Section 3 Policy |
The Boston Housing Authority has issued a Section 3 Policy for public comment and seeks your input on this important program. The Policy details the Authority's implementation of Section 3 of the Housing and Urban Development Act of 1968, which provides for employment and contracting opportunities for BHA residents and low- and very-low income residents of the Boston area. The proposed Policy is available for review in PDF form at the bottom of this page.
The Policy updates and expands on the Authority’s “Resident Employment Provision (REP).” It reflects the following major changes:
- The Policy itself is intended to be a stand-alone document that describes BHA’s Section 3 program, policies, and procedures.
- The Policy delineates BHA departmental responsibilities related to Section 3 (p. 11-18). While the majority of Section 3 duties are carried out by the Office of Civil Rights, the Policy discusses the roles of the Community Services, Procurement, Capital Construction, Real Estate Development, Operations, Human Resources, Leased Housing, Fiscal Affairs, and Legal Departments.
- The Policy establishes a Section 3 Training Fund (p. 8-9). The Fund is the designated depository for monetary sanctions recovered by the BHA in conjunction with its enforcement of Section 3 contractual requirements. In addition, the Fund will be permitted to accept donations from individuals or entities not under consideration for contract award or currently contracting with BHA.
- The Policy adds an internal complaint procedure for aggrieved Section 3 applicant individuals or business concerns (p. 20-21). Written complaints are to be directed to the Chief of Staff, care of OCR, with the goal of resolving matters in a timely and less formal basis than a HUD investigation.
- While the REP had no minimum dollar threshold for a Section 3 Compliance Plan, this Policy requires a Section 3 Compliance Plan for construction contracts valued over $100,000 (p. 19). A Section 3 Compliance Plan is a document that spells out the specific efforts the general contractor and its subcontractors will take to comply with the Section 3 goals.
Please note that comments on the Policy are due at the close of business on Friday, March 2, 2012, and should be addressed to Matthew Steele at matthew.steele@bostonhousing.org or OCR, 52 Chauncy Street, Boston, MA 02111.
A hearing on this proposed Policy will be held at 125 Amory Street, Training Center, Jamaica Plain, MA 02119 on Tuesday, February 28, 2012 at 12:00 p.m. If you have a reasonable accommodation request relative to either reviewing the Policy or attending the Hearing, please call 617-988-4379 or TDD 800-545-1833 x420. Interpreters can be made available at the Hearing upon request.
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