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Thread: The CDBG entitlement community thread

  1. #76
    I interviewed several months ago with a CDBG consulting firm, and the panel asked extremely detailed questions about Section 3 and contracting. It's my understanding that hiring contractors that qualify as Section 3 is a goal. Genuine efforts need to be made and documented towards meeting the goal, but it's not a requirement to meet the goal. Davis Bacon on the other hand is absolutely mandatory. It's interesting that Section 3 was pushed down as an contractual requirement rather than a goal since that could be problematic.

    In the scenario you described, it's possible that your company would no longer qualify as a Section 3 business concern if Davis-Bacon salaries were paid year long, but at the same time the intent of Section 3 is being met: to provide job opportunities for low income persons. In fact, it would be seen as a major Section 3 success if all the employees would no longer qualify as low-income. I suspect that an argument could be made about the temporary nature of the Davis Bacon job that might allow you to keep Section 3 status with HUD's blessing.

    With all that said, I didn't get the job. So maybe I have it all wrong.

    I would also be interested if anyone else could provide some insight.
    The content contrarian

  2. #77
    moderator in moderation Suburb Repairman's avatar
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    Quote Originally posted by OfficialPlanner View post
    I interviewed several months ago with a CDBG consulting firm, and the panel asked extremely detailed questions about Section 3 and contracting. It's my understanding that hiring contractors that qualify as Section 3 is a goal. Genuine efforts need to be made and documented towards meeting the goal, but it's not a requirement to meet the goal. Davis Bacon on the other hand is absolutely mandatory. It's interesting that Section 3 was pushed down as an contractual requirement rather than a goal since that could be problematic.

    In the scenario you described, it's possible that your company would no longer qualify as a Section 3 business concern if Davis-Bacon salaries were paid year long, but at the same time the intent of Section 3 is being met: to provide job opportunities for low income persons. In fact, it would be seen as a major Section 3 success if all the employees would no longer qualify as low-income. I suspect that an argument could be made about the temporary nature of the Davis Bacon job that might allow you to keep Section 3 status with HUD's blessing.

    With all that said, I didn't get the job. So maybe I have it all wrong.

    I would also be interested if anyone else could provide some insight.
    I agree with your interpretation on Section 3 vs. Davis-Bacon. Unfortunately, Section 3 is another area in which HUD has little practical experience, and training for both contractors and recipients is nearly non-existent. I remember attending a supposed Section 3 training with HUD reps from D.C. They were asked several questions from about 75 of us at the training, and were unable to answer a single question (including a question very similar to this about Davis-Bacon actually knocking a contractor out of Section 3).

    Once again, I love the programs, but HUD provides catastrophically bad support.

    "Oh, that is all well and good, but, voice or no voice, the people can always be brought to the bidding of the leaders. That is easy. All you have to do is tell them they are being attacked and denounce the pacifists for lack of patriotism and exposing the country to danger. It works the same way in any country."

    - Herman Göring at the Nuremburg trials (thoughts on democracy)

  3. #78
    Super Moderator kjel's avatar
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    Quote Originally posted by Suburb Repairman View post
    I agree with your interpretation on Section 3 vs. Davis-Bacon. Unfortunately, Section 3 is another area in which HUD has little practical experience, and training for both contractors and recipients is nearly non-existent. I remember attending a supposed Section 3 training with HUD reps from D.C. They were asked several questions from about 75 of us at the training, and were unable to answer a single question (including a question very similar to this about Davis-Bacon actually knocking a contractor out of Section 3).

    Once again, I love the programs, but HUD provides catastrophically bad support.
    I frequently receive mixed signals regarding the completion of the Section 3 report from the municipality. The truth is that nobody really knows how to fill the damn thing out because it's "squishy" and can be interpreted a number of ways. Our Davis Bacon wages are very high as well, which complicates things as the previous poster mentioned. Our muni also has an affirmative hiring requirement for city residents who are minorities. Yes, that's three different requirements that I have to keep track of on top of the project management itself

    So here is our methodology:

    Section 3 requirements are based on "low" and "very low" income residents particularly those receiving assistance (food stamps/SNAP, housing, or cash). Since Section 3 does not explicitly state what "low/very low" means, I've borrowed this definition from the HUD Income Limits Documentation System which we use regularly for housing programs. Low Income is 80% of the Area Median Income adjusted for household size, and Very Low Income is 50% of the AMI adjusted for household size. You can find this information for your area here ---> http://www.huduser.org/portal/datasets/il.html. Believe it or not I am considered to be "low income" due to our household size and that we have one income, it's more generous than you think.

    We developed a little addendum questionnaire for our contractors/subcontractors about their workers on the job. It has the low/very low income chart and the worker checks off which box is applicable for their income, we ask for voluntary race/ethnicity self identification, and whether or not someone in the household has received assistance. As far as applying it to contractors that have the actual contract, well it's a little more complicated but can more or less follow the same path you just have to ask what their net earnings were for the prior year and what their household size is. My drywaller has a little company but he doesn't necessarily net a lot when it's all said and done-he may have contracts of $300K for the year, but might also have business expenses (labor, material, overhead) of $240K for the same year, netting him $60K. He's still low income if he's a household of 4 in our area.
    "He defended the cause of the poor and needy, and so all went well. Is that not what it means to know me?" Jeremiah 22:16

  4. #79
    Super Moderator luckless pedestrian's avatar
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    I am having a tough time organizing my CDBG admin - I am spending monies that were not spent before me and I have current projects too

    How do you organize your projects?

  5. #80
    Super Moderator kjel's avatar
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    I am sharing this very useful link to the Texas Department of Housing & Community Affairs page that deals with completing the Section 3 Summary Report. They have a spreadsheet version of the report which auto calculates those mysterious percentages for the report.

    http://www.tdhca.state.tx.us/program.../reporting.htm
    http://www.tdhca.state.tx.us/program...ummary-rpt.xls
    "He defended the cause of the poor and needy, and so all went well. Is that not what it means to know me?" Jeremiah 22:16

  6. #81
    Cyburbian Masswich's avatar
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    HUD keeps changing their minds on things, drives me crazy

  7. #82
    Super Moderator kjel's avatar
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    Quote Originally posted by Masswich View post
    HUD keeps changing their minds on things, drives me crazy
    So does the muni. Apparently they updated the certified payroll forms but didn't provide the update to us, naturally after we filled out the old forms.....
    "He defended the cause of the poor and needy, and so all went well. Is that not what it means to know me?" Jeremiah 22:16

  8. #83
    Cyburbian The One's avatar
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    LOL

    From HUD Section 8: http://www.huduser.org/portal/datasets/il/il14/ca.pdf

    San Francisco, CA HMFA
    FY 2014 MFI: 9710

    Individual Low Income = $62,050
    Family of Four Low Income = $88,600
    Skilled Adoxographer

  9. #84
    Super Moderator kjel's avatar
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    Quote Originally posted by The One View post
    From HUD Section 8: http://www.huduser.org/portal/datasets/il/il14/ca.pdf

    San Francisco, CA HMFA
    FY 2014 MFI: 9710

    Individual Low Income = $62,050
    Family of Four Low Income = $88,600
    Fair Market Rent is $1,956/month for a 2 bedroom in San Francisco County. Yikes!
    "He defended the cause of the poor and needy, and so all went well. Is that not what it means to know me?" Jeremiah 22:16

  10. #85
    Cyburbian
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    Consolidated Plan

    Well, we received our entitlement notification, I'm in the thick of writing our first consolidated plan. We have our IDIS accounts all set up... but HUD still hasn't added our jurisdiction to the system, so there is no default data available for all the required tables. It also appears that much of this information is not available anywhere else besides IDIS. The tables in the Con. Plan template don't match the ones provided by American FactFinder, nor the tables available from HUD's own CHAS data viewer!

    Also the plan has to be drafted by the end of March. Awesome.

  11. #86
    Super Moderator kjel's avatar
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    Quote Originally posted by DrGrant View post
    Well, we received our entitlement notification, I'm in the thick of writing our first consolidated plan. We have our IDIS accounts all set up... but HUD still hasn't added our jurisdiction to the system, so there is no default data available for all the required tables. It also appears that much of this information is not available anywhere else besides IDIS. The tables in the Con. Plan template don't match the ones provided by American FactFinder, nor the tables available from HUD's own CHAS data viewer!

    Also the plan has to be drafted by the end of March. Awesome.
    Welcome to the insanity.
    "He defended the cause of the poor and needy, and so all went well. Is that not what it means to know me?" Jeremiah 22:16

  12. #87
    moderator in moderation Suburb Repairman's avatar
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    Quote Originally posted by DrGrant View post
    Well, we received our entitlement notification, I'm in the thick of writing our first consolidated plan. We have our IDIS accounts all set up... but HUD still hasn't added our jurisdiction to the system, so there is no default data available for all the required tables. It also appears that much of this information is not available anywhere else besides IDIS. The tables in the Con. Plan template don't match the ones provided by American FactFinder, nor the tables available from HUD's own CHAS data viewer!

    Also the plan has to be drafted by the end of March. Awesome.
    You should be able to request an extension under those circumstances. Contact your HUD rep.

    "Oh, that is all well and good, but, voice or no voice, the people can always be brought to the bidding of the leaders. That is easy. All you have to do is tell them they are being attacked and denounce the pacifists for lack of patriotism and exposing the country to danger. It works the same way in any country."

    - Herman Göring at the Nuremburg trials (thoughts on democracy)

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