Certification of Consistency with Consolidated Plan for Legal Aid Fair Housing Initatives Program GrantCopyrighted
June 21, 2021
City of Dubuque Consent Items # 22.
City Council Meeting
ITEM TITLE: Certification of Consistency with Consolidated Plan for Legal Aid Fair
Housing Initiatives Program Grant
SUMMARY: City Manager recommending approval of the Certification of Consistency
with the Consolidated Plan for Legal Aid Fair Housing Initiatives
Program.
SUGGESTED Suggested Disposition: Receive and File; Approve
DISPOSITION:
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Description Type
Legal Aid Fair Housing Certification of Consistency City Manager Memo
with Consolidated Plan-MVM Memo
Cover Memo Certification of Consistency with
Consolidated Plan for Legal Aid Fair Housing Initiatives Staff Memo
Program Grant
Certification Form Supporting Documentation
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Certification of Consistency with Consolidated Plan for Legal Aid Fair
Housing Initiatives Program Grant
DATE: June 11, 2021
Iowa Legal Aid intends to apply for a Fair Housing Initiatives Program grant to conduct
fair housing testing in the City of Dubuque. Grant funds will be used to conduct two
types of testing: 1) fair housing tests in individual complaints upon referrals from another
group or agency, which could include the Human Rights Department or the Housing and
Community Development Department; and 2) proactive testing surveys of housing
providers who advertise as not accepting housing choice vouchers to develop an
understanding and data regarding whether or not refusal to accept vouchers is a pretext
for discrimination under existing fair housing law. Given that the State of Iowa recently
enacted legislation pre-empting local government from enacting "source of income"
protections, taking proactive steps to eliminate discrimination that is illegal under
existing civil rights law is increasingly important.
Human Rights Director Kelly Larson recommends City Council approval of the
Certification of Consistency with the Consolidated Plan for Legal Aid Fair Housing
Initiatives Program.
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
Cori Burbach, Assistant City Manager
Kelly Larson, Human Rights Director
Alexis Steger, Housing and Community Development Director
Dubuque
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To: Michael C. Van Milligen, City Manager
From: Kelly Larson, Human Rights Director
Date: June 7, 2021
Subject: Certification of Consistency with Consolidated Plan for Legal Aid Fair Housing
Initiatives Program Grant
The purpose of this memorandum is to request approval of the attached Certification of
Consistency with the Consolidated Plan, which I provided provisionally to Legal Aid in order to
meet a June 14 grant deadline. Legal Aid is aware that the certification may be withdrawn if you
and/or the City Council do not approve.
Iowa Legal Aid intends to apply for a Fair Housing Initiatives Program (FHIP) grant to conduct
fair housing testing in the City of Dubuque. Grant funds will be used to conduct two types of
testing: 1) fair housing tests in individual complaints upon referrals from another group or
agency, which could include the Human Rights Department or the Housing and Community
Development Department; and 2) proactive testing surveys of housing providers who advertise
as not accepting housing choice vouchers to develop an understanding and data regarding
whether or not refusal to accept vouchers is a pretext for discrimination under existing fair
housing law. Given that the State of Iowa recently enacted legislation pre-empting local
government from enacting "source of income" protections, taking proactive steps to eliminate
discrimination that is illegal under existing civil rights law is increasingly important.
The City of Dubuque Consolidated Plan and its associated Fair Housing Action Plan derived
from the Analysis of Impediments to Fair Housing are consistent with Legal Aid's proposal.
Housing cost burden is our most significant housing problem by far and it disproportionately
impacts households of color. Recipients of Housing Choice Vouchers are disproportionately
households of color, single female headed households with children, and households with
individuals with disabilities — all of whom are protected under the Fair Housing Act. One of the
high priority actions recommended in the 2019 Analysis of Impediments includes establishing an
external, independent fair housing testing program to identify problems members of protected
classes face when seeking fair housing in Dubuque.
Requested Action
The requested action is that you approve the provisional certification and obtain City Council
approval as needed.
cc: Crenna Brumwell, City Attorney
Alexis Steger, Housing and Community Development Director
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I certify that the proposed activities/projects in the application are consistent with the jurisdiction's current, approved Con solidated Plan,
(Type or clearly print the following information:}
Applicant Name: A] I
Project Name: 0
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Location of the Project:
Name of the Federal
Program to which the
applicant is applying:
Name of
Certifying Jurisdiction:
Certifying Official
of the Jurisdiction
Name:
Title:
Signature:
Date:
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Page I of 1 form HUD•2991 (3198)