, Department of Labor;
• Meet any and all local or state licensing requirements;
• Be able to provide evidence (i.e., certificate of successful completion and
satisfactory test results) that all workers under his / her employ (i.e.,
employees and/or subcontractors and their employees) who will be involved
in any rehabilitation that disturbs painted surfaces (known or presumed to be
lead based paint) or any lead hazard reduction activity, have been trained in
safe work practices or abatement practices as required by HUD's Lead Safe
Housing regulations and the IDPH's 641-Chapter 70 IAC;
• Provide current and active insurance certificates that document sufficient
insurance coverage (insurance schedule will be detailed in project
specifications); and
■ Be approved by the IEDA as not being on the HUD's or the U.S. Department
of Labor's (DOL's) lists of debarred or suspended contractors.
9.13 Contractor Procurement: The procurement of contractors for individual
resiliency projects (including any lead hazard reduction activity), or various
components of resiliency projects, where projects are broken down into
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components, will be undertaken by the City. Contractors will be procured through
a competitive sealed bids procurement process.
Upon completion of the final work write-up and bid documents, the City will
advertise for bids in accord with State of lowa adopted procurement methods for
construction. Bids will be posted on the City of Dubuque's website. Invitations to
bid will also be sent to the eastern lowa plan review rooms and area
clearinghouses as well. In addition to publicly advertising, all known area
contractors (those contractors identified through the City's contractor marketing
efforts and that meet the requirements of Section 9.12 above) will be notified, in
writing, inviting them to bid on the City's projects as they are undertaken.
The City's publicly advertised bidding process will allow sufficient time for
contractors to compile and submit their bids. Bids will be opened publicly at a
specified date, time and place. The lowest responsive, responsible bidder will be
awarded the contract subject to bid verification and acceptability. A responsible
bidder is a contractor that has met the requirements of Section 9.12 above and
all other material terms and conditions of the bid documents. Contractor's bids
need to be typewritten or completed in ink. Contractor's bids submitted in pencil
will not be accepted.
Following the opening of all bids, the City will perform a verification of the bids
received (i.e., to ensure true itemized bids submittal, to verify and to recalculate
the contractor's figures, to consider any alternate bids sought after and received,
etc.). A bid tabulation (summary) sheet will then be prepared by the City
reflecting all bids received. All contractors submitting bids must also include a
non-collusion affidavit with their submissions.
The successful bidder(s) will be notified, in writing, of the community's intent to
award them a contract. All unsuccessful bidders will also be notified, in writing,
by the City.
9.14 Contract Execution: Following contractor(s) procurement, but prior to the
award of a construction contract(s), the City will reevaluate the amount of
assistance to be applied toward that project, secure all non-program funds and
finalize its financial commitment of BBHHRP funds to that property owner. The
City's loan documents (the five-year receding forgivable loan) will be prepared for
signing.
Following notification(s) of award to the successful contractor(s), arrangements
will be made with all parties to formally execute the resiliency construction
contract(s). Prior to contract(s) execution, the successful contractor(s) must
submit a complete list of the materials and equipment suppliers and a complete
list of subcontractors intended to be used. Concurrent with the signing of a
contract(s), the property owner will execute the promissory note and mortgage
lien and/or repayable loan documents discussed in Section 8.0.
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Following contract(s) execution, the City will issue a notice(s) to proceed to the
contractor(s), all contracts entered into. Where projects are accomplished with
several individual contracts in lieu of one general contract, the timing and
coordination of issuing notices to proceed will need to be considered and
handled accordingly.
Frequently, contract execution and loan documents signing, as well as obtaining
the contractor(s) lists of suppliers and subcontractors and the actual issuance of
the notice(s) to proceed, will actually take place during the scheduled pre-
construction conference required to be held.
9.15 Pre-Construction Conference: Prior to the start of construction, the City
will hold a pre-construction conference with the property owner and the
contractor(s) awarded the contract(s). At the pre-construction conference, the
final work write-up(s) (project specifications) will be reviewed by all parties, line
item by line item, to ensure a thorough understanding of the work to be
accomplished. Additional topics to be discussed at the pre-construction contract
include, but are not limited to:
• Timing and coordination of the sequence of the work (especially when and
where lead hazard reduction activity or resiliency work that disturbs painted
surFaces, known or presumed to be lead based paint, or abatement projects
in which all lead hazards will be removed, are to be accomplished, and/or if
the project entails multiple contracts covering various components of the
entire project);
• Temporary relocation, limited access to living areas, and coordination of
household schedule with lead-based paint work activity issues, as applicable
(i.e., conveyance of the details of the City's temporary relocation offering and
options, responsibilities, timing and coordination, packing and moving,
storage, secured property owner non-access to work area(s) during interior
lead hazard reduction work, specialized cleaning, clearance testing and final
visual assessment, and the community's authorization of re-occupancy
following completion and successful clearance testing); and
• Safe work or abatement practices, and OSHA requirements, as applicable.
Additionally, the responsibilities of all parties to the contract(s) need to be
thoroughly discussed. The various processes and procedures involved in
completing the project also needs to be covered (e.g., change order procedures,
contractor payment processes, various lead hazard reduction requirements,
grievance /dispute resolution procedures, etc.).
The required pre-construction conference, where all parties to the contract(s) are
together, provides the contractor(s) an opportunity to issue the required lowa
Department of Public Health's Pre-Renovation Notification (all target housing) if
this has not transpired before this meeting. The City should ensure that this takes
place and obtain a copy of the executed pre-renovation notification form for its
project files.
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9.16 Target Housing—Occupancy
Scheduling the Lead-Based Paint Work: The City will first coordinate with its
contractors and property owners, the timing and sequence of all non-lead-based
paint related interior and exterior resiliency/rehabilitation work (i.e., those items
that do not disturb painted surfaces; those items disturbing painted surfaces that
are documented as not being lead-based paint; or those items that fall within the
allowable de minimis areas), and any exterior lead-based paint related resiliency/
rehabilitation work and/or exterior lead hazard reduction activity, so that all of this
work combined is accomplished ri� vr ta the start of any interior lead-based paint
related resiliency/rehabilitation work (i.e., interior work that disturbs painted
surfaces, known or presumed to be lead-based paint, and/or any interior lead
hazard reduction activity).
Worksite Restricted Entry and Security: No Occupants at Worksite: Occupants
shall not be permitted to enter the worksite during lead hazard reduction activities
until after hazard reduction work has be�� cam�letec! and clearance has been
achieved.
Protection of Occupants' Belongings: The dwelling and worksite shall be secured
against unauthorized entry and occupants' belongings shall be protected from
contamination during hazard reduction activities by relocating or covering and
sealing all belongings.
Occupant Protection Measures: All households will be provided the option of
temporary relocation. Households with children under six years of age and/or a
pregnant woman (if known) must be temporarily relocated as described below in
the Temporary Relocation section.
Households that will not have safe access to sleeping areas, bathroom, and
kitchen facilities outside the sealed work area must be temporarily relocated as
described below in the Temporary Relocation section.
Households that live in houses that will require more than five calendar days to
complete the lead hazard reduction activity for the interior of the house must be
temporarily relocated as described below in the Temporary Relocation section.
Households that are not required to temporarily relocate and do not choose
temporary relocation will be required to vacate the house during the work hours
and have no access to the worksite when in the house after work hours except
for households where all occupants of the house are at least 62 years old. The
requirements that apply to projects where the households do not temporarily
relocate (except for households where all occupants are at least 62 years old)
are described in Section 9.17 "Eight Daytime Hours or Five Calendar Days".
Households that that do not include any person under 62 years old and that have
received complete disclosure of the nature of the work are not required to leave
the house if there will be safe access to sleeping areas, bathroom, and kitchen
27
facilities outside the sealed work area (worksite) and if each occupant of the
house signs an "Elderly Waiver for Relocation". A sample "Elderly Waiver for
Relocation" is included as Exhibit E.
9.17 Eight Daytime Hours or Five Calendar Days: Eight Daytime Hours:
Treatment of the interior will be completed within one period of 8-daytime hours,
the worksite is contained so as to prevent the release of leaded dust and debris
into other areas, and treatment does not create other safety, health or
environmental hazards (e.g., exposed live electrical wiring, release of toxic
fumes, or on-site disposal of hazardous waste).
- or -
Five Calendar Days: Treatment of the interior will be completed within 5
calendar days, the worksite is contained so as to prevent the release of leaded
dust and debris into other areas, treatment does not create other safety, health or
environmental hazards; and, at the end of work on each day, the worksite and
the area within at least 10 feet (3 meters) of the containment area is cleaned to
remove any visible dust or debris, and occupants have safe access to sleeping
areas, and bathroom and kitchen facilities.
Prior to the start of the lead hazard reduction work the worksite shall be sealed to
prevent the release of leaded dust, and to contain lead-based paint chips and
other debris from hazard reduction activities within the worksite until they can be
safely removed. A warning sign shall be posted at each entry to a room where
hazard reduction activities are conducted.
For either Eight Daytime Hours or for Five Calendar Days, the work area will be
sealed and no occupant will enter the work area until all such work has been
completed AND successful clearance testing and final visual assessment results
meeting IDPH standards has been achieved.
9.18 Temporary Relocation: Temporary relocation is required for the following
households during interior work in target housing that disturbs areas that have or
are presumed to have lead-based paint:
• All households with children under six and/or a pregnant woman (if known)
■ For projects where there will not be safe access to sleeping areas, bathroom,
and kitchen facilities during the lead hazard reduction work
• For projects that will require more than five days to complete the lead hazard
reduction work
• Any household that requests temporary relocation
The relocated households and their personal belongings will be fully protected
during any resiliency/rehabilitation work that disturbs painted surFaces (known or
presumed to contain lead-based paint) and during any lead hazard reduction
activity. Any personal belongings not temporarily relocated (e.g., large pieces of
furniture, etc.) will be protected (e.g., covered and sealed) so that they will not
become contaminated with lead-contaminated dust or construction debris during
such interior work.
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The household will be relocated to a suitable, safe /decent / sanitary living
arrangement that is free of any lead-based paint hazards (post-1978 unit or
clearance examination). Temporary relocation will continue to be provided until
the interior lead-based paint related work has been completed, the work area(s)
thoroughly cleaned (using HUD recommended specialized cleaning methods)
and clearance testing and final visual assessment (interior or exterior) has been
conducted with results achieved that meet IDPH standards. The City will not
authorize entry or re-occupancy of the assisted property by the relocated
household until all such work has been completed and successful clearance
testing and final visual assessment results meeting IDPH standards has been
achieved.
Some, if not all, of the relocated household's belongings must also be temporarily
relocated (or adequately protected), prior to the start of such interior work. The
occupant's belongings will be relocated to a safe and secure location (e.g. - a
lockable storage facility) accessible only to their owners. Any personal
belongings not temporarily relocated (such as large pieces of furniture) must be
covered and sealed to prevent possible contamination from lead-contaminated
dust or construction debris during interior lead-based paint related rehabilitation
and/or lead hazard reduction activity.
9.19 Construction Supervision: Throughout the term of construction and/or
lead hazard reduction activity, all individual resiliency projects, the City will
oversee the work of the contractor(s) and any subcontractors doing the work.
Construction supervision will be accomplished primarily through periodic and
frequent work-in-progress inspections by the City's Resiliency Inspector.
Inspections relating to contractor payment requests, any City required (e.g.,
building or housing code required) inspections, and any inspections relating to
change order requests will all occur as necessary.
Periodic inspections / construction supervision may also be necessary during
rehabilitation that disturbs painted surfaces, known or presumed to contain lead-
based paint, and/or during lead hazard reduction activity as well as during
cleaning done for the purpose of clearance testing and final visual assessment.
The primary purposes of these inspections are to ensure that contractors are
following required safe work practices and applicable OSHA requirements. The
City's Resiliency Inspector should wear appropriate protective clothing and
equipment during such inspections. All inspections must be documented in
individual project files.
The main purpose of construction supervision is to ensure that all work specified
in individual project work write-ups is completed, completed in a satisfactory
workmanship-like manner, and completed in a timely manner.
9.20 Change Orders: During the course of construction, the City may find it
necessary to change the work write-up on any given project. Changes occur with
any addition to or with any deletion of items to be accomplished, or with any
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other change that may occur to the original, as-bid, work write-up that alters the
scope of work in any way. Change orders are needed for any and all
substitutions that are made to the project as well, even if the dollar value of that
work item remains unaffected. Change orders are also needed for time
extensions to a resiliency construction contract.
Any and all changes to the contract work write-up require a fully executed
change order signed by all parties to the contract. Change orders need to be
contained in individual project files.
Change orders are an extension of the original project specifications (work write-
up). Change orders need to detail all changes, be clear, concise and accurate,
and be prepared individually listing all items if more than one item is included in
the change order. The contractor's costs associated with all items listed within
change orders must also be itemized.
9.21 Contractor Payment Procedures: All payments to contractors are to be
based on work completed at the time of the payment request. With all payment
requests received by the City, the City's Resiliency Inspector will make an
inspection to verify that work (work for which payment is sought) has been
completed. No payment requests will be honored prior to the City conducting an
inspection.
All materials, supplies and equipment purchased by the contractor(s) (including
subcontractors) for a particular resiliency project must be satisfactorily installed
prior to the City making payment for those items on that project. Payment
requests for materials, supplies and equipment stockpiled on a job site and not
yet installed will not be honored until the contractor (or subcontractor) has
satisfactorily installed them.
Contractors may be paid lump sum at the completion of projects, or may seek
partial payments throughout construction with a final payment request at the
completion of the project. The City will withhold a minimum of ten percent (10%)
from all partial payment requests received from contractors. This ten percent
(10%) withholding may be reduced to a lesser amount if the City requires
participating contractors to be bonded. All withholding from partial payment
requests will be paid to the contractor with the final payment request, but not
prior to the acceptable lead dust sample clearance results are obtained, if
applicable.
In addition to a required inspection prior to making payment to contractors, the
City must receive fully executed lien waivers from contractors for all materials
and supplies, equipment, and labor costs for which payment is being sought.
Where partial payment requests are made by contractors, fully executed partial
lien waivers are also necessary prior to the City honoring the contractor's partial
payment request.
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Specifically, all fully executed lien waivers applicable to the first partial payment
request must be received by the City before payment will be made on the
contractor's second partial payment request. Subsequent partial payment
requests will follow this procedure, whereby lien waivers for the previous partial
payment request are required ri� ar to the City honoring subsequent partial
payment requests. For final payment, fully executed lien waivers are required
prior to the City honoring the final payment, including the payment of funds
previously withheld (retainage) from partial payments.
All lien waivers received from contractors (partial and final lien waivers) need to
be reviewed and checked against the "Project Subcontractors / Suppliers" list
that submitted by the contractor prior to the start of construction.
Any target housing assisted with the City's program funds (and/or other HUD
funds) that involves construction that disturbs painted surFaces, known or
presumed to be lead based paint, lead hazard reduction activity and/or
abatement projects will require thorough, specialized cleaning and clearance
testing and final visual assessment following the completion of such work. Final
payment(s) to the contractor(s) will not occur prior to successful clearance testing
and final visual risk assessment results meeting IDPH standards.
The property owner's concurrence and acceptance of all work for which payment
is being sought must be obtained prior to the City making any partial or final
payments to contractors. Refer to Section 9.22 below regarding property owner
concurrence and acceptance of final payment.
9.22 Project Completion /Acceptance: Upon completion of the project (all
work except the interior rehabilitation that will disturb painted surFaces, known or
presumed to contain lead based paint, and/or interior lead hazard reduction
activity accomplished in target housing), the City will conduct a final inspection of
the construction work accomplished on that project (including exterior lead
hazard reduction activity work if applicable). The final inspection will be
conducted by the Resiliency Coordinator and Resiliency Inspector in the
presence of the property owner. It is desired that the contractor(s) and a
representative of the City's Housing Resiliency Committee (or his/her designee)
attend the final inspection to make note of and clarify any unfinished and/or
questioned work. If the Resiliency Inspector and Resiliency Coordinator
determine the project is complete and acceptable and owner (or tenant) disagree
with the determination, the owner (or tenant) may file a grievance with the
Resiliency Coordinator per Section 11 of this Administration Plan.
The final inspection is made to ensure that all work was completed and was
accomplished in accordance with the work write-up and any change orders that
were issued, and to ensure that work was accomplished in a satisfactory manner.
Should any construction work items remain unfinished or in need of rework, a
punch-list will be formulated by the City (or its representative) and presented
to the contractor(s) for finalization prior to final acceptance and final payment
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authorization. If work or rework remains, a time frame for completion of such
items will also be specified in the punch-list.
For assisted target housing projects involving any interior lead hazard reduction
activity, the final inspection is conducted for all resiliency/ rehabilitation work
items and/or exterior lead hazard reduction items except the interior rehabilitation
work that will disturb painted surfaces (known or presumed to be lead based
paint) and/or interior lead hazard reduction activity to be accomplished. In effect,
this is an intermediate final inspection. Therefore, all other (non-interior lead-
based paint related) work needs to be completed, inspected and accepted prior
to the contractor(s) commencing with the interior rehabilitation that will disturb
painted surfaces (known or presumed to be lead based paint) and/or interior lead
hazard reduction activity.
Temporary relocation will not occur until all other (non-interior lead-based paint
related) work has been completed, inspected and accepted. Once the
intermediate final inspection has occurred and the occupants and their
belongings relocated the interior rehabilitation that disturbs known or presumed
lead-based paint and/or lead hazard reduction activity can commence.
As an alternative, reverse work seqtaencinq will be allowed if it better fits the work
schedule of the contractor and/or the occupant. If reverse work sequencing is
implemented, all interior construction work that daes not disturb painted surfaces
and/or does not involve interior lead hazard reduction activity needs to be
completed and accepted initially. Temporary relocation will then occur, at which
time the interior construction that disturbs known or presumed lead-based paint
and/or interior lead hazard reduction activity can then commence. Upon
completion of this work, clearance testing — including a final visual risk
assessment—will be conducted on the interior of the dwelling. In effect, this is a
partial final visual risk assessment (interior of the dwelling only). After successful
clearance testing, the City will authorize re-occupancy of the assisted property.
Subsequent to re-occupancy, all exterior construction work items and all exterior
lead hazard reduction items will then commence. Upon completion of this work
the City will conduct a final inspection of all resiliency work and lead hazard
reduction activity accomplished on the project. At or prior to the final inspection
clearance testing and a visual risk assessment will be completed, if applicable, on
all of the exterior work accomplished.
Upon completion of the interior lead-based paint related work, specialized
cleaning procedures of the affected interior work areas must occur (in
accordance with HUD guidelines) and prior to the City conducting the required
clearance testing and final visual assessment.
Clearance testing and a final visual assessment must follow the completion of all
lead-based paint related work. Clearance testing must be accomplished in
accordance with the lowa Department of Public Health's requirements found at
641-Chapter 70 of the lowa Administrative Code. Clearance testing results must
meet the applicable IDPH standards. If clearance testing fails to meet the
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applicable IDPH standards, the affected work areas must be re-cleaned by the
contractor(s) responsible for this and clearance testing must be re-conducted.
This process continues until the project meets IDPH clearance testing standards,
including the final visual assessment.
Program funds are to be used o�for the initial cost of cleaning for clearance
testing. If clearance testing fails to meet the applicable IDPH standards, any and
all costs associated with subsequent re-cleaning needs to be borne by the
contractor(s) responsible for this. It is extremely important for contractors to
follow safe work practices and to thoroughly clean affected work surfaces with
the initial cleaning so that successful clearance testing results and successful
final visual assessment results are achieved with the initial clearance testing and
final visual assessment.
The City will use the "Notification of Lead Based Paint Hazard Reduction
Completion and Final Visual Risk Assessment and Clearance Testing Results"
form to document its clearance testing results as well as to notify the property
owner as required. This form serves as the required notification as well as the
IDPH (641-Chapter 70 IAC) required report.
The clearance test and final visual assessment will serve as the "final" final
inspection for assisted target housing that includes any interior lead-based paint
related work. Assisted target housing involving any interior rehabilitation that
disturbs painted surFaces (known or presumed to be lead-based paint) and/or
any interior lead hazard reduction activity will effectively entail two final
inspections.
When all work is determined to have been satisfactorily completed, the City will
execute a Final Completion and Acceptance form with the signatures of all
parties to the contract(s).
Following the execution of the Final Completion and Acceptance form, the City
can record the forgivable loan agreement and issue the final payment and the
payment of all withholding (retainage) from previous partial payment requests
paid, once all lien waivers have been executed by the contractor and are in the
City's possession. Prior to making final payment and the payment of withheld
funds to the contractor, all manufacturer's and supplier's warranties must have
been conveyed to the property owner by the contractor. An "Anti-Kickback
Statement" should also be executed prior to the City making final payment to the
contractor.
10.0 Program Administration
10.1 Responsibilities of Parties: The responsibilities of the parties coordinating
and working on the HUD Resiliency Grant Program are detailed as follows.
10.1a City: The overall authority for the implementation and administration of
the City's HUD Resiliency Grant Program is with the City itself. This ultimate
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responsibility rests with the chief elected officials of the City (i.e., the mayor
and city council). The day-to-day implementation and administration of the
program has been assigned to the Dubuque Housing and Community
Development Director. The Director will assign and direct staff and vendors in
the implementation and administration of the program. The Director or
Resiliency Coordinator will sign resiliency construction contracts upon
approval of the Housing Resiliency Committee.
The primary responsibility of the City is to ensure that the program is carried
out in accordance with its contract with the lowa Economic Development
Authority (IEDA), and to ensure compliance with all applicable state and
federal requirements governing the program funds associated with the City's
HUD Resiliency Grant Program.
10.1b Housing Resiliency Committee: The City will establish a separate
oversight committee. This Housing Resiliency Committee will be appointed by
the Dubuque Housing and Community Development Director and be charged
with certain programmatic responsibilities. The Committee will consist of a
minimum of three members. East Central Intergovernmental Association
(ECIA) representatives will attend meetings and provide documents for
Committee review and approval.
Responsibilities of the Rehabilitation Committee include, but are not limited
to:
■ Approval authorization of all applications for assistance;
• Individual resiliency construction contracts approval authorization;
= Grievance and dispute resolution responsibilities;
• Long-term monitoring responsibilities to ensure that assisted properties
remain the principal places of residence to the assisted property owners or
in rental projects that the assisted properties remain rental properties with
the minimum required LMI tenant ratios for the prescribed period tied to
the City's financial assistance (i.e., the five-year receding forgivable loan);
• Oversight of any recaptured funds received from any five-year receding
forgivable loans that go into default.
10.1c Resiliency Coordinator: The City will designate certain staff for the
day-to-day programmatic administrative responsibilities. This may be City
staff or designated staff of a third party entity under contract with the City.
Those responsible for the day-to-day programmatic administration may be
one or more persons.
The primary responsibilities of the Resiliency Coordinator (or his/her
designee) include, but are not limited to:
• Program oversight to assure targets are being met;
• Provide status updates to the Resiliency Committee;
• Oversight and monitoring of program staff and vendors to assure
progress is maintained at the level required to achieve targets;
• Perform periodic quality control field inspections;
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• Collaborate with Resiliency Inspector on inspections and work
specifications;
■ Be the City Representative during final inspection;
+ Review leveraged funded project costs;
■ Be a liaison to property owners and tenants to advise them on Resiliency
requirements of the BBHHRP and, life-safety issues, etc.;
• Securing of temporary relocation facilities.
10.1d Resiliency Inspector: The City will utilize City staff or contract for it
Resiliency Inspector work. The City will issue an RFP to solicit proposals for
the work required of the inspector position. The City will determine the most
advantageous means to fill the Inspector position and contract with an
outside party for the work or hire staff. The East Central Intergovernmental
Association (ECIA) was selected following the RFP process to provide the
Resiliency Inspector services.
The primary responsibilities of the Resiliency Inspector include, but are not
limited to:
• Marketing of the program to applicants and contractors (during
inspections, pre-construction meetings, etc.);
• Initial housing inspections;
* Work write-ups;
• Cost estimates;
• Historical clearances;
■ Feasibility determinations;
• Level of benefit and determination of amount of assistance;
• The determination of lead hazard reduction need for all assisted target
housing (recall that this can only be accomplished by lowa-certified
Sampling Technicians, Lead Inspectors / Risk Assessors, or Elevated
Blood Lead (EBL) Inspectors / Risk Assessors);
• Revisions and finalization of individual project work write-ups, as
applicable;
• Contractor procurement;
■ Contracting;
• Coordination of Temporary relocation and verifying the relocation during
construction (as applicable);
• Construction supervision (inspections, change orders, contractor
payments, lead hazard reduction oversight, etc.);
■ Project completion, final inspection(s), clearance testing and final visual
assessment (as applicable) and final acceptance;
• Grievance and dispute resolution responsibilities; and
■ Progress reporting to the Intake/Reporting Person, Housing Resiliency
Committee, the City and the IEDA, as applicable.
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10.1e Home Advocate: The City will utilize City staff or contract for Home
Advocate work. The City will issue an RFP to solicit proposals for the work
required of the Home Advocate position. The City will determine the most
advantageous means to fill the Home Advocate position and contract with an
outside party for the work or hire staff. The Dubuque Visiting Nurse
Association (VNA) was selected following the RFP process to provide the
Home Advocate services.
The Home Advocate will meet with property owners and tenants to assure
success of the resiliency work and offer additional assistance and service
referrals to increase individual and social resiliency in the Bee Branch
Watershed. The primary responsibilities of the Home Advocate include, but
are not limited to:
• Meeting with property owners and tenants to assure they have a clear
understanding of the resiliency construction work being completed;
• Informing property owners of additional potential funding sources for other
work that may be needed on their properties;
• Informing property owners and tenants of programs, services, and
opportunities to assist them in becoming more resilient citizens in the
event of future disaster events, whether they be natural or human-made,
neighborhood or individual;
• Providing property owners and tenants with brochures on Fair Housing,
Equal Opportunity requirements, accessibility matters, and local rental
codes and requirements;
■ Follow-up during and after construction to assure property owners and
tenants are satisfied and approving of resiliency work completed and
determine any additional needs for work on property and/or individual or
household assistance.
10.1f Grant Administrator: The Grant Administrator is a City employee who
will establish the separate accounting for the BBHHRP grant program. The
Grant Administrator will maintain all City records on the Resiliency contract to
assure compliance with CDBG regulations. The primary responsibilities of the
Grant Administrator include, but are not limited to:
• Set up accounting codes for the processing of all invoices and payments
associated with the BBHHRP contract;
• Receive and enter invoices into the designated account based on the work
performed to maintain documentation of Resiliency funds, leveraged
funds, and matching funds;
• Submit invoices to the Finance Department for payment;
• Maintain records of payments to vendors;
• Track force account labor (City staf� timesheet records and costs for grant
reimbursements.
• Prepare the CDBG draws and forward to ECIA Intake Person for
uploading into the iowagrants system.
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10.1g: East Central Intergovernmental Association (ECIA): ECIA is
working with the City and will function in the role of CDBG Grant Administrator
for the CDBG NDR contract. ECIA is assisting the City with the following
roles including, but not limited to: development of the Administrative Plan,
application and verification forms, completion of the general Environmental
Reviews and individual housing environmental clearances, review of CDBG
draws for program compliance, provision of general assistance and potential
relocation assistance services and/or Davis-Bacon compliance. ECIA will
provide the Intake Person with the duties listed below.
10.1 h Intake Person: The Intake Person will provide the initial contact with
program applicants. This person will receive applications and conduct the
verification process. The primary responsibilities of the Intake Person include,
but are not limited to:
• Marketing of the program to applicants (answering questions prior to and
during the application review process;
• Application intake and processing;
• Property eligibility verification within the identified Bee Branch Creek
eligible areas;
• Verification of applicant information received documenting their eligibility
to participate — income, DOB, etc.;
. Informing applicants of eligibility and inspection scheduling with property
owners and Resiliency Inspector and Home Advocate;
• Submission of applicant demographic data in the iowagrants system;
• Submission of CDBG Resiliency Program draw requests;
• Submission/entering of reports to IEDA on project status
11.0 Grievance and Dispute Resolution
In the event of a grievance or dispute, the following steps, in order, will be taken
to resolve the matter.
Step 1: Any grievances or disputes arising between a property owner and the
contractor(s) will initially be mediated by the City's Resiliency Inspector. It is the
grieving (or disputing) party's obligation to contact the City's Resiliency Inspector
with a detailed account of the issue(s) comprising the grievance or dispute. The
Resiliency Inspector will make a determination of resolution on the issue(s)
brought to their attention and convey to both the property owner and the
contractor a course of action to be taken, in what time frame, and by whom.
Step 2: Should either party contest the City's Resiliency Inspector's initial
decision, a request for an appeal hearing by the City's Housing Resiliency
Committee may be made via the Resiliency Coordinator. This request must be
made in writing. The Housing Resiliency Committee will set a date, time, and
place for this appeal hearing and notify the parties of same. The Housing
Resiliency Committee will make their determination at, or shortly after, their
meeting and convey their determination of resolution to the issue(s) raised, in
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writing, to both parties. The Rehabilitation Committee's determination will convey
to both parties a course of action to be taken, in what time frame, and by whom.
The decision of the Housing Resiliency Committee will be final and binding on all
parties.
Step 3: In the event that the grievance or dispute remains unresolved to the
satisfaction of either party, the right to file legal action remains the last and only
recourse available to the grieving or disputing party.
Should a grievance or dispute arise between either the property owner or
contractor and the Resiliency Inspector, the procedure to follow is the same as
described above, except that Step 1 would be omitted.
Written grievances or disputes that are received by the IEDA directly (or
indirectly) from a property owner, the contractor or a representative of the
property owner or contractor will be forwarded to the City for resolution.
Resolution is to follow the above described process.
12.0 Temporary Relocation Policy
The City's Temporary Relocation Policy and Temporary Relocation Contracts are
attached as Exhibit A.
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EXHIBIT A: CITY OF DUBUQUE RESILIENCY PROGRAM
TEMPORARY RELOCATION POLICY
The following relocation policies shall be followed:
1) Relocation shall be required under the following circumstances:
a. When the residence is undergoing work that disturbs areas that have or are
presumed to have lead-based paint.
b. When safe access to, and use of, sleeping areas, bathrooms and kitchen facilities is
not available for period of at least eight (8) consecutive hours.
c. When occupancy of the residence is not reasonable due to the presence of lead
hazards, excessive noise, excessive airborne particles, electrical hazards, lack of
heat, lack of running water, plumbing issues, lack of ingress/egress or any other
reasons as verified by the Program Administrators and/or Resiliency Inspector.
d. NOTE: Households participating in the program in which all occupants are sixty-two
(62) years of age or older are NOT required to leave the home if there will be safe
access to sleeping areas, bathroom and kitchen facilities and if each occupant of
the home signs an Elderly Waiver of Relocation form.
2) Contractors will be required to provide a minimum of five (5) working days notice prior
to relocation being required.
3) Contractors shall notify residents within not more than one (1) working day of when the
home has been certified for re-occupancy by the program administrative entity and
Resiliency Technician.
4) All relocation units will be selected by the program administrator in consultation with
the displaced persons and/or Landlord/Property Manager (on rental properties) will be
suitable, safe, decent and similarly accessible and must be constructed after January
1, 1978 or lead safe. All units will be inspected by the Program Administrators and/or
Resiliency Inspector prior to being approved for relocation. Units should be in as close
a proximity to the permanent residence as feasible.
5) Tenants/homeowners will have several options to achieve temporary relocation into a
lead-safe and accessible unit. The following lists the preferred method in order for
temporary relocation: 1) relocate with family or friends; 2) relocate to furnished units
leased by the City and utilized by the program when available; and 3) relocate to a
participating lead-safe hotel with the stay covered by the program.
6) It is anticipated that temporary relocation will typically be for duration of five (5) to ten
(10) working days. A provision will be placed in all resiliency contracts deducting
temporary relocation costs from payments due the contractor beginning immediately
after the fifteenth (15t") working day of relocation.
6) The City will, through the HUD Resiliency Grant Program, cover the following relocation
related expenses:
a. Cost of lodging, (rent, lease, hotel/motel).
b. Cost of storage of essential household goods as needed.
c. Per diem cost of food if no cooking facilities are available on site.
d. Cost of utilities, (if applicable).
e. Cost of moving, (if applicant is incapable of moving without assistance).
f. Aggregate relocation costs shall be capped at 200/household if City of Dubuque
owned properties are utilized. Aggregate relocation costs shall be capped at
1 500/household if City of Dubuque owned properties are not available.
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g. Payments will be based upon actual costs incurred within not later than 40 days of
the City of Dubuque Housing & Community Development's receipt of proper
expense documentation
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