2002-3025:Wv Dxum~gmwCCowwv eA
ORDINANCE NO. oS 0a?-, OWA
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF DENTON, TEXAS,
APPROVING THE GUIDELINES FOR THE RENTAL REHABILITATION PROGRAM AND
ELIGIBILITY CRITERIA; AUTHORIZING EXPENDITURES IN EXCESS OF $25,000 FOR
PROJECTS MEETING PROGRAM GUIDELINES AND CRITERIA; AND PROVIDING FOR
AN EFFECTIVE DATE.
WHEREAS, the City Council of the City of Denton recognizes the need to assist low and
moderate income families in securing safe, sanitary and decent housing; and
WHEREAS, the City of Denton has developed a program to rehabilitate tenant occupied
housing units by making needed repairs through its Rental Rehabilitation Program, which is
administered by the City of Denton Community Development Office and funded through a federal
grant; NOW, THEREFORE,
THE COUNCIL OF THE CITY OF DENTON HEREBY ORDAINS:
SECTION 1. That the City Council approves the Rental Rehabilitation Program Guidelines
and eligibility criteria attached to and made a part of this ordinance for all purposes, and authorizes
the City of Denton Community Development to administer this program.
SECTION 2. That the City Council authorizes the expenditure of funds in excess of
$25,000 by the Community Development Office for projects meeting program guidelines and
criteria, subject to compliance with competitive bidding laws, where applicable.
SECTION 3. That this ordinance shall become effective immediately upon its passage and
approval.
PASSED AND APPROVED this the / ' day of &rMki , 2002.
cam, 94-r1k,
EULINE BROCK, MAYOR
ATTEST:
JENNIFER WALTERS, CITY SECRETARY
BY: 0z' O"y I -h' ,
APP VED J TO LEGAL FORM:
HERBERT L. PROUTY, CITY ATTORNEY
BY: /
u
CITY OF DENTON
RENTAL REHABILITATION PROGRAM
GUIDELINES
2002
RENTAL REHABILITATION PROGRAM GUIDELINES
TABLE OF CONTENTS
ELIGIBILITY REQUIREMENTS: 8
II. APPLICATION PROCESSING: 9
III PROJECT SELECTION ..................................................................................................9
IV. CONTRACTOR SELECTION, MONITORING AND DEBARMENT:
10
V. PAYMENT TO CONTRACTOR:
11
VI. FINANCIAL ASSISTANCE OPTIONS:
11
VII. PROGRAM GUIDELINES:
12
VIII. MINIMUM REHABILITATION STANDARDS:
16
APPENDIX I - FAIR MARKET RENTS (FMRS)........ _
21
APPENDIX II - RENTAL REHABILITATION PROCEDURES
22
APPENDIX III - APPLICATION FOR THE CITY OF DENTON
24
APPENDIX IV - TENANT ASSISTANCE POLICY
29
APPENDIX V - TENANT PRE NOTIFICATION SAMPLE LETTER
32
APPENDIX VI - RENTAL RERABR.rrATION TARGET AREA MAP
33
APPENDIX VII - TENANT BENEFICIARY INFORMATION TRACKING FORM
34
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INTRODUCTION
The City of Denton Rental Housing Rehabilitation Program is designed to assist low and moderate-
income families in securing safe, sanitary and decent housing. This program's objective is to rehabilitate
renter occupied housing units by making needed repairs with the first priority as correcting code
violations.
The Rental Rehabilitation Program is administered by the City of Denton's Community Development
Division and funded through a federal grant. The Community Development Division is located at 100 W.
Oak Street, Suite 208.
The following pages contain a detailed description of the program including policies and procedures.
The purpose of these guidelines is to explain to potential clients and the citizens of Denton, the Rental
Housing Rehabilitation Program and types of assistance available. For further information or clarification
of the guidelines, contact the Community Development Division at 940-349-7726
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DESCRIPTION OF PROGRAM PROCEDURES
ELIGIBILITY REQUIREMENTS:
A. Applicant/(Owner) Requirements: Eligible property owner(s) [hereinafter referred to as Applicant]
must:
1.) Be a citizen of the United States or a legal resident alien.
2.) Maintain primary residence within the city limits of Denton.
3.) Own unit(s) to be assisted within a targeted neighborhood (see Appendix VII).
4.) Hold fee simple title to the property.
5.) Have an annual gross household income at or below 150 percent of the current Dallas
metropolitan area median income. (See Table LA below).
6.) Not have assets in excess of $600,000 (rental properties, personal property, cash on hand,
stocks, bonds, etc.).
7.) Exhibit the financial ability to pay monthly property expenses including mortgage payments,
taxes, insurance, utility bills, etc.
8.) Show proof of financial ability to fund the Applicant portion of the rehab project.
9.) Provide proof that all property taxes assessed by the various taxing agencies in Denton
County are paid in full on all properties owned by Applicant.
10.) Obtain a statement of income on all tenants. Income data must be verified; i.e., by contacting
the tenant's employer and/or obtaining a copy of the tenant's latest income tax return and/or
obtaining copies of 1 month of paycheck stubs, etc. Annual income includes earnings (wages,
pensions, etc.) spouse's earnings, interest from stocks, bonds, income from real estate, public
assistance, etc. Also, include amounts of any monies regularly contributed to tenant(s) by any
other adult member of the family, child support payments, SSI, etc.
B. Tenant Requirements: The current and future tenants of a unit to be rehabilitated with funding from
this program must be low or moderate income. Low/ Moderate income is defined as 80 percent
and below of the current Dallas metropolitan area median income. (See Table I.B below)
Table IA-Applicant Income Limits Table I.8 -Tenant Income Limits
Household Size
Maximum Owner Income
1
69,900
2
79,800
3
89,850
4
99,750
5
107,700
6
115,650
7
123,750
8
131,700
Household Size
Maximum Tenant Income
1
$37,250
2
$42,550
3
$47,900
4
$53,200
5
$57,450
6
$61,700
7
$65,950
8
$70,200
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II. APPLICATION PROCESSING:
Any property owners wishing to apply for Rental Rehabilitation assistance must complete the application
and all other required forms included in the proposal packet. All information on the completed
applications will be verified by the Community Development staff. If any information is found to have
been intentionally falsified, the application will be rejected and the applicant will not be allowed to
reapply. If the applicant is determined to be eligible for the program, a preliminary inspection will be
made of the dwelling unit(s). The dwelling unit(s) must meet certain standards to be considered eligible
for rehabilitation. These standards are listed below:
• The unit(s) must be located within the recognized Rental Rehabilitation Target Area
(Appendix VII).
The unit(s) must not be situated in the Designated Flood Plain Area.
Applicant may not occupy any assisted unit regardless of his or her income with the
exception of the circumstances set forth in Section VII-FF on page 15 of these
Guidelines.
The unit(s) must be in an existing condition that would permit rehabilitation to bring the
structure to meet current City of Denton building codes.
City-approved water supply, sanitary sewer and electrical system must service the
unit(s).
• The unit(s) must be two bedroom or larger. Preference will go to three bedroom and
four bedroom units.
• Owner must agree to have a Lead Paint Risk Assessment completed on all units to be
assisted that were built before 1978 (a "hold harmless" agreement must be signed by
owner before City staff can conduct the Lead Risk Assessment).
III PROJECT SELECTION
Project selection will be based upon an analysis of the following factors:
• Location of unit(s).
• Number of bedrooms.
• Owner's ability to obtain private financing.
• Number and extent of major health and safety violations to be corrected.
• Tenant displacement (preference given to no displacement)
• Economic feasibility
• Amount of subsidy required
• Owner's Equity in property
• Potential impact on neighborhood
• Track record of landlord in low income tenant placement
• Management and maintenance capabilities
• Quality of rehabilitation plan
• Accessibility or adaptability of unit(s) for handicapped tenants
• Commitment by landlord to and/or likelihood of low income tenant placement
• Assisted wit(s) must be available for rental, or currently rented to low income
household(s).
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IV. CONTRACTOR SELECTION, MONITORING AND DEBARMENT:
A. Contractors participating in the Rental Rehabilitation Program will be selected by the eligible
Applicant. The Applicant will be required to solicit at least two bids from contractors based on the
preliminary work specifications completed by the CD inspector. The Applicant shall also be
responsible for supplying all bidders with a Community Development Contractor's Packet that
includes the contractor information sheet, performance manual, and general specifications for
workmanship, all insurance and bonding requirements, a contractor's eligibility certification form
and a copy of the preliminary work write-up. Bid proposals and all other required forms from the
contractors should be submitted to Community Development Division for review.
B. Acceptable bid proposals must fall within a ten percent (10%) margin of the cost estimate
developed by the community development inspector. THE CITY OF DENTON AND/OR THE
APPLICANT RESERVE THE RIGHT TO REJECT ANY AND ALL BIDS. Any contractor whose
name appears on the most current HUD Debarred Contractors List will not be eligible to
participate in this program.
C. Once the contractor has been selected and approved, a contract agreement must be signed.
Before the contractor can start work, the Applicant must issue a notice to proceed.
D. The Applicant, the Community Development staff and the City of Denton building code
inspectors will monitor the contractors work. If the Applicant considers any work done by the
contractor to be unsatisfactory or incomplete, the property owner should advise the contractor of
the discrepancy and ask that it be corrected.
E. Acceptance of Work
1.) Final Inspection - In order for the contractor to close out a rehabilitation job, a final
inspection shall be made by the City of Denton building code inspector, the Community
Development Inspector, and the property owner. If the final inspection results in no
additional work or no specked corrections, the property owner shall sign the contractor's
release form which states that all work has been completed to their (property owner's)
satisfaction. The building code inspector shall sign a final inspection form to confirm the
same. At this time, the contractor is required to submit to the property owner copies of all
warranties and releases of liens from subcontractors and suppliers. The Community
Development staff will not authorize payment to the contractor until these documents are
properly completed and submitted to the property owner and copies provided to the
Community Development Division.
2.) Warranty of Work - As stated in the rehabilitation contract, the contractor shall guarantee
the work performed for a period of at least one year from the date of final acceptance. The
owner is responsible for periodic review of the work.
Contractor Debarment
1.) A contractor will be declared ineligible to participate in projects funded by the City of
Denton's Housing Rehabilitation Program for one or more of the following causes:
2.) Failure to complete a project within the prescribed contract period.
3.) Failure to complete warranty repairs within a reasonable time period.
4.) Failure to use licensed plumbing and electrical subcontractors.
5.) Failure to obtain proper insurance, i.e., both liability and worker's compensation.
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6.) Failure to complete work in accordance with program specifications and/or accepted
standards of workmanship.
7.) Failure to pay all subcontractors working on the project appropriately and/or submit
affidavits of payment signed by all subcontractors.
8.) Failure to obtain proper permits for work in progress.
G. Contractors will be notified of their proposed debarment and will be afforded the opportunity to
comment or appeal the action. Ali appeals must be made in writing to the Community
Development Division at least 15 days after the date of the notification letter.
V. PAYMENT TO CONTRACTOR:
A. The contractor shall receive payment for all completed contracts within 15 working days after
final inspection and approval of all work. Ten percent (10%) of the total contract amount will be
withheld for 30 days. At the end of this time, the property owner must approve release of
contingency funds.
B. An "All Bills Paid" affidavit or release of lien from all subcontractors and suppliers must be
submitted before payment. Rental rehabilitation partial payment minimum are as follows:
projects over 50,000 at least 10% per draw, projects under 50,000 50% and final payment.
VI. FINANCIAL ASSISTANCE OPTIONS:
Applicant is provided with two assistance options:
Option 1: The City of Denton will provide 25 percent (or up to the maximum limit-whichever is lower) of
the amount needed to rehabilitate the property. Funds will be provided as a 10-year deferred loan. At
the end of the 10-year period, if all program guidelines have been met, the loan will be forgiven.
Option 1 Maximum Limits:
$6,000 for three or more bedroom units.
$5,000 for two bedroom units.
(One-bedroom units are not eligible for assistance.)
Option 2: The City of Denton will provide 50 percent (or up to the maximum limit-whichever is lower)
of the amount needed to rehabilitate the property. The first 25 percent will be a deferred loan (as
described in option 1 above). An additional amount of 25 percent (or up to the maximum limit -
whichever is lower) will be a loan with a 2 percent interest rate. There will be a 10-year loan term.
Option 2 Maximum Limits:
$6,000 as a loan and $6,000 as a deferred loan for three or more bedroom units.
$5,000 as a loan and $5,000 as a deferred loan for two bedroom units.
(One-bedroom units are not eligible for assistance.)
Applicants are required to sign a contract. A lien will be placed on the property for the 10-year period.
Applicants are required to maintain the property and affirmatively market the property to low and
moderate-income households.
* All project funding contributed by the Applicant will be placed in an escrow account with the City
of Denton prior to contract execution.
The owner must also comply with the terms of the note and mortgage that include the following:
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No conversion to condominiums or any, type of cooperative ownership for the 10-year duration of the
lien.
No discrimination against tenants receiving Federal, State or local rental assistance for the 10-year
duration of the lien.
The project must be maintained according to adopted City of Denton building codes in effect during the
year in which the rehabilitation took place.
The owner must affirmatively market vacant units for the ten-year duration of the lien using the "fair
housing logo" below.
EQUAL HOUSING
OPPORTUNITY
The unit will be made available and leased to persons whose income is at or less than 80% of the area
median income.
If the Applicant violate any of these restrictions, the entire amount of the loan less 10% for each full year
after completion of the rehabilitation of the units until the time of default, will be due and payable in full
immediately after the owner is notified that the loan must be repaid.
VII. PROGRAM GUIDELINES:
A. Property owner agrees to comply with all HUD requirements to not discriminate upon the basis of
race, ethnicity, religion, gender, disability status or family status in the sale, lease, rental, or use
of occupancy of the subject property.
B. Property owner agrees to not award any contract for rehabilitation work to be paid for in whole or
in part with the proceeds of the grant, to any contractor who, at the time, is ineligible under the
provisions of any applicable regulations issued by the Secretary of Labor, United States
Department of Labor, or the Department of Housing and Urban Development to receive an
award of such contract.
C. The tenant will continue to occupy the premises during the rehabilitation. Any tenant required to
move temporarily or permanently as a result of the rehabilitation*, must be paid
relocation/displacement costs as outlined in the City's Tenant Assistance Policy (Appendix IV to
these Guidelines).
*Any displacement of tenant(s) living in unit(s) at the time applicant decided to apply for funding who
move because of their inability to pay increased rents, are considered displaced. Displacement
costs are the responsibility of the property owner.
D. Property owner agrees that existing house utility services will be made available to the contractor
without charge as follows: electricity, gas, water and telephone (local calls only).
E. Property owner agrees that the City shall be the agent for the owner and as such agent shall
hold both the owner's private funds and all grant funds in escrow for the purpose of
disbursement thereof to the contractor.
F. Property owner agrees that it is his/her sole responsibility to see that the contractor completes
the work specified in his contract to the owner's satisfaction and that the City of Denton has no
responsibility for any defects, faulty work or incomplete work by the contractor. The owner
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further agrees that the City has,no liability for warranty of any of the workmanship or materials
furnished by the contractor und6r the contract. The owner further agrees that latent or hidden
conditions in the property which were not included in the original inspection and work write-up of
the City are not the responsibility of the contractor nor of the City, but remain the responsibility of
the owner.
G. As part of the consideration for providing the funds to rehabilitate property as described herein,
the property owner agrees to maintain and keep the property in good repair after the completion
of the work to be performed by contractor, taking into consideration the ability of the owner to do
so. The property owner also agrees to maintain the property up to City of Denton Building Code
standards that were in effect when the rehabilitation was completed. Owner agrees to do this
during the term of the loan agreement and understands that if at anytime the property fails to
meet these Code standards, the loan amount will become due immediately.
H. The owner shall issue a written Notice to Proceed within thirty (30) days from the date of
acceptance of the contractor's bid and proposal. If the contractor does not receive the Notice to
Proceed within this 30-day period, the contractor has the option of withdrawing his/her bid and
proposal. If the contractor chooses to do this, a written notice must be delivered to the owner
with a copy to the City. The contractor shall not begin the work to be performed until receipt of
written Notice to Proceed from the owner after which the contractor shall begin the work within
ten (10) calendar days of the date of said Notice and shall complete said work within ninety (90)
days or as agreed to in the Rehabilitation contract.
The contractor shall not assign the contract without written consent of the owner and the City
and/or its agent.
J. The contractor shall not be responsible for any delays in the completion of work due to the
following:
1.) Any acts of the government; including controls or restrictions upon or requisitioning of
materials, equipment, tools or labor by reason of war, National Defense or any other
national emergency.
2.) Any acts of the owner.
3.) Causes not reasonably foreseeable by the parties to this contract at the time of the
execution of the contract which are beyond the control and without the fault or negligence
of the contractor; including but not limited to acts of God or of the public enemy; acts of
another contractor in the performance of some other contract with the owner, fires, floods,
epidemics, quarantine restrictions, strikes, freight embargoes and weather of unusual
severity such as hurricanes, tornadoes, etc.
4.) Any delay of the subcontractor occasioned by any of the causes specified in
Subparagraphs (A) (B) and (C) above, provided that the contractor promptly (within 10
days) notifies the Owner in writing of the cause of the delay. If the facts show the delay to
be properly excusable, the owner shall extend the contract time by a period
commensurate with the period of excusable delay.
K. The contractor shall not be held responsible for preexisting violations of law including but not
restricted to zoning or building code regulations at the property listed in the contract. Before
beginning work, the contractor shall examine the work write-up for compliance with the
applicable ordinance and codes for the new or replaced work and shall immediately report any
discrepancy to the owner. Where the requirements of the work write-up fail to comply with such
applicable ordinances or codes for the new or replaced work, the owner and the City will adjust
the contract by change order to conform to such ordinances or code and make appropriate
adjustment in the contract price unless waivers in writing covering the difference have been
granted by the proper authority.
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L. The contractor shall comply with all non-discrimination clauses included in the contract;
non-compliance may result in termination of the contract.
M. Bids or proposals will be submitted at the bidder's risk and the City and/or the owner reserve the
right to decline funding for projects not in compliance with the guidelines.
N. Subcontractors shall be bound by.the terms and conditions of the contract, insofar as it applies to
their work. This shall not relieve the general contractor from the full responsibility to the owner for
the completion of all work to be executed under this agreement and he shall not be released
from this responsibility by any subcontractual agreement he may make with others.
0. When adjacent property is affected or endangered by any work done under this contract, it shall
be the responsibility of the contractor to take whatever steps are necessary for the protection of
the adjacent property and to notify the owner thereof of such hazards.
P. Repairs shall be made to all surfaces damaged by the contractor resulting from his/her work
under this contract at no additional cost to the owner. Where "repair of existing work" is called for
by the contract, the feature shall be placed in "equal to new condition" either by patching or
replacement. Al damaged, loose or rotted parts shall be removed and replaced and the finished
work shall match adjacent work in design and dimension.
Q. After the final inspection and acceptance by the owner of all work under the contract including
cleanup, the contractor shall submit to the owner for approval a requisition for payment. When
the required warranties and other required documents have been submitted and the contractor
has executed the release of liens, the final payment will be made. The payment will include any
amounts remaining due under the contract as adjusted in accordance with approved change
orders. Payments will be made within 15 days of formal requisition for payment. Partial
payments will be made at discretion of the owner with the consent of the City.
R. A Rehabilitation Loan may be made to cover the cost necessary to bring the dwelling into
conformance with City of Denton Codes. The two categories of repairs listed below are to be
included as priority items:
1.) Required Repairs: Code violations which create hazardous conditions in regard to safety
or health will generally involve the basic heating, plumbing or electrical systems.
2.) Recommended Repairs: Code corrections or preventive maintenance efforts which
should be undertaken to avoid more costly future action.
3.) Heating, plumbing and electrical improvements
4.) Weatherization
5.) Exterior work such as roofing, siding, painting, step and porch repair and retaining walls
6.) Interior work such as renovation and repair of existing kitchen and bath facilities.
S. The Denton Central Appraisal District automatically reappraises any house where a building
permit is issued. Participants in the Rehabilitation Program should be aware that the appraised
value of their property might increase which consequently may cause their yearly property taxes
to increase. The policy shall be thoroughly explained to any person applying for rehabilitation
assistance.
T. Change orders may be made to cover an item of work that cannot be determined until sometime
during the course of the rehabilitation work. Change orders will be considered as follows:
1.) Change orders are used to add work necessary to correct incipient items that have been
found to be defective after work is in progress but were not anticipated at the time the
contract was executed.
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2.) The change order amount is limited to a maximum of 10 percent (10%) of the total
contract amount. If it is necessary to request a change order to make required repairs and
the contract is already at the maximum amount, a work item of less priority will be deleted
from the bid proposal in order to compensate for the added amount.
3.) Change orders will be used when it is necessary to delete work from a contract for any
reason. When items are deleted from the contract, they shall be at their previously bid
amount. When items are deleted, but do not have specific costs, in such cases the
contract shall be reduced by negotiating the cost at prevailing rates.
4.) All change orders shall be executed by the property owner, contractor, and a Community
Development official.
5.) Except for the purpose of affording protection against any emergency endangering fife or
property, the Contractor shall make no change in the work or rehabilitation, provide any
extra or additional work or supply additional labor, services or materials beyond that
actually required for the execution of the contract.
6.) All change order requests must be submitted by the contractor, signed by the homeowner
and approved by Community Development Division. No claim for an adjustment of the
contract price by the contractor or homeowner will be valid unless this is done.
7.) The approval of a change order shall constitute authorization by the property owner and
Community Development to change the loan amount equal to the cost of the work added
or deleted, unless all available funds have been utilized. If this is the case, the owner must
absorb the total cost or delete non-code items in order to pay for the work described in the
change order.
8.) It may be necessary to change the time of completion due to the addition of certain work
items or delays that are beyond the contractor's control.
U If the work completed is not in accordance with the construction contract, Community
Development shall advise the property owner of the non-compliance who then shall obtain
appropriate action from the contractor. No payment shall be processed on a construction
contract until a contractor has satisfactorily completed all necessary corrective action.
V. The owner shall be able to select the color and style of certain materials (i.e. carpet, floor
covering, paneling, paint, etc.).
W. The contractor warrants that all materials, fixtures, and equipment furnished by the contractor
and its subcontractors shall be new, of good title and that the work will be done in a neat and
workmanlike manner. Neither the final payment nor any provision in the contract nor partial or
entire use or occupancy of the premises by the owner shall constitute an acceptance of work not
done in accordance with the Contract or relieve the Contractor of liability in respect to any
express warranties or responsibility for faulty materials or workmanship. The contractor shall
promptly remedy any defect in the work and pay for any damage to other work resulting
therefrom that may appear within a period of one year from the date of final acceptance of the
work unless a longer period is specified. The owner will give notice of observed defects with
reasonable promptness.
X. Mobile homes are not eligible for rehabilitation.
Y. Interest of certain federal and other officials:
1.) No member or Delegate to the Congress of the United States and no Resident
Commissioner and no federal employee shall be admitted to any share or part of this
contract or to any benefit to arise from same.
1s
2.) No member of the governing body of the City and no other public official of or within the
City or County who exercises any functions or responsibilities in connection with the
administration of the Community Development Block Grant Program and no other
employee of the Economic Development Department who exercises any such functions or
responsibilities shall have any interest, direct or indirect, in rehabilitation proceeds which is
incompatible or in conflict with the discharge or fulfillment of his functions and
responsibilities in connection with the carrying out of the Housing Rehabilitation Program.
The length of time this exclusion shall be in effect is one (1) year following the ending of
term of office and shall be binding upon, but not limited to, all of the individuals and
agencies herein described.
Z.. The property owner agrees that for a period of ten years after the project is completed not to
convert the rehabilitated units to condominium ownership. If the owner does convert
rehabilitated units to condominium ownership, the entire loan amount shall be due immediately.
AA. The property owner agrees not to discriminate against prospective tenants on the basis of their
receipt of or eligibility for, housing assistance under any Federal, State or local housing
assistance program; on the basis that the tenants have a minor child who will be residing with
them; or on the basis that they are handicapped.
BB. Applicant agrees to rent all assisted units to households whose total gross annual income is at
or below 80 percent of the area median income found in Table I.B, page 7 of these guidelines
(see "note" below). Applicant agrees to track tenant income and beneficiary data (See
Appendix VII -Tenant Income and Beneficiary Tracking Form). This form is to be made
available to the Community Development Division when requested. The Form is to be
completed at the time assisted units are leased. (NOTE: Income Limits may change annually -
usually on October 1 s`. It is the Applicant's responsibility to request a copy of the most current
income limits from the Community Development Division.)
CC. The property owner agrees to maintain the rehabilitated property up to adopted City of Denton
Building Code Standards in effect the year in which the rehabilitation was completed. This will be
applicable for a period of at least ten years after the project is completed.
DD. The property owner agrees to comply with applicable lead-based paint regulations.
EE. The property owner agrees to comply with the City of Denton's Tenant Assistance Policy,
including execution of all tenant notifications outlined in the policy. Copies of all tenant
correspondence regarding this project must be submitted to the Community Development
Division.
FF. When the property to be rehabilitated is a td- or four-plex, and the owner/applicant meets the
income limits for tenants (see Table I.B on page 7 of these guidelines), the owner/applicant is
eligible to occupy one of the assisted units.
VIII. MINIMUM REHABILITATION STANDARDS:
Roofs
Roofs should not leak and have no evidence of rotted decking, fascia or soffit. Any roof with two or more
layers of roofing must be stripped to the decking. If it is determined a new roof is necessary the decking
must be checked for broken or rotted decking and shall be repaired or replaced as needed. Where new
decking is required the material shall be one-half inch plywood or one-half inch wafer board to be used
with H clips between sheets. All roofs that are stripped shall be replaced with new felt paper, the proper
flashing and metal drip edge with 240 pound shingles. Any roof with less than a 4/12 pitch shall be
covered with rolled roofing, with at least 12 inches of lap, if installation of rolled roofing is not sufficient to
promote proper run off roof will be rebuilt.
Siding and Trim
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All exterior siding and trim shall be free;of holes, cracks or rotted material that might admit moisture into
walls. New siding may be applied only if the cost of new siding and installation is comparable to the
repair and painting costs of the existing siding.
Windows
All windows and hardware shall operate satisfactorily. Cracked or broken windows shall be replaced.
Window glazing shall be weather tight and windows shall be weather stripped so as not to allow entry of
air and water around the glass, sashes or window casings. All windows shall have screens and working
locks.
Drainage
The grade of concrete or dirt should drain at least five feet away from foundation walls.
Site Improvements
All replaced concrete surfaces are to be level with the widths to match the existing surfaces.
All steps both concrete or wood that pose a threat to the occupants shall be repaired or, if necessary,
replaced with treated material or concrete.
Foundations and Piers
Skirting shall be six (6) inches underground level. If it is necessary to install skirting, new 22 or 24 gauge
skirting shall be used.
Kitchens
Kitchens shall have a specific area that contains a sink with hot and cold running water, counter
workspace, and space for storage of cooking utensils.
Stairs
All stairs shall provide for the safety of ascent and descent. All treads and risers should show no
evidence of breakage or have evidence of excessive wear. All stairs shall be equipped with handrails.
Utility Areas
Gas or oil fired water heaters or furnaces shall not be located in the bathrooms or bedrooms. In addition
to all plumbing and electrical codes, water heaters and furnaces shall be enclosed with a sealed door
and adequate upper and lower combustion air. All washer and dryer hookups must meet City Code.
Structural System
The wood, masonry or steel components shall be in serviceable condition for the expected useful life of
the rehabilitated building. Structural members that are in seriously deteriorated condition shall be
replaced.
Sagging and unleveled floors shall be raised and stabilized as level as possible without causing interior
damage.
Termite inspection and treatment shall be done if evidence of active infestations exist. A certified pest
control company will carry out the treatment and present documents of proof.
Electrical System
17
All replacement of existing wiring and equipment shall be done in conformance with the National Electric
Code and the City of Denton Code. And potential source of electrical hazard or ignition of combustible
material shall be corrected.
GFCI outlets shall be used in bathrooms, kitchen, garage, and exterior receptacles. Additional outlets
shall be added to eliminate extension cords and, at the request of the City Inspector, to meet City Codes.
Plumbing
The plumbing system shall operate free of fouling and clogging, and not have cross-connections which
permit contamination of the water supply or back siphonage between fixtures.
All sinks, lavatories, water closets, water heater, and other plumbing fixtures shall have accessible cutoff
valves. All fixtures shall have P-traps, necessary vents and be properly connected to a public or private
sewage disposal system. All sewer lines shall have accessible cleanouts. All water heaters shall be
installed with double wall vent stack, a pop-off valve, and overflow to the exterior of the structure.
Mechanical Equipment
All gas fired heating units must be vented with double wall pipe and proper upper and lower combustion
air. The unit shall not be installed in a living area such as bedrooms or under stairways.
Rigid gas pipe must be used to supply heating units with a maximum of three (3) feet of flexible pipe
from the stop to the appliance. All ductwork shall be properly sealed from the heat source to the register
vent and from the return air supply to the heat source. A gas pipe pressure test is required. All leaks
must be repaired.
Insulation and Weatherization
An "R-30" insulation value in the attic shall be required.
Exterior Doors
All exterior doors shall be solid core. All locks shall be capable of tightly securing the door and shall be
readily operable from the inside without the use of keys. All exterior doors shall be weather stripped so
that there is no significant entry of air or water into the structure.
Porches and Decks
All porches and decks shall be safe and capable of supporting anticipated loads. All porches and decks
in deteriorated condition and which serve no useful purpose or which are not economically repairable
shall be removed.
Porches and decks 30 inches above grade shall have guardrails and flights of stairs with four or more
risers. They shall have a handrail on at least one side.
Gutters and Downspouts
Gutters and downspouts should exist where they are deemed necessary to promote proper drainage.
Gutters will not normally be installed if they do not already exist.
Downspouts that cannot be connected to drain tiles shall have splash backs with proper site grading.
Chimneys and Vents
Furnace and water heater vents shall be double wall vent pipe.
Existing unlined masonry chimneys having open mortar joints or cracks shall be removed or made safe
by installation of a UL approved flue liner.
18
Vent-a-hood stacks shall be vented through the roof.
Interiors
All floors, walls, and ceilings shall be maintained in good, clean, and sanitary condition. All peeling paint,
cracked or loose plaster, and other defective surface conditions shall be eliminated. All doors shall be
operational.
Carpet and vinyl that is badly wom, tom or too dirty to be cleaned shall be replaced. This shall be
determined by the C.D. Inspector. Existing carpet shall be cleaned with a commercial steam cleaner, if
necessary.
Bathrooms
An operational water closet, tub or shower, and lavatory should be in the bathroom. Hot water should
flow to the lavatory and tub or shower. Cold water should be supplied to all fixtures. Either a window or
an exhaust fan must be present to properly vent the bathroom.
Cabinets
Built-in kitchen cabinets shall be repaired up to 50 percent of the cost of new cabinets. Bathroom
cabinets are not required.
ALL WORK MUST COMPLY WITH HUD TITLE X REGULATIONS REGARDING LEAD - BASED
PAINT. BY APPLYING FOR CDBG FUNDS, OWNER/APPLICANT UNDERSTANDS THE CITY
MUST COMPLETE A LEAD RISK ASSESSMENT TO DETERMINE THE SCOPE OF WORK AND
COST ESTIMATE ON PROPERTIES BUILT BEFORE 1978. FOR PROPERTIES BUILT BEFORE
1978, OWNER / APPLICANT MUST EXECUTE AN ACKNOWLEDGEMENT AND RELEASE OF
LIABILITY FOR LEAD PAINT TESTING OF PROPERTY.
19
20
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Page 21
APPENDIX II - RENTAL REHABILITATION PROCEDURES
The following list of procedures is designed to insure that property owners understand their
responsibilities under the Rental Rehabilitation Program. Please call the Community Development
Division at (940) 349-7726 if you have any questions regarding these procedures.
1.) Return completed application. Include a copy of property deed, tax receipts from all
taxing entities, proof of insurance coverage on the property and documentation of all
owner(s) income and assets*.
2.) A set of work specifications must be drawn up by the owner and approved by the
Community Development Division.
3.) The owner of the proposed property will bear the responsibility of contacting at least
two general contractors, who will submit bid proposals. These proposals must remain
within a margin of ten percent of the estimate determined by the Community
Development Division.
4.) Upon project approval, a title search must be submitted.
5.) Certification that all tenants have received timely written notice that they will not be
displaced by the project must be submitted within two weeks of application
submission. A copy of the City of Denton's Tenant Assistance Policy must
accompany the notice to the tenant.
6.) Requests for all interim and final payments should include an itemized list of
completed work and its cost and two "Requests for Payment" signed by both the
property owner and the contractor. IT IS THE CONTRACTOR'S RESPONSIBILITY
TO FILE ALL NECESSARY PAPERWORK WITH COMMUNITY DEVELOPMENT
DIVISION
7.) A final inspection must be completed by Community Development Division.
8.) Final payment is contingent on receipt of the following by Community Development:
a) signed affidavits from all subcontractors stating that they have received full
payment
b) affidavit from general contractor and signature on lien assignment
c) two executed requests for payment
*Documentation of income sources may include but is not limited to the following:
Current year's income tax Return with W-2's for each household member who has
filed tax returns.
APPENDIX II
PAGE 22
• Most current Social Security income statement if applicable.
• Paycheck stubs for last four weeks for each employed household member.
• Names and addresses of all retirement income or any other income sources (ALL
INCOME SOURCES AND ASSETS MUST BE DISCLOSED--RETIREMENT,
RENTAL HAP INCOME, AFDC, FOOD STAMPS, PROPERTIES OWNED, ETC.)
• Divorce decree if you receive child/other support from a divorce or if you were
awarded property through a divorce.
• Name, address, account number(s) of all banks, credit unions, savings banks, IRA
accounts, etc. for all household members who have any such accounts.
APPENDIX II
PAGE23
APPENDIX III -APPLICATION FOR THE CITY OF DENTON
RENTAL. HOUSING REHABILITATION PROGRAM
OWNER PROPOSAL FORM
CONTACT AGENCY: COMMUNITY DEVELOPMENT DIVISION
100 W. OAK, SUITE 208
DENTON, TX 76201
TELEPHONE NO. (940) 349-7726
PLEASE COMPLETE ALL SECTIONS OF THIS OWNER PROPOSAL FORM.
IF YOU NEED ASSISTANCE IN COMPLETING THE FORM, CONTACT THE
AGENCY LISTED ABOVE.
SECTION I: OWNERSHIP DATA
A.COMPLETE THE INFORMATION BELOW FOR ALL OWNERS OF THE PROPOSED PROPERTY.
NAME
STREET
ADDRESS
CITY
STATE
ZIP
(AC)
Phone #
B. TYPE OF OWNERSHIP (check one):
❑ (a) Sole Owner
❑ (c) Corporation
❑ (e) Other:
C. PROPERTY ADDRESS:
D. BUILDING DESCRIPTION
❑ (b) Partnership
❑ (d) Limited Partnership
No.
Street Unit No(s).
City
APPENDIX III
PAGE 24
1
❑ Single Family ❑ Duplex ❑ Tri-Plex ❑ Four-Plex
E. BUILDING STRUCTURE
❑ Frame ❑ Brick ❑ Masonry ❑ Other:
F. FOR EACH UNIT IN THE PROJECT PLEASE PROVIDE THE INFORMATION REQUESTED IN THE
FOLLOWING TABLES.
The following information must be provided on all existing tenants. Applications will not be processed until all tenant information is
received.
Tenant's Name
Curren
Rent
Apt.
No.
No.
Occupants
Over
65
Ethnic
Code
*FEM
HHH
Handi-
Capped
Section
8
Income
..vin. mr me more mo ve, use me muowmg canes:
Ethnic Codes: 1 - White 2 - Black 3 - Amer. Indian/Alaskan Native
4 - Asian Pacific Islander 5 - Hispanic 6 - Other
* Please note a female head-of-household is a single female with dependent children.
Section 8 recipient Codes: C - Certificate V - Voucher N - None
A. NOTE: PROVIDE INFORMATION FOR ALL UNITS
UNIT NUMBER
NUMBER OF BEDROOMS, EXISTING
NUMBER OF BEDROOMS, AFTER REHABILITATION
CURRENT RENT
PROJECTED RENT AFTER REHABILITATION
UNIT OCCUPIED (O) OR VACANT
SECTION II: PROPERTY DATA
B. ORIGINAL MORTGAGE
APPENDIX III
PAGE 25
Orig.'Amount Mortgagee Balance
C. OTHER LIENS
Amounts Lien Holder Total Due
D. ORIGINAL PURCHASE PRICE
E. DATE OF PURCHASE
F. ESTIMATED MARKET VALUE OF PROPERTY (Attach recent appraisal)
G. DOLLAR AMOUNT OF RECENT CAPITAL IMPROVEMENTS
DESCRIBE IMPROVEMENTS BELOW:
H. AMOUNT OF INSURANCE COVERAGE
1. NAME OF INSURANCE COMPANY (Attach copy of policy)
J. AMOUNT OF RENTAL REHABILITATION FUNDS REQUESTED FROM CITY
K. FINANCING OF OTHER REHABILITATION COSTS NOT COVERED BY THE RENTAL REHABILITATION PROGRAM
1. AMOUNT OF ESTIMATED OWNER COSTS FOR REHABILITATION TO BE PAID FROM OWNER'S FUNDS
(EQUITY):
2. AMOUNT TO BE BORROWED FROM PRIVATE LENDING INSTITUTION:
NAME OF LENDING INSTITUTION:
3. ANTICIPATED INTEREST RATE AND LOAN PERIOD: % for years
APPENDIX III
PAGE 26
SECTION III: PROPERTY OWNER INCOME DATA
Note: Owner income eligibility is based on household income which includes the income of all worldng members of the
household. If the property is owned by a partnership or corporation, all partners and/or principals must be income
eligible.
Please list all income amounts below and provide documentation of each income source. (To be completed by all households with
ownership in the property.)
Income Type
Owner
Household
Member
#1
Household
Member #2
(please attach
additional sheet if
needed)
Total
Salary
Overtime pay
Fees/tips
Commissions/bonuses
Interest and/or dividends
Net income from business
Net rental income
Social Security, pensions
retirement
Unemployment benefits, workers
compensation, etc.
Alimony, child support
Welfare pymts, AFDC, food
stamps, etc.
Assets
Checking accounts
Savings/CD accounts
Stocks, bond, etc.
Rental property income
Value of private residence
Life Insurance
Other
APPENDIX III
PAGE27
SECTION IV: CERTIFICATION
THE OWNER/CO-OWNER CERTIFIES: (1) THAT HE/SHE HAS READ THE RENTAL
REHABILITATION PROGRAM GUIDELINES AND UNDERSTANDS THE PROCEDURES AND
REGULATIONS DESCRIBED THEREIN; (2) THAT HE/SHE AGREES TO ABIDE BY THOSE
PROCEDURES, REGULATIONS, AND CONDITIONS; AND (3) THAT THE INFORMATION
CONTAINED IN THIS APPLICATION AND PROPOSAL IS TRUE, CORRECT, AND COMPLETE.
THE APPLICANT AGREES NOT TO DISCRIMINATE UPON THE BASIS OF RACE, AGE,
GENDER, DISABILITY, FAMILY STATUS, CREED OR NATIONAL ORIGIN IN THE SALE,
LEASE, RENTAL, USE, OR OCCUPANCY OF THE REAL PROPERTY REHABILITATED WITH
ASSISTANCE FROM THE RENTAL REHABILITATION PROGRAM.
VERIFICATION OF ANY OF THE INFORMATION CONTAINED IN THIS APPLICATION MAY BE
OBTAINED FROM ANY SOURCE NAMED HEREIN.
THE APPLICANT CERTIFIES THAT HE/SHE HAS NOT REQUIRED ANY TENANT TO MOVE
WITHOUT CAUSE, SUCH AS VIOLATION OF THE LEASE OR LOCAL LAW DURING THE 12
MONTHS PREVIOUS TO THE DATE OF THIS APPLICATION.
Owner's Signature Social Security Number
Date
Co-Owner's Signature Social Security Number
Date
ITEMS TO INCLUDE WITH THIS APPLICATION:
1. A COPY OF THE DEED.
2. PICTURE(S) OF THE BUILDING AND, IF AVAILABLE, PICTURES OF THE INSIDE OF THE UNIT(S).
3. PROOF THAT PROPERTY TAXES AND ALL UTILITIES ARE PAID IN FULL. INCLUDE A RECENT
TAX STATEMENT SHOWING PROPERTY VALUE.
4. DOCUMENTATION OF OPERATING EXPENSES, TAXES AND INSURANCE.
5. SIGNED LETTER FROM ALL EXISTING TENANTS STATING THEY HAVE RECEIVED A COPY OF
THE TENANT ASSISTANCE POLICY AND UNDERSTAND THEIR RIGHTS ACCORDING TO THE
POLICY. A COPY OF THE POLICY AND A SAMPLE LETTER ARE ATTACHED.
6. INCOME DOCUMENTATION and COMPLETED AND SIGNED INCOME VERIFICATION FORMS.
APPENDIX III
PAGE 28
Community Development
Division
I&Lm
APPENDIX IV -TENANT ASSISTANCE POLICY
Rental Rehabilitation Program
Introduction
The regulations for the Rental Rehabilitation Program (24 CFR 511.10(h) require grantees to adopt a written
Tenant Assistance Policy. The purpose of the Tenant Assistance Policy is for the grantee to articulate how it will
assist tenants currently living in or moving into projects rehabilitated under its Rental Rehabilitation Program.
City of Denton residents have been made aware that the policy exists and that the policy is available to tenants
in projects selected for rehabilitation.
Definition of Displacement
The term "displaced person" means any person that moves from real property, or moves personal
property from real property, permanently and involuntary as direct result of rehabilitation, demolition or
acquisition for a Rental Rehabilitation Program project. Permanent, involuntary moves for a Rental
Rehabilitation Program project include:
A. A permanent move from the real property following notice by the property owner to move
permanently from the property, if the move occurs on or after the date that the owner submits a
request for Rental Rehabilitation Program assistance that is later approved and funded.
B. A permanent move from the real property that occurs before the submission of the request for
assistance to the City, if either the City or HUD determines that the displacement resulted directly
from rehabilitation, acquisition, or demolition for the project.
C. A permanent move from the real property by a tenant-occupant of a dwelling unit that occurs after
the execution of the agreement between the owner and the tenant if,
The tenant has not been provided a reasonable opportunity to lease and occupy a suitable,
decent, safe and sanitary dwelling in the same building/complex following the completion of
the project at a rent, including average utility costs that does not exceed the greater of:
The tenant's rent and estimated average utility costs before the execution of the agreement
between the City and the owner or the total tenant payment as determined under 24 CFR
813.107, if the tenant is lower income, or 30% of gross household income if the tenant is not
lower income, or;
2. The tenant has been required to relocate temporarily but:
The tenant is not offered payment for all reasonable out-of-pocket expenses incurred in
connection with a temporary relocation, including the cost of moving to and from the
temporarily occupied housing and any increased rent and utility costs, or other conditions of
APPENDIX IV
Page 29
the temporary relocation are not reasonable, and the tenant does not return to the
building/complex or;
3. The tenant is required to move to another unit within the building/complex but is not offered
reimbursement for all reasonable out-of-pocket expenses incurred in connection with the
move or other conditions of the move are not reasonable.
A person does not qualify as a displaced person, however, if the person has been evicted for cause
based upon a serious or repeated violation of material terms of the lease or occupancy agreement and
the City determines if the eviction was not undertaken for the purpose of evading the obligation to
provide relocation assistance or the person moved into the property after the owner's submission of the
request for assistance but, before commencing occupancy, received written notice of the owner's intent
to terminate the person's occupancy for the project or the person is an owner-occupant who moves as
a result of the rehabilitation of the real property or the person is ineligible under 49 CFR 24.2(g)(2) or
the City determines that the person was not displaced as a direct result of the acquisition, rehabilitation
or demolition for the project and the HUD office concurs in that determination.
ll. Relocation Assistance
Relocation assistance is available to tenants from two sources:
A. Rental rehabilitation funding as provided in CFR 511.10(g) (iv).
B. Section 8 assistance provided by the Denton Housing Authority
Permanent Relocation Assistance
Moving expenses will be provided to a family or individual displaced from any dwelling. They may, at
their discretion, choose either a payment related to actual moving expenses or the fixed moving
expense and dislocation allowance indicated in the federal register by the Department of
Transportation. Replacement housing assistance can be taken in one of two ways:
Tenants will be screened to determine if the family is eligible to receive a housing voucher/certificate.
When available, housing vouchers/certificates will be offered to families who are permanently
displaced. In the absence of vouchers/certificates or when a tenant is found to be ineligible (if for
reasons other than not being low income), the Public Housing Authority will provide at least one referral
to an available decent, safe, and sanitary unit. Tenants eligible for a replacement housing payment
may also elect to obtain a cash payment which will allow them to rent a comparable replacement
dwelling for a 42-month period or purchase a replacement dwelling.
Tenants eligible for a replacement housing payment include:
Those displaced from a dwelling occupied at least 90 days prior to the execution of an
agreement between owner and the City and,
2. Those displaced from a dwelling that they did not occupy for at least 90 days immediately
before the execution of the agreement between the owner and the granteetrecipient.
Generally, replacement housing payments will be the monthly rent and average utility costs
at the displacement dwelling or 30% of the tenants average monthly gross income. If a gap
exists between the new cost of housing with Section 8 assistance and the old costs,
replacement housing payments will be made to cover the gap.
Temporary Relocation Assistance
APPENDIX IV
PAGE 30
All tenants temporarily relocated from their residence will be reimbursed for all out-of-pocket expenses
incurred in connection with the move.
III. Provisions of Assistance
Tenant Assistance will be provided from three sources
A. The property owner - The property owner will be charged with informing his/her tenants of
their rights under the Uniform Relocation Assistance and Real Property Acquisition Policies Act of
1970 (URA). The property owner will provide the Community Development Division with
evidence of communication to tenants concerning these matters.
B. Community Development Division - The Community Development staff will be responsible for
counseling tenants regarding the appropriateness of replacement housing payments. Community
Development staff will also be responsible for complaint resolution and referral of tenants to the
DHA for additional assistance.
C. The Denton Housing Authority - The DHA will perform the following tests related to tenant
assistance: 1) certifying eligibility of tenants, 2) issuing vouchers/certificates, 3) notifying and
counseling tenants of their rights and rules of participation, and 4) identifying suitable replacement
dwellings.
IV. Denton Housing Authority Policies
The DHA provides counseling and application assistance at their office located at 308 S. Ruddell.
Applicants including all income verifications must be submitted to the office prior to any consideration
for Section 8 or other public housing assistance.
Each applicant found to be eligible is placed on DHA's waiting list. Any applicants found to be eligible
under one of the federally mandated preference categories will be moved to the appropriate position on
the waiting list.
Section 7 of the City's Memorandum of Understanding with DHA states that "DHA recognizes that
some tenants residing in units rehabilitated with rental rehabilitation funds may qualify for preferential
treatment under federal guidelines" Those households whose rent burden is 50% or more of
household income will be entitled to move forward on the DHA's waiting list along with others who fall
into the rent burdened category.
V. Equal Housing Opportunity and Non-Discrimination
The Community Development Division and the Denton Housing Authority are charged with upholding
individual rights under the Federal Fair Housing law.
The Community Development Division administers the City's Fair Housing Ordinance. Ordinance No.
81-33 declares "The policy of the City against discrimination in housing:"
The City and DHA agree not to discriminate in providing information, counseling, referrals or other
relocation services to persons displaced by rental rehabilitation activities. The City and DHA also
commit that the practices and methods using and administering this program will not result in this
displacement of persons because of their particular race, color, religion, sex, handicap, family status or
national origin.
For further information, please call the Community Development Division at 940-349-7726. The Community
Development Division is located in the Texas Building at 100 W. Oak, Suite 208, Denton, TX 76201.
APPENDIX IV
PAGE 31
APPENDIX V -TENANT PRE NOTIFICATION SAMPLE LETTER
-aj
Re:
Dear Tenant:
tese n yt M4.
This letter is to let you know that the rental unit where you live is being considered for
rehabilitation through the U.S. Department of Housing and Urban Development Rental
Rehabilitation Program under the City of Denton's Rental Rehabilitation Program.
PLEASE DO NOT MOVE! This renovation project is being considered in order to provide
you with a safer, more comfortable and attractive place to live. If you move without receiving
a notice to vacate from the owner, you may not be eligible for relocation assistance.
We do not foresee you or any other resident will be displaced by the rehabilitation. However,
if for some unforeseen reason displacement should become necessary, relocation assistance
will be provided for you. This assistance is described in the attached Tenant Assistance
Policy, which contains many important facts regarding the rental assistance available to you.
If you need more information or need further explanation, please contact (OWNER) at
(TELEPHONE NUMBER), or Alma Espino with the City of Denton at 940-349-7756.
Thank you for your cooperation. Please keep in mind this project is simply under
consideration at this time so PLEASE DO NOT MAKE ANY PLANS TO MOVE. Should we
decide at a later date to proceed with the project, you will be notified.
I hereby certify that I have received this notice and a copy of the Tenant Assistance Policy.
Signature
Date
Appendix V
Page 32
Appendix VI - Rental Rehabilitation TARGET AREA MAP
Appendix A
Page 33
Appendix VII -Tenant Beneficiary Information Tracking Form
PLACE APPENDIX VII HERE (PAGE 33)
Appendix A
Page 34