HomeMy WebLinkAboutWHSP RFP - Information Sessions Q&AQ #Question & Date Answer/Information
1 Will award recipients be required to comply
with Davis-Bacon? 06.26.2024
The projects we are about to undertake will fall into one of two categories, as defined by US Treasury. They
will either be considered an Affordable Housing project under the Negative Economic Impact category, or
they would be part of the Infrastructure category. The Davis-Bacon Act requirements (prevailing wage
rates) do not apply to projects funded solely with ARP funds under these two categories. However, vendors
may be otherwise subject to the requirements of the Davis-Bacon Act if ARP award funds are used on a
construction project in conjunction with funds from another federal program that requires enforcement of
the Davis-Bacon Act. State and/or local requirements should also be considered. Subrecipients may wish to
consult their own legal counsel if the have other concerns about Davis-Bacon.
2 With regards to compliance, will county staff
assist with data collection? 06.26.2024
County staff will collect data to meet the compliance responsibilities of the recipient organization. Other
data may require collection and reporting by the subrecipient according to applicable Federal Uniform
Guidance. Subrecipients may wish to consult their own legal counsel if they have specific concerns about
Federal Uniform Guidance.
3 Are recipients required to comply with Section
3 of the HUD Act of 1968? 06.26.2024
US Treasury guidelines do not include or reference Section 3 requirements in their ARPA materials. To the
extent that an affordable housing project is in alignment with the federal housing programs shown in
“Presumption 1”, the covered project would be required to adhere to all applicable local codes, and comply,
at a minimum, with the applicable federal housing program’s requirements related to the following:
Resident income restrictions, the period of affordability and related covenant requirements for assisted
units, tenant protections, and housing quality standards. As reminder, Federal Uniform Guidance
requirements would be applicable, which includes procurement instructions related to bidding, etc.
Subrecipients may wish to consult their own legal counsel if they have specific concerns about the Section 3
HUD requirement.
4 Are staff presentation slides used during the
virtual information session available to
attendees? 06.26.2024
Staff presentation slides are part of the session recording. The recording and slides will be posted on the
county's housing program webpage.
5 Due to the use of ARPA funds, will a full
Environmental Assessment be required? If so,
is that an eligible project cost? 06.28.2024
Affordable Housing and Infrastructure projects funded solely with ARP funds have no specific
Environmental Assessment requirements. Other standard Federal, State, Local or EPA requirements would
apply, but there is no additional requirement specific to use of ARP funds.
6 When would a National Environmental
Protection Act (NEPA) review be required?
06.28.2024
NEPA requirements do not apply to projects funded solely with ARP funds under the Affordable Housing
and Infrastructure categories. Projects supported with ARP funds may still be subject to NEPA review if the
project is also funded by other federal financial assistance programs or have certain federal licensing or
registration requirements.
Workforce Housing Services Program RFP FY 2025 - Virtual Information Sessions Q&A