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APPENDIX 2

APPENDIX 2.  USE OF CIAP FUNDS FOR DRUG
ELIMINATION ACTIVITIES

I.    General

HUD strongly encourages all PHAs to take
an active leadership

role in eliminating illegal drugs from public
housing projects.

HUD recognizes that the elimination of drugs
in public housing

and the protection of public housing property
require the

cooperation of the local government and the
provision of

resources beyond that which are currently
available to support

the Public and Indian Housing Program.

II.   Local Government Cooperation
and Other Public/Private Resources

Although Federal funds provide primary support,
public housing

cannot be operated successfully without the
involvement of the

local government and local community. 
Accordingly, CIAP-funded

improvements related to drug elimination
shall not be funded in

a vacuum without such local involvement. 
The PHA shall discuss

its drug-related problems and proposed action
plan with the

local government and obtain a letter from
the local government

reaffirming local cooperation and assistance
and explaining how

the PHA's proposed drug elimination activities
fit into local

strategies and neighborhood improvement programs. 
Where

possible, the primary source of funding for
non-physical drug

elimination activities should be the Drug
Elimination Act.

III.  PHA Drug Strategy

PHAs that wish to use CIAP funds for drug
elimination

activities shall develop a written drug strategy
which:  (1)

assesses the nature and extent of the drug-related
problems;

(2) identifies current activities being undertaken
by the PHA,

State, tribal or local government, resident
management

corporation and resident council, or other
organized groups of

projects residents to address the problems;
(3) sets forth a

realistic strategy for responding to the
problems on both a

short-term and long-term basis; and (4) integrates
the

requested drug activities into the PHA's
overall strategy,

including management tools, enforcement strategies,
and

intervention and prevention programs. 
At Joint Review, the PHA

shall provide its action plan and the letter
from the local

government under Item II. to HUD for review.

                         
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APPENDIX 2

IV.   Cooperative Arrangements with
Local Police Departments

Under the terms of the Cooperation Agreement
between the local

government and the PHA, the local government
is responsible for

providing the same level of services (police,
fire, trash

collection) to public housing as are provided
to other

neighborhoods.  Therefore, under comprehensive
modernization

only, CIAP funds may be used to pay for the
cost of additional

on-duty police only where such police will
provide additional

services over and above those for which the
local government is

already contractually obligated to provide
under the

Cooperation Agreement.  The additional
services shall be

verifiable through time sheets and written
work assignments.

In such case, CIAP funds may be used as transfer
payments to

the local government for the salaries and
employee benefit

contributions of the additional on-duty police,
but not for the

related liability insurance or equipment
which is the

responsibility of the local government.

On-duty police are local government employees
who are carrying

out the full duties and responsibilities
of the police

department.  Off-duty police who may
be hired by the PHA as

security guards generally do not carry out
the full duties and

responsibilities of the police department
during the time they

are temporary PHA employees.

V.    Management Improvements
- General

Under comprehensive modernization only, management
improvements

that are related to eliminating drugs and
that are project

specific or PHA-wide in nature are eligible
CIAP costs where

they are necessary to correct identified
management problems

and to sustain the physical improvements
at the project being

comprehensively modernized.  Refer to
paragraph 2-3 of this

Handbook.

Management improvements are fundable only
for the

implementation period of the physical improvements,
unless a

longer period, up to a maximum of five years,
is clearly

necessary to achieve HUD-approved performance
targets.

Where management improvements involve ongoing
costs, HUD is not

obligated to provide continued funding or
additional operating

subsidy after the end of the implementation
period.  The PHA is

responsible for finding other funding sources,
reducing its

ongoing management costs, or terminating
the management

activities.  Therefore, if the PHA wishes
to continue the

management improvement, the PHA should identify
and begin to

seek out other funding sources as soon as
possible after CIAP

funding approval.

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APPENDIX 2

VI.   Eligible Management Improvements

Under comprehensive modernization only, examples
of eligible

management improvements related to drug elimination
activities