Texas Department of Housing & Community Affairs - Building Homes and Strengthening Communities

Section 3 Compliance Plan, Suggested Components

TDHCA Program Services Division recommends that a project owner, subrecipient, or General Contractor create a Section 3 Compliance Plan to coordinate their local economic opportunity efforts and maximize the project’s community benefits. A summary of the subrecipient’s plan can help to explain Section 3 features when presenting the project to prospective employees, subcontractors, or neighborhood residents. A plan enables the contract awardee to create a frame of reference so everyone involved in the project may understand the purpose of creating local economic opportunities. If the project falls short of its employment benchmarks, the plan enables project managers to explain, in the final report, their good faith efforts to meet their legal obligations under the rule. A Section 3 plan can improve the long-term viability of a project by reinforcing community interest through public presentations.

The following list suggests basic components for a Section 3 Compliance Plan to get you started. Visit the Compliance Resources page for other suggestions and examples.

  • Identify the project by Fund Source/ Program, Subrecipient or Owner name, project name, address, service area, Section 3 Coordinator and their contact information.
  • Compare the available local labor force and training facilities with project demands and enumerate jobs by title subject to hire; ascertain which jobs will require on-the-job training.
  • Describe strategies, resources, and partnerships the Subrecipient or contractor may utilize to fulfill responsibilities listed in the Obligation Summary for Contract Awardees (DOC).
    • Will the project workforce include Section 3 workers among pre-existing contractors?
    • How might project employers include local residents in their workforces?
    • How to track labor hours and differentiate those of Section 3 workers from others?
    • How might project employers reach and contact potential Section 3 workers and businesses?
    • How will subcontractors compile worker hours to facilitate tabulation by prime contractor?
  • How will the Subrecipient or contractor notify Section 3 residents about opportunities? (e.g.: via Public Housing Authority, Workforce Development Board, Community College apprenticeship programs, labor organizations, YouthBuild Programs, etc.)
  • Outline contractor strategies to recruit Section 3 businesses and to advertise subcontractor opportunities. (e.g.: Small Business Development Centers can help with this.)
  • Anticipate Section 3 Summary Report to TDHCA, with good faith efforts (§75.25 Reporting (b)).

If you have any questions, please contact your program’s contract specialist, or TDHCA Program Services staff.