Lead Based Paint Hazard Reduction Program
Office of the Mayor
and City Council
City Hall
50 West 13th Street
Dubuque, Iowa 52001-4864
THE crTYOF ~
DUBUQuE
~~~
13 September 00
David Jacobs
Deputy Director
Office of Lead Hazard Control
US Department of Housing & Urban Development
Room P-3202
451 17th Street SW
Washington DC 20410
Re: Lead-based paint hazard reduction program
City of Dubuque Section 8 rental assistance programs
Mr Jacobs:
As you know, the City of Dubuque is a Lead-Based Paint Hazard Reduction Program grantee,
since 1997. We are proud of our initial successes in our program that has been generously funded
through your office, having inspected 340 units and completed hazard reduction activities in
another 290 units to-date. We have additionally trained and certified 46 contractors and 63
workers in hazard reduction procedures.
Dubuque also administers a program of rental assistance, to approximately 1000 Section 8
households (the City owns no public housing.) It is in regard to application of the pending lead-
based paint hazard reduction requirements to Section 8 housing that this letter is being directed to
the Office of Lead Hazard Control.
In preparation for the 15 September implementation deadline, we have sent our inspectors to the
HUD-sponsored training. We have devised a one-day worker training course and had this
approved by our state Department of Public Health. We have scheduled a series of these
trainings, for landlords, workers and contractors, beginning this month; we anticipate offering
these as frequently as necessary in order to reach as many individuals as may have interest in
working in treatment of deteriorated painted surfaces in their rental units. The :first such training
is scheduled to be held this month.
Additionally, we have prepared a letter of explanation, to all our Section 8 Program landlords, and
have mailed this to each, in August. We followed this up with a meeting with the board of
directors of the area landlord association. It was at this point that we encountered resistance to
our plan for implementation of the new HUD regulations in our Section 8 units.
Service
People
Integrity
Responsibility
Innovation
Teamwork
The 1000 Section 8 units on our program are owned by approximately 500 landlords. The
majority of these are ''mom and pop" operators, owning only a single or a few units. Many of
these owners are older persons, having purchased their rental properties for retirement earnings.
Most of these owners perform their own maintenance and light repairs. It is these landlords who
are most threatened by the pending regulations and in whose behalf we are making an appeal to
your office for a temporary stay of implementation of the regulations.
Our request to you is to allow us adequate time to provide additional education and training to
these Section 8 Program landlords. As well, we will make these workshops available to all other
owners, as interested. It is the intention of the Housing Services Department staff to hold a
number of scheduled "safe work practices" trainings, beginning in September, to meet this need.
With this opportunity to learn the requirements of the new HUD regulations in performance of
paint treatment in their Program rental units, we will build the local capacity needed to enable
local property owners to perform the work legally and safely.
As you know, our ability to successfully administer a Section 8 program requires the cooperation
of participating landlords. We must be careful to listen to their complaints and to respond in ways
which make continuing as Section 8 owners a ''user-friendly'' experience. And as the new
regulations will require these owners to maintain their properties to a level exceeding that
required of all other landlords, our goal is to transition to these standards in a way that they will
accept. This means we have to provide adequate time for discussion, training and education. For
this reason, we are requesting that the implementation deadline be extended in Dubuque to I
January 2001.
We have proposed this approach to the landlords association and received a favorable response.
With this compromise, we believe that we will obtain the cooperation of these owners, insure their
continued participation in the Section 8 Program and offer long-term adequacy of housing choice
to lower-income households in safe, healthy and compliant units.
Sincerely
~Du~
Mayor
cc:
Rita Gergely, Director, Lead Poisoning Prevention Program
Iowa Dept of Public Health