Community HOME Investment Program (CHIP)

1
Community HOME InvestmentProgram(CHIP)

• HOMEOWNER REHABILITATION
• FEDERAL COMPLIANCE

2
Compliance AgendaRehabilitation - Reconstruction

• Environmental Review Requirements
• Fair Housing and Equal Opportunity
• Accessibility - Visitability

3
Environmental Review Requirements

• Obligation of Recipients
• Comply with environmental and historic
  preservation laws
• Assess and evaluate environmental effects
• Minimize and mitigate any adverse effects
• Public Notification
• Do not obligate funds until release of funds

4
Environmental Review Requirements
Tier 1

• State Recipient
• Complete Statutory Checklist
• Provide detailed information
• Publish in newspaper
• Submit to DCA Day 16
• Signed Checklist
• Proof of Publication
• Request ROF
• Receive Authority to Grant Funds

• Sub-Recipients
• DCA complete Statutory Checklist
• DCA publish in newspaper
• DCA charge sub-recipient for cost of publishing
• DCA request ROF
• DCA issue Authority to Grant Funds after HUD
  clearance

5
Environmental Review Requirements
Tier 2

• State Recipients
• Submit Site Specific Environmental Screening
  Checklist
• Signed by Authorizing Official
• Mayor
• Chairman
• CEO/Executive Director(non-profits)
• Submit all supporting documentation
• DCA verify clearance
• DCA issue Notice to Proceed

• Sub-Recipients
• Submit Environmental Screening Checklist
• Submit supporting documentation
• Floodplain/Wetland Maps
• Noise Study
• SHPO clearance
• DCA complete Site Specific Environmental
  Screening Checklist
• DCA perform clearance
• DCA issue Notice to Proceed

6
Tier 1 Statutory Assessment Site Specific
Environmental Screening Checklist
7

• GEORGIA DEPARTMENT OF COMMUNITY AFFAIRS
• Community HOME Investment Program
• Environmental Screening Checklist
• A separate checklist must be completed for each
  development site and submitted in the
  Application.
• Applicant Name _________________________________
  __________
• Project Address ________________________________
  ___________
• Type of Activity ___New Construction ___
  Reconstruction __ Rehabilitation
• Part I Historic Preservation (Complete only if
  existing building is on site)
• What year was the house originally constructed?
  
• 2. What source data was used to determine year of
  construction?
• ___Tax Record ___ Appraisal ___Builders
  Deed
• ___ Historic Survey Data ___ Sanborn Fire
  Insurance Map

8
Single Family Housing Development Program
b. Coastal Areas Protection and
Management ____ ____ References
(1) Coastal Zone Management Act of 1972 as
Amended (16 U.S.C. 1451-1464)
(2) Coastal Barrier Resources Act of
1982 (16 U.S.C. 3501). (3) Coastal
Barrier Improvement Act of 1990 (16 U.S.C.
3501). c. Runway Clear Zones and
Accident Potential Zones ____ ____
Reference 24 CFR Part 51 d.
Endangered Species ____ ____
Reference Endangered Species Act of 1973 as
Amended (16 U.S.C. 1531-1543). e.
Solid Waste Management ____ ____
Reference Solid Waste Disposal Act as Amended
by the Resource Conservation and
Recovery Act of 1976 (42 U.S.C. 6901-6987) and
U.S. Environmental Protection
Agency (EPA) Implementing Regulations 40 CFR
Parts 240-265). f. Farmland
Protection ____ ____
Reference (1) Farmland Protection Policy Act of
1981 (7 U.S.C. 4201), particularly
sections 1540(b) and 1541 (7 U.S.C. 4201(b) and
4202) (2) Farmland Protection
Policy (Department of Agriculture 7 CFR part
658). g. Sole Source
Aquifers ____ ____ Reference
(1) Safe Drinking Water Act of 1974 (42 U.S.C.
201, 300(f) et seq., and 21 U.S.C.
349) as amended particularly section 1424(e) (42
U.S.C. 300h03(e)) (2) Sole Source
Aquifers (EPA 40 CFR part 149). h.
Wild and Scenic Rivers ____ ____
Reference The Wild Scenic Rivers Act of 1968
(16 U.S.C. 1271 et seq.) as amended,
particularly section 7(b) and (c) (16 U.S.C.
1278(b) and (c)). i. Air
Quality. ____ ____ Reference
(1) The Clean Air Act (42 U.S.C. 7401 et. seq.)
as amended particularly section
176(c) and (d) (42 U.S.C. 7506 (c) and (d))
(2) Determining Conformity of Federal
Actions to State or Federal Implementation Plans
(EPA 40 CFR parts 6, 51, and
93). j. HUD Environmental
Standards ____ ____ Reference
Applicable criteria and standards specified in
HUD environmental regulations (24
CFR part 51) (other than the runway clear zone
and clear zone notification
requirement in 24 CFR 51.303(a)(3)) and HUD
Notice 79-33, Policy Guidance to address
the Problems Posed by Toxic Chemicals and
Radioactive Materials, September 10, 1979).
9
Single Family Housing Development Program

• k. Environmental Justice. ____ ___
  _
• Reference Executive Order 12898
  Federal Actions to Address Environmental Justice
• in Minority Populations and
  Low-Income Populations, February 11, 1994 (59 CFR
  7629),
• 3 CFR, 1994 Comp. P. 859.
• Noise
• Reference HUD Regulations (24 CFR Part
  51. Subpart B)
• a. Is the site within 1,000 feet of
  a major road, highway, or freeway? ____ ____
• b. Is the project within 3,000 feet
  of a railroad? ____ ____
• c. Is the project within 15 miles of
  a military airfield? ____ ____
• d. Is the project within 5 miles of
  a civil airport? ____ ____
• 4. Thermal and Explosive Hazards
• Reference 24 CFR 51.200
• a. Is the site in an area where
  fuels, hazardous gases or flammable ____ ____
• chemicals are stored?

10
Fair Housing and Equal Opportunity

• Applicable Civil Rights Laws and Regulations
• Section 109 of the Housing and Community
  Development Act of 1974
• Section 504 and the Americans with Disabilities
  Act (ADA)
• Affirmative Marketing
• Ethnic and Racial Reporting Requirements
• Section 3

11
Fair Housing Equal Opportunity

• Section 109
• The right of all in this country to inherit,
  purchase, lease, sell, hold and convey real and
  personal property without regard to
• Race Sex
• Color Disability
• Religion Familial
  Status
• Or
• National Origin

12
Fair Housing and Equal Opportunity

• ADA and Section 504
• Ensures non-discrimination based on disability
• Accessible locations include
• Housing
• Public Hearing locations
• Application Intake
• Public Information
• TDD
• Georgia relay service

13
Fair Housing and Equal Opportunity

• Affirmative Marketing
• Affirmatively Further Fair Housing
• Market to Appropriate Target Population
• Advertise
• Newspapers
• Television
• Town Hall Meetings

14
Fair Housing and Equal Opportunity

• Minority Business Enterprises (MBE/WBE)
• Make business opportunities available
• Minority
• Women
• Required to report activity

15
Fair Housing and Equal Opportunity

• What is Section 3?
• Provision of the Housing and Urban Development
  Act of 1968
• Helps foster local economic development,
  neighborhood economic improvement, and individual
  self-sufficiency
• Requires recipients of certain HUD financial
  assistance to provide job training, employment
  and contracting opportunities for low or very low
  income residents in connection with projects and
  activities in their neighborhood.

16
Fair Housing and Equal Opportunity

• Section 3 Applicability
• 200K Threshold for Recipient Grant Award
• 100K Threshold for Construction Contracts
• Housing rehabilitation
• (including lead-based paint abatement)
• Housing construction
• Other public construction

17
Fair Housing and Equal Opportunity

• Ways to qualify for Section 3
• Resident
• Business

18
Fair Housing and Equal Opportunity

• Who are Section Residents?
• Residents of the non-metro county where the
  HUD-assisted project is located and who have a
  household income that falls below HUDs income
  limits.
• Public housing resident
• Section 8 resident
• Determining Income Levels
• Section 3 low income is defined as 80 or below
  the median income of that area (CDBG low to
  moderate income standard).
• Section 3 very low income is defined as 50 or
  below the median income of that area (CDBG low
  income standard).

19
Fair Housing and Equal Opportunity

• What is a Section 3 Business?
• 51 or more owned by Section 3 residents
• Section 3 residents make up 30 of its full-time
  permanent staff
• Provide evidence of a commitment to subcontract
  more than 25 of the dollar award of all
  subcontracts to businesses that qualify as a
  Section 3 business

20
Fair Housing and Equal Opportunity

• Ways to Implement Section 3
• Contact resident councils, resident managers or
  other resident organizations to request
  assistance in notifying residents of jobs
• First-source hiring agreements
• Sponsor job informational meetings
• Partnership with Department of Labor

21
Fair Housing and Equal Opportunity

• Ways to Implement Section 3
• Partnership with Local Technical College
• Conduct job interviews at the housing development
  or the neighborhood service area of the project
• Use community-based organizations to recruit and
  screen qualified persons
• Compile a list of all existing vocational
  training and apprenticeship programs in the area.

22
Fair Housing and Equal Opportunity

• Remember
• Discuss plans for complying with Section 3 in
  your 2012 Application
• Start early establishing systems and
  relationships
• DCA will work on standard approaches for
  recipients
• Section 3 Reporting More to come

23
Accessibility Visitability

• Accessibility
• Mandated by Federal Law
• New Construction
• Reconstruction

• Visitability
• Mandated by Georgia Law
• New Construction
• Reconstruction

24
Accessibility Visitability

• Accessibility
• Zero step entry
• Front, side or rear
• 36 inch door width
• First Floor
• Interior door 32 inch
• Hallway width 36 inches
• Bathroom wall reinforced for grab bars
• Electrical Plug at least 15 inched above floor
• Electrical no higher than 48 inches above floor
• Breaker box
• Light switch
• thermostat
• Main breaker inside on first floor

• Visitability
• Zero step entry
• Front, side or rear
• All main floor doors with 32 inches of clear
  passage space
• Includes bathroom
• At least a half-bath on main floor

25
Compliance Requirements

• Questions?
• Tarolyn Moore [phone]
• tarolyn.moore_at_dca.ga.gov