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MIGRANT SEASONAL FARMWORKER PROGRAM & HOUSING ASSISTANCE SGA (SGA/DFA-03-108) Questions and Answers

WHAT DOES THE COST PROPOSAL CONSIST OF? ARE SPECIFIC ITEMS OR EXPLANATIONS ANTICIPATED TO BE INCLUDED IN THE COST PROPOSAL?

ANSWER: The cost proposal for the National Farmworker Jobs program consists of the budget information summary (ETA 9093)(attached) and the Standard Form SF 424. Farmworker Housing Assistance applicant cost proposal consists of the SF 424 and the SF 424A. A written explanation in support of the cost proposal is not required.

IS THE SGA ASKING FOR A PROGRAM PLAN OF SERVICE SUCH AS THE FORM SUBMITTED BY CURRENT GRANTEES AS PART OF THEIR ANNUAL PROGRAM PLAN/ REAPPLICATION AND RESPONSES TO 2(A) THROUGH 2I)? OR ARE THE RESPONSES TO 2(A) THROUGH 2(I) THEMSELVES CONSIDERED THE PROGRAM PLAN OF SERVICE?

ANSWER: The program plan of service requires a description of each service along with the estimated numbers to receive training services and related assistance services. The program planning summary (ETA 9094) and the budget information summary (ETA 9093) are also required to respond to the SGA; however, completing the ETA 9094 will not satisfy the requirement to provide estimated numbers for those proposed to receive training services and to receive related assistance services.

DOES THE 50 NUMBERED PAGE LIMITATIONS INCLUDE THE COST PROPOSAL?

ANSWER: NO

SHOULD APPLICATIONS FOR HOUSING ASSISTANCE BE SUBMITTED AS INDIVIDUAL STATE APPLICATIONS OR CAN A REGIONAL APPLICATION BE SUBMITTED?

ANSWER: Applicants are to determine the geographic areas where they propose to operate a housing assistance program. When preferred by the applicant, a multi-state or a regional application may be appropriate.

IF REGIONAL APPLICATIONS ARE ALLOWED, THEN WILL THAT APPLICATION BE LIMITED TO THE 15-PAGE REQUIREMENT AND MUST A PROGRAM BE PROPOSED FOR EACH STATE IN THAT REGION?

ANSWER: YES, the 15-page limitation requirement will be imposed for regional applications. No, it is not a requirement that a program be proposed for each state in that region. However, applicants must be guided by the regional allocations, in preparing proposal.

FOR THE HOUSING ASSISTANCE APPLICATION DO WE TREAT DELAWARE/MARYLAND AS A COMBINED SERVICE AREA?

ANSWER: The Delaware/Maryland and the Connecticut/Rhode Island combined service areas apply to the national farmworkers jobs program only. Applicants for housing assistance funds are to identify the geographic area to which they propose to operate.

FOR THE HOUSING ASSISTANCE APPLICATION, NO BUDGET IS REQUESTED, BUT WILL WE STILL SUBMIT PAGE 1 OF THE APPLICATION FOR FEDERAL ASSISTANCE WITHOUT A FIXED FUNDING LEVEL?

ANSWER: A financial proposal is requested for the farmworker housing assistance applications. The housing assistance applicants should submit a SF 424 &424A.

ARE NON-PROFIT ORGANIZATIONS ELIGIBLE FOR THIS GRANT?

ANSWER: Yes, when the organization responds successfully that it has 1) an understanding of the problems of eligible migrant and seasonal farmworkers, 2) a familiarity with the area to be served and 3) the ability to demonstrate a capacity to administer effectively a diversified program of workforce investment activities and related assistance for eligible MSFWs. The information needed to demonstrate these capacities is required by the SGA.

INDIRECT SERVICES MUST FOCUS ON INCREASING OR MAINTAINING THE STOCK OF EMERGENCY AND TEMPORARY HOUSING, BUT YEAR-ROUND 167 ELIGIBLE FARMWORKERS HAVE NEEDS FOR YEAR-ROUND HOUSING SUCH AS RURAL DEVELOPMENT'S SECTION 514/516 FARM LABOR HOUSING PROGRAM. THE QUESTION IS; CAN INDIRECT SERVICES BE USED TO MAINTAIN AND INCREASE THE AVAILABLITY OF THIS TYPE OF FARMWORKER HOUSING?

Answer: The SGA provides that "indirect services must focus exclusively on increasing (or maintaining) the stock of emergency and temporary housing including portable housing units." Services related to year-round housing may not be financed indirectly with these funds, such as through leveraging activities.

PLEASE GIVE ADDITIONAL INFORMATION AND/OR CLARIFY THE STATEMENT IN THE NOTE SECTION CONCERNING SOLE-SOURCE PROCUREMENT AND HOW OR IF IT APPLIES TO STATE GOVERNMENTS AS GRANTEES.

Answer: This provision means that grantees can not simply rely upon the identification of a service provider in its application as the grounds to enter into a sole-source procurement transaction. This provision does not change or add to a grantee's responsibility for complying with applicable state and/or local procurement standards, as required by 29 CFR Parts 95 and 97. This does not prohibit sole-sourcing. A sole-source selection of a service provider funded under the grant must be authorized under those applicable state and/or local standards.

IS IT POSSIBLE FOR A CONSORTIUM TO COVER TWO OR THREE REGIONS?

Answer: Yes. Each applicant for housing assistance funds is free to select and identify the geographic area or areas for operating its proposed farmworker housing assistance grant. The allocations to the agricultural regions will guide ETA in distributing funds. (The agriculture regions will not be used to decide on the geographical territories of the grantees.)

THE SGA ELIMINATES THE REGIONAL STRUCTURE AND FARMWORKER HOUSING GRANTEES. THE SGA DOES NOT INVITE APPLICATIONS FROM HOUSING CONSORTIUMS. THE REGIONAL STRUCTURE WAS A DEPARTMENT OF LABOR CREATION. WHY THE CHANGE NOW? IT APPEARS FROM THE SGA THAT DOL WILL NOT MAKE ANY SEPARATE HOUSING GRANTS, AND IS NOT PLANNING TO MAKE ANY SINGLE PURPOSE GRANTS FOR HOUSING, BUT INSTEAD, FUND OTHER WIA GRANTEES. PLEASE EXPLAIN.

Answer: The SGA provides for two separate competitions. One is the National Farmworker Jobs program grants and the other is for the farmworker housing assistance grants. Awards will be made under each competition. The SGA for the farmworker housing assistance allows for applications that propose to serve a multi-state area.

THE SGA STATES THAT DOL WILL NOT FUND FACILITIES CONSTRUCTION. WHAT DO YOU CONSIDER FACILITIES CONSTRUCTION?

Answer: The WIA regulations at 20 CFR 667.260 provide that WIA funds must not be spent on construction or purchase of facilities or buildings except as provided in the exceptions.

THE UNITED STATES DEAPRTMENT OF AGRICULTURE, RURAL DEVELOPMENT (RD) IS THE ONLY FUNDING SOURCE - FEDERAL, STATE AND LOCAL THAT HAS CONSTRUCTION FUNDS (LOANS AND GRANTS) SPECIFICALLY FOR FARMWORKERS. THEIR FUNDS ARE SO LIMITED THAT IT WOULD NOT BE COST EFFECTIVE TO CONSTRUCT TEMPORARY HOUSING. TEMPORARY AND EMERGENCY HOUSING WOULD STILL ENTAIL A MORTGAGE BEING PAID DURING HE TIME THE UNITS ARE NOT OCCUPIED. NONE OF RD'S PROGRAMS IDENTIFY EMERGENCY HOUSING AS AN ELIGIBLE OPTION.

Answer: Temporary and portable housing may be obtained through rental or lease arrangements.

IT IS DIFFICULT AT BEST, TO BUILD PERMANENT HOUSING FOR FARMWORKERS, HOW DOES AN AGENCY BUILD TEMPORARY AND EMERGENCY HOUSING WITH THE KNOWN COMMUNITY OBSTACLES: ZONING, THE NOT IN MY BACKYARD SYNDROME? WHERE DOES THE FUNDING COME FROM?

Answer: The SGA does not require building temporary or emergency Housing, or any new construction. The SGA emphasizes increasing the Availability of emergency and temporary housing for migratory farmworkers. While for some communities new construction may be a strategy to increase housing availability, another community may choose a strategy of renting or leasing existing housing units for use by migratory farmworkers in order to increase their access to housing.

WHAT IS DOL'S DEFINITION OF TEMPORARY AND EMERGENCY HOUSING?

Answer: For this solicitation, we intend for "temporary housing" to mean housing provided for a temporary requirement, such as housing for a migrant farm worker while he or she is working or traveling in the migration stream. We intend for "emergency housing" to primarily address situations where the absence of available or affordable housing has led to safety and sanitation concerns, especially if children are present. Such situations could arise at the farm worker's resident location as the result of lost earnings opportunities due to natural disasters or from other causes, including domestic relations causes.

PLEASE EXPLAIN RELATING HOUSING ASSISTANCE TO THE PROMOTION OF A FARMWORKER'S EMPLOYMENT? ARE WE EXPECTED TO DEVELOP AN INDIVIDUAL EMPLOYMENT PLAN TO ACCOMPLISH THIS?

Answer: The NFJP grantee would assist in the development of the Individual Employment Plan. Paragraph (d) of WIA Section 167 authorizes assistance related to workforce investment activities be provided "as needed by eligible migrant and seasonal farmworkers and identified pursuant to the" Program Plan required in Paragraph (c). Housing assistance Activities are among the types of authorized related assistance or supportive services. Paragraph (c) (2) (b) requires that grant plans describe the related assistance and supportive services to be provided and the manner in which such assistance and supportive services to be provided and the manner in which such assistance and services are to be integrated and coordinated with other appropriate services.

WHAT TYPE OF SERVICES DOES THE DEPARTMENT INTEND AS, "DIRECT INVESTMENTS IN HOUSING ASSISTANCE FOR MIGRANT AND SEASONAL FARMWORKERS AT THEIR HOME BASE"? CAN DOL PROVIDE ANY EXAMPLES? HOW IS "HOME BASE" IN THIS CONTEXT DEFINED?

Answer: Examples of direct investments in housing assistance are supportive housing services to a farm worker (which may include emergency assistance due to lost income from crop damage) and "housing development assistance" which is defined as "an organized program of education and on-site demonstrations about the basic elements of family housing and may include financing, site selection, permits and construction skills, leading towards home ownership." Home base is the community the migrant farmworker considers home. Typically, the home base is located in California, Texas, Florida and Gulf Coast areas.

LEVERAGING OTHER FUNDS FOR CONSTRUCTION AND/OR MAINTENANCE OF MULTI-FAMILY FARM LABOR HOUSING (SUCH AS USDA 514/516 PROJECTS) APPEARS TO BE AN UNALLOWABLE ACTIVITY BECAUSE USDA WILL NOT ALLOW OCCUPANCY RESTRICTIONS SOLELY FOR WIA 167 ELIGIBLE CUSTOMERS AND THE HOUSING IS, TECHNICALLY, A PERMANENT STRUCTURE INTENDED FOR TEMPORARY OR CONTINUOUS OCCUPANCY AS LONG AS THE OCCUPANTS ARE ENGAGED IN SEASONAL AGRICULTURAL LABOR AS THEIR PRIMARY OCCUPATION. IS THIS CORRECT?

Answer: The questions seems to imply that the only allowable leveraging Activities are those that benefit WIA 167 eligible migrants and seasonal Farmworkers solely. To clarify, these funds can be used to access other available housing assistance resources that are intended to finance temporary or emergency housing for use by WIA 167 eligible participants and others, as long as the increase in availability of housing increases the access of WIA 167 eligible participants to such housing.

A SURVEY IS INCLUDED IN THE SGA. IS IT REQUIRED TO BE COMPLETED AND SUBMITTED.

Answer: Yes