Section 3 of the Housing and Urban Development Act of 1968 requires recipients of HUD funding to create job training, employment, and contract opportunities for low- and very low-income individuals. When you think of HUD funding, it's probably subsidized housing that comes to mind. However, HUD also provides financial assistance to community centers, libraries, parks, and local road improvement, among other things.
The intent of Section 3 is to provide these opportunities to the "greatest extent feasible," as outlined in 24 CFR 135.30. This means that other procurement considerations are subordinate to Section 3 goals, and that cost considerations are insufficient grounds for awarding contracts to firms that are not Section 3-compliant.
- Part I: Why does it matter?
- Part II: Is my PHA subject to Section 3?
- Part III: What are my PHA’s responsibilities?
- Part IV: Can you recommend some Section 3 best practices?
Can you recommend some Section 3 best practices?
- As with any large-scale, long-range, and collaborative initiative, your PHA's Section 3 program should be planned out strategically. Not planning it out is planning to fail! Look at the mission, brainstorm SWOTs, identify stakeholders, assess gaps in your internal resources, and put together a project plan that includes responsibilities and timelines.
- Collaboration begins within the PHA! Procurement can't do this alone. You'll also need to include resident initiatives, human resources, and finance — and your Section 3 efforts must be championed from the top down with strong and supportive leadership.
- Self-sufficiency staff and programs are key internal partners. Do you have an FSS program? Tie in Section 3 to your residents' individual training and services plans (ITSPs). A ROSS program? YouthBuild? Public housing self-sufficiency projects? All your economic self-sufficiency programs and activities can contribute to Section 3 success.
- Designate or hire a Section 3 coordinator. 'Nuff said.
- Now you’re ready to creatively and effectively collaborate with community partners. Work with the people doing the work! They'll help make your Section 3 program successful. These crucial partners will help you design an effective Section 3 program, and will help outreach, recruit, train and ensure hiring. Consider forming a Section 3 advisory board and include decision makers and experts from your local city or county government, Department of Labor Workforce Investment Board, welfare agency, community colleges, skilled trades, and other key stakeholders. At least one public housing resident should be a participant on the Section 3 advisory board.
NMA senior associate Cara Gillette trains, consults, and provides technical assistance nationwide in fair housing, public housing management, hearings, economic self-sufficiency, and governing boards. Prior to joining NMA, she administered public housing and Section 8 waiting lists, served as hearing officer, managed public housing, and oversaw resident economic development programs at the San Diego Housing Commission. She has previously written for the NMA blog on how to work with sequestration in the public housing program.