Amendment to Lead & Healthy Homes Work Plan Copyrighted
November4, 2019
City of Dubuque Action Items # 5.
ITEM TITLE: Amendmentto Lead & Healthy Homes Work Plan
SUMMARY: City Manager recommending approval to amend the Lead
& Healthy Homes Work 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 the amendment
be submitted to the U.S. Department of Housing and Urban
Development (HUD)for adoption and approval of the
changes.
SUGGESTED DISPOSITION: Suggested Disposition: Receiveand File;Approve
ATTACHMENTS:
Description Type
Amendmentto Lead & Healthy Homes Work Plan- Staff Memo
MVM Memo
Staff Memo Staff Memo
Lead & Healthy Homes Work Plan DraftforApproval Supporting Documentation
Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Amendment to Lead & Healthy Homes Work Plan
DATE: October 31, 2019
Housing & Community Development Director Alexis Steger recommends City Council
approval to amend the Lead & Healthy Homes Work 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 the amendment be submitted to the
U.S. Department of Housing and Urban Development (HUD) 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. After
the meeting, Jerry Maro, President of Dubuque Area Landlord Association, reported that
the board will support the wording of Alexis Steger's memo, with no changes.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
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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
Dubuque
THE CITY OF �
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TO: Michael C. Van Milligen, City Manager
FROM: Alexis M. Steger, Housing & Community Development Director
DATE: October 31, 2019
RE: Amendment to Lead & Healthy Homes Work Plan
Information
This memo is a request to amend the Lead & Healthy Homes Work 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 Lead & Healthy Homes
program is helping create lead safe 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, a work plan amendment is being proposed for the program so that the work
plan would state:
"Property owners participating in the grant program shall be required,
for the term of the forgivable loan, for any funded unit, to give
preference to low to moderate income families, being defined as below
80°k Area Median Income, and accept Housing Choice Vouchers (HCV)
provided by the Section 8 program funded by the U.S. Department of
Housing & Urban Development, if the prospective tenant is otherwise
qualified. Property owners shall provide certifications of the above
preference at specified intervals provided by the City. Failure to comply
will result in remaining balance of forgivable loan becoming due and
payable on the date of notification of non-compliance."
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.
2
The City of Dubuque reviews work plan changes to any program 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 Lead & Healthy
Homes Work 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 U.S. Department of Housing and
Urban Development (HUD) 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 Lead & Healthy
Homes Plan and direct staff to submit the draft to HUD for adoption and approval of the
changes.
3
City of Dubuque Lead Hazard Control Proqram Workplan
Organization Description:
Situated at the intersection of lowa, Illinois, and Wisconsin, the community of Dubuque, lowa,
stands among the Mississippi River bluffs as a metropolitan service area for seven surrounding
counties. The City of Dubuque is the local governing body for the city. Comprised of a Mayor
and City Council that creates and approves policy for its nearly 58,000 citizens. Dubuque's City
limits encompasses roughly 32 square miles.
City of Dubuque Goals 2024:
o Robust Local Economy: Diverse Businesses and Jobs with Economic Prosperity
o Vibrant Community: Healthy and Safe
o Livable Neighborhoods and Housing: Great Place to Live
o Financially Responsible, High-Performance City Organization: Sustainable, Equitable, and
Effective Service Delivery
o Sustainable Environment: Preserving and Enhancing Natural Resources
o Partnership for a Better Dubuque: Building Our Community that is Viable, Livable, and Equitable
o Diverse Arts, Culture, Parks, and Recreation Experiences and Activities
o Connected Community: Equitable Transportation, Technology Infrastructure, and Mobility
Program Description:
The Lead Hazard Control Program resides within the Housing & Community Development
Department, under the H& CD Director Alexis Steger. The program mission is to reduce lead
hazards in low to moderate income housing units throughout the City and educate residents on
lead hazard exposure. To date approximately 1280 housing units have been made lead safe
since 1997.
The target population for the program is low to moderate income eligible families within the city
limits that have children under the age of 6 or pregnant women residing in the units. These sub-
groups within the city have long been vulnerable to the effects of lead poisoning and often do
not have the resources to make units lead safe on their own.
The goal of the program is to reduce as many lead hazards in housing units as possible, in the
most cost-efficient manner available. Additionally, the program aims to educate citizens on the
hazards of lead hazard exposure.
Goals
Responsible Date Activity Evaluation
Objective Activity Person Complete Measure
Units LIRA
170 Units Assessed Ins ector/PM 3/30/22 assessed
Units
120 Com leted/cleared Ins ector/PM 9/30/22 Dust Clearance
PM/Co
Outreach to Orgs Director 6/30/22 # Presentations
Pm/Co
Outreach to citizen Director 6/30/22 # Events/Mailers
Advocacy
145 Assessments Partner 6/30/22 # Assessments
Staff:
Estimated Other
1. Personnel (Direct Labor) Hours FTE Admin Direct Program
Cost
Position Title - Name or label Vacant*
Housin & CD Director-Alexis Ste er 42 mos 321 7% 80% 20% 0%
Co-Director- Health Specialist- Mary Rose
Corri an 42 mos 321 7% 80% 20% 0%
Co-Director- General Housing Specialist-
Madeline Haverland 43 mos 1,388 20% 30% 15% 55%
Grants Pro ram Mana er- Sharon Gaul 45 mos 5,400 75% 50% 50% 0%
Lead/HH Inspector- Chris Schneider 42 mos 6,720 100% 5% 95% 0%
Lead/HH Inspector-Vacant, hired 36 mos 5,760 100% 5% 95% 0%
Housing Financial Specialist- Jason Duba 42
mos 6,720 100% 20% 0% 80%
Grant Administrator- John Thar 42 mos 1,388 20% 5% 0% 95%
HUD Recipient Project Director:
Alexis Steqer- Housing & Community Development Director
Supervision of grant staff two hours per week (321 total over grant) devoted to grant oversight
and compliance with City policy and procedure. Position will devote approximately 7% of time
to collaboration with other city departments. In kind match total $16,050 split 80%Admin, 20%
Direct.
Co-Director:
Mary Rose Corriqan- Public Health Specialist
Responsibility in collaboration with State Department of Health and EBL case management
locally. Connection responsibility with education and outreach with medical community.
Position will devote approximately 7% of time at two hours per week (321 total over grant).
In kind match for Mary Rose Corrigan: $14,194.62, split 80%Admin, 20% Direct.
Co-Director:
Madeline Haverland- General Housing Specialist:
Primary responsibilities for this position include direct project inspection quality control for code
enforcement standards in Lead Hazard approved units, Lead Inspector start-up coordination of
duties, ongoing programmatic evaluation, environmental review oversite and approval, liaison
between different housing activity funding sources. This position to be 20% FTE, with 30%
spent in admin and 15% spent in direct, and 55% spent in Other Direct. Estimated at 43 months
of oversite activity equating to Admin: $14,157.60, Direct: $7,078.80, Other Direct: $25,955.60.
Day to Day Program Manager:
Sharon Gaul-Grants Program Manager
Primary responsibilities of oversite of all facets of production program including contractor
capacity building, oversite of financial and budgetary requirements, coordination of inspection
and advocacy activities, internal project coordination with other partners and funding programs,
HUD regulation compliance accountability and main point of contact for programming and
outreach. This position is estimated to be 75% FTE contributing 5,400 hours over the life of the
grant for full POP plus close out. It is estimated 50% of the Program Manager's time will be
administrative and 50% direct costs. The total Direct Cost: $102,600,Admin Cost: $102,600.
Intake and Fiscal Officer:
Jason Duba- Housing Financial Specialist:
Primary responsibilities for position will be application intake and income verification, occupant
relocation coordination, financial and budgetary data entry for quarterly reporting purposes. This
position is estimated to be 100% FTE contributing 6,720 hours over 42 months. It is estimated
this position will be 20% admin and 80% other direct costs. The total Admin Cost: $34,272.00,
and total other direct cost: $137,088.
Chris Schneider& (1) VACANT- Lead/Healthy Homes Inspector:
The two Inspector/Risk Assessors are calculated on 42 and 36 months respectively. It will take
on average two months to get the first inspector interviewed and trained. It is then planned that
approximately six months into the grant a second inspector will be hired, to be trained by the
first. In addition, likely two inspectors are not needed at the end for full closing out period of a
Program. The Inspectors time was estimated at 95% direct costs and 5% administrative. Each
are 100% FTE positions. Total direct for the two inspectors: $193,882.08 and $166,184.64.
Admin Cost: $10,204.32 and $8,746.56.
City Financial Coordination:
John Tharp- Grant Administrator
Position responsibility will be heavy on the City project fiscal end of the program with purchase
order processing, City finance reporting, City budget and eligible activity checks and balances,
City ECIVIS grant and finance software reporting provided to fiscal officer for draw and quarterly
reporting. This position estimated at 20% FTE over 42 months. 95% in other direct cost and
5% in admin time projected. Other Direct Cost: $45,491.70, Admin Cost: $2,394.30.
Income Verification process:
Utilize Annual income method as defined by 24 CFR 5.609/Part 5 Annual Income. Utilize the
most current Area Median Income set by HUD annually. Refer to PGI 2017-05 for whom
Income counts in the household.
1) Do not count these household members or their income
live-in aides & their children
children being pursued for legal custody or adoption that are not living in
home
Do count child subject to shared-custody agreement in which child resides in
home 50%
2) Collect documents to verify Income utilizing the following review hierarchy:
a) Third Party Documents (online or hard copy)
6 - 8 weeks of wage statements, bank statements, unemployment
compensation,
pay stubs, tax returns, bank statements, etc.
b) Verbal Third Party (documented by grantee)
TenanULandlord Declaration (signed statement by tenant and/or property
c) owner)
3) Determine the basis on which statements are paid:
Hourly, weekly, monthly, etc. with anticipated increases
4) Determine any variations in pay
steady employment - collect 3 consecutive months of pay
non-conforming employment - collect previous 12 months of pay
5) Determine if there is additional earned income
annual cost of living adjustments, bonuses, raises, overtime, etc.
6) Make the determination if Income Eligible
Insure income verification is completed within the current period specified in PGI 2017-05. If
Threshold timing should be over allotted period, income verification shall be recalculated prior to
project commencement.
Colleqe Student income verification will be according to attached.
Financial Policy:
Mechanisms shall be in place for income eligibility. Recapture provision shall exist if terms of
contract are not met. All recapture shall be handled as program income and utilized.
Procurement:
Federal Procurement policy 2 CFR 200 shall be followed. lowa Chapter 26 for public bidding
process shall be followed with a Sealed Bid process that aligns with Federal regulation. Local
City AP 3.10 shall be followed with bid thresholds in mind. Procuring services and local vending
shall follow AP 3.10. The strictest of the 3 layers above shall always be followed.
Payments and invoicing shall be entered by the Lead Financial Specialist into the ECIVIS City
Grant software, with associated grant id numbers to insure no co mingle of federal funding. PGI
2015-01 shall be utilized by Grant Administrator for grant eligible expenses.
Complete Process for data needed to perform LOCCS draw.
Approving Official shall coordinate access to LOCCS system.
Occupant Considerations:
Occupant protection plan shall be completed by contractor prior to construction and provided to
occupant.
EBL coordination effort shall be the following process: Also, to be incompliance with lowa
Chapter 68- Control of Lead-Based Paint Hazards. EBL attachment process.
Contractor capacity building strategy:
Once period of performance is started and ROF has been met a community contractor interest
and guideline meeting will be held with interested contractors. The guidelines of the new grant
and items that will change from prior grant periods will be discussed. Stakeholders will be
engaged to give feedback about items that worked in prior grants as well as challenges that
were faced in the vendor and contracting side of past grants. Workforce Development partners
in the community will also be at this event for subject matter expertise in skills gaps and training
needs.
Outreach and Intake Tracking:
An outreach benchmark tool will be created in Excel to track outreach efforts. Partners will be
utilized in this effort with their events and education on Lead Based Paint Hazards in the
community. Number of people in attendance to event, number of mailers sent, door hangers
hung, yard signs placed, Banners for awareness will be utilized and tracked as examples. All
members of the team will be involved in the outreach.
Intake application benchmark tool will be created in Excel to track effort. Number of applications
sent and received will be monitored and reviewed quarterly by Co Directors with Grants
Program Manager. This tool will be managed and entered by Lead Financial Specialist.
Project Assessment/Inspection: Refer to 2017-01 Dust Lead Action and Clearance Levels.
LEAD INSPECTION/ RISK ASSESSMENT & HEALTHY HOMES ASSESSMENT — Lead & HH
Inspectors (15— 30 days with SHPO)
a. Perform LI/RA and HH Assessment — Lead & HH Inspectors
i. Sketch floor plan
ii. Take Dust Wipes
iii. Photos
b. Ship dust wipes to EHS Laboratory
c. Download readings from XRF analyzer to computer- adjustments as necessary
d. Document on State HHLPSS system
e. Download photos
f. Prepare 106 and forward to Planning
i. Planning to review and forward to State Historic Preservation Office (SHPO)
g. Finalize floor plan on floor plan software
h. Begin narrative report— including Lead and Healthy Homes
i. Rank deficiencies utilizing Dubuque's Life Safety Health Hazard based protocol for
categorizing HUD 29 hazards
i. Summary of above Refer to PGI 2017-05
j. Receive dust wipe results from lab (3-4 days) and enter into the narrative
k. Prepare scope of work from lead hazards identified in the LI/RA and results of
Hazard scoring from HH Assessment
I. Prepare City's cost estimate from scope of work (after SHPO findings received)
m. Work write up and scope of work reviewed and approved - Program Manager
Scope and Design of project shall follow 2012 HUD applicable Chapters, Title X, follow lowa
Department of Health guidelines for addressing lead hazards, local International Property
Maintenance Code (IPMC) for rental units.
Environmental Review process shall be documented to extent possible in HUD HEROES
system.
TIER II ENVIRONRMENTAL REVIEW (immediately before LI/RA)
a. Tier II Environmental Review performed — Lead & HH Inspectors
i. Appendix A
ii. Send to SHPO
iii. SHPO requirements notated on Appendix A
Tier I I Environmental Review—Sign off—Co-Director-General Housing Specialist
Construction Project process:
a. Bid packet prepared - Lead & HH Inspectors
i. Lead & HH narrative report
ii. Lead XRF readings
iii. Floor Plan
iv. 106 Review
b. Bid packet posted on website — Lead Financial Specialist
c. Text and email notifications distributed to contractors via City website notification
(Notify Me) — Lead Financial Specialist
d. Send bid packet to property owner— Lead & HH Inspectors
e. Hold Bid Tour- Lead & HH Inspectors
i. Published Time and Date
f. Contractor to follow Chapter 26 guidelines for public bidding
g. Bid awarded to lowest "responsible" bidder—Grants Program Manager
Relocation Policy:
2012 HUD Guidelines for Chapter 8 Sect. 4 Temporary Relocation
Unified Relocation Act URA
Payment of temporary location shall be handled via the following options as available:
1) Families may stay with family or friends during construction and receive a stipend for
food.
2) Families may stay in approved hotel locations, list provided by City to occupant. City will
pay directly for hotel and provide stipend if cooking facilities are not provided.
3) When available furnished relocation unit(s) may be available to occupants at City cost.
Deposit shall be provided by property owner or owner of owner-occupied unit.
4) If landlord has vacant unit and can provide unit, no deposit shall be required by landlord.
Unit Monitoring:
Web based tool will be used to capture field visits to property. Lead/HH Inspector will capture
notes from visit and interactions with contractor or owner. State HHLPS program also updated.
Site visit case notes to have purpose and results of visit.
Clearances:
Shall be documented by Inspector and 2017-01 Dust action levels met prior to re-occupancy.
All dust wipe results shall be captured in project file for abatement reports required for each unit.
Special protocol, and thresholds will be established for carpeted areas that are problematic for
dust clearances.
Post Clearance Monitoring shall be conducted by the General Housing Specialist and Grants
Project Manager as needed for quality control between units. 2012 HUD Guidelines Chapter 6
and 15 shall be maintained.
Grant amendment policy 2013-03 shall be followed for all amendments that should be needed
throughout grant life cycle. Amendments possibly needed but not limited to are: Authorizing
Official change, Budget amendments, Key Personnel changes, Period of performance change,
Benchmark changes, Other significant changes, etc.
Training of Staff:
All required State certifications will be provided by lowa Department of Public Health Certified
trainer, and Healthy Homes Specialist Credential by qualified regional trainer. LIRA training,
Abatement Contractor and HH Credential required for Inspectors and Grants Program Manager.
Staff Training will also include review and sign off, by all staff of the following: NOFA awarded,
Title X, Procurement Policies, Grant Narrative, lowa Code Lead Based Paint chapters. GMO
Handbook.
Program Evaluation:
Housing Director and Co-Directors will be tasked with regular and ongoing program evaluation.
Grants Program Manager will be tasked with setting up quarterly reports from all partners.
End original Workplan. Amendments below. Last Revision 10/15/19
Workplan Amendment 1:
Rental Property Owner Requirements:
Property owners participating in the grant program shall be required, for the term of the
forgivable loan, for any funded unit, to give preference to low to moderate income families,
being defined as below 80% Area Median Income, and accept Housing Choice Vouchers (HC�
provided by the Section 8 program funded by the U.S. Department of Housing & Urban
Development, if the prospective tenant is otherwise qualified. Property owners shall provide
certifications of the above preference at specified intervals provided by the City. Failure to
comply will result in remaining balance of forgivable loan becoming due and payable on the date
of notification of non-compliance.