YouthBuild construction training work sites and projects

CLASSIFICATION
   EMPLOYMENT AND TRAINING ADMINISTRATION                  YouthBuild
               ADVISORY SYSTEM                             CORRESPONDENCE SYMBOL
          U.S. DEPARTMENT OF LABOR                         OWI-DYS
             Washington, D.C. 20210                        DATE
                                                           October 7, 2015

ADVISORY:        TRAINING AND EMPLOYMENT GUIDANCE LETTER NO. 6-15

TO:              STATE WORKFORCE AGENCIES
                 STATE WORKFORCE LIAISONS
                 STATE WORKFORCE ADMINISTRATORS
                 STATE AND LOCAL WORKFORCE INVESTMENT BOARDS
                 ALL YOUTHBUILD GRANTEES

FROM:            PORTIA WU /s/
                 Assistant Secretary

SUBJECT:         Qualifying Work Sites and Construction Projects for YouthBuild Grantees and
                 Their Role in Training

1. Purpose. The intent of this Training and Employment Guidance Letter (TEGL) is to provide
   guidance on the types of work sites that are acceptable for construction training for
   YouthBuild participants, describe the minimum construction activities allowed for work site
   training, and clarify the policy around successful exit as it pertains to hands-on occupational
   training.

2. References.
   • Workforce Innovation and Opportunity Act (Pub. L. 113-128 July 2014);
   • YouthBuild Final Rule, 20 CFR Part 672;
   • ETA-9143, “Work Site Description”
      (http://www.doleta.gov/Youth_services/YouthBuild.cfm);
   • TEGL 05-10, “Match and Allowable Construction and Other Capital Asset Costs for the
      YouthBuild Program”
      (http://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=2932);
   • TEGL 35-12, “Definition and Guidance on Allowable Construction Credentials for
      YouthBuild Programs” (http://wdr.doleta.gov/directives/corr_doc.cfm?DOCN=8795);
      and
   • Joint Letter between Housing and Urban Development (HUD) and Department of Labor
      (DOL) encouraging Section 3 partnerships with YouthBuild grantees, Registered
      Apprenticeship sponsors, and Public Housing Authority contractors
      (http://www.doleta.gov/Youth_services/pdf/HUDDOL_FinalJointLetter.pdf)

3. Background. The YouthBuild program model requires hands-on construction training that
   supports the outcome of increasing the supply of affordable housing within the communities
   that YouthBuild serves. A key component of the program model is providing hands-on
 RESCISSIONS                                              EXPIRATION DATE
 None                                                     Continuing

training for youth in industry-recognized curricula that develops skills necessary to build or
substantially renovate housing for low-income or homeless individuals or families.

Per the Workforce Innovation and Opportunity Act, the five purposes of the YouthBuild
program are to:

(1) enable disadvantaged youth to obtain the education and employment skills necessary to
    achieve economic self-sufficiency in occupations in demand and postsecondary education
    and training opportunities;

(2) provide disadvantaged youth with opportunities for meaningful work and service to their
    communities;

(3) foster the development of employment and leadership skills and commitment to
    community development among youth in low-income communities;

(4) expand the supply of permanent affordable housing for homeless individuals and low-
    income families by utilizing the energies and talents of disadvantaged youth; and

(5) improve the quality and energy efficiency of community and other nonprofit and public
    facilities, including those facilities that are used to serve homeless and low-income
    families.

To ensure that youth are obtaining the required employment skills for in-demand
occupations, they must have training opportunities that will support them in attaining
industry-recognized credentials. Experiential learning is a key component of credential
attainment. In terms of construction training, there is a wide variety of trades and
specializations within construction and it is important that youth have hands-on exposure to
these trades to better prepare them for the job market.

Grantees satisfy this requirement by offering construction skills training to youth on approved
work sites, either building housing from scratch or through extensive rehabilitation of
existing housing stock. Utilizing work sites, above and beyond classroom and lab training, is
a vital and necessary component of a successful YouthBuild program. Proper work sites
ensure that youth obtain hands-on experience and build the skills necessary to support the
goal of expanding affordable housing in communities served.

Some grantees struggle to find and maintain access to construction work sites because
planned partnerships fall through or the proposed work site loses funding. It is important that
grantees plan ahead for potential work site issues and understand that not every work site
opportunity qualifies for the required work site component of the grant. Grantees may need
to have a second or even third alternative in mind should the proposed work site fall through
and/or not qualify. However, grantees are required to ensure that YouthBuild participants are
engaged in the hands-on construction at an approved work site to meet the intent and purpose
of the DOL YouthBuild program. Therefore, participants that are exited from the

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   YouthBuild program without completing the hands-on construction component at an
   approved residential work site will be considered unsuccessful exiters of the DOL
   YouthBuild program. As a result, the Department may question or disallow grant costs.

4. Qualifying Work Site Examples. There are several criteria that impact whether a work site
   qualifies as appropriate for construction skills training. The first is whether the work site
   meets the threshold for low-income, as defined by the United States Housing Act of 1937 (42
   U.S.C. 1437a(b)(2)). The second is whether the site provides substantial hands-on
   experience for youth. This means that the work site must include from-the-ground-up
   building experience (e.g. foundation, framing, roofing, dry wall installation, finishing) or a
   substantial level of rehabilitation (i.e., “a gut job”). Additional examples of “a gut job”
   include demolishing existing walls and then reframing them; completely gutting a kitchen
   and installing new flooring, cabinetry, upgraded plumbing, upgraded electrical and
   installation of new appliances, or completely gutting a bathroom and installing new flooring,
   upgraded plumbing and/or electrical to make the bathroom more energy efficient and up to
   code, removing an old commode and replacing it with a water-conserving commode,
   installing a new sink, tub (or resurfacing the existing tub) or shower and replacing older
   faucets with water-efficient faucets, etc.

   All YouthBuild work sites must be built or renovated for low-income individuals or families
   and are required to have a restrictive covenant in place that only allows for rental or re-sale to
   low-income participants for a particular period of time. This ensures that the work sites
   developed by YouthBuild programs fulfill the intent of the legislation to expand the supply of
   permanent affordable housing.

   Determining whether a work site meets the criteria for providing substantial hands-on
   experience can be complex. Both rehabilitation and new construction are allowable
   activities. However, there are limitations on the activities in which youth are allowed to
   engage (i.e., roofing and use of heavy machinery are not allowable activities for youth
   younger than eighteen based on the Fair Labor Standards Act (see
   http://www.cdc.gov/niosh/docs/2004-113/). Such limitations restrict some YouthBuild
   participants’ opportunities to engage in certain construction work, especially with new
   construction. Furthermore, the term rehabilitation can be overly broad in its definition –
   everything from painting and yard work to potentially gutting and replacing plumbing and
   electrical work. This TEGL seeks to establish the minimum level of rehabilitation that
   qualifies for consideration as a YouthBuild work site.

   As referenced in TEGL 35-12, “Definition and Guidance on Allowable Construction
   Credentials for YouthBuild Programs,” there are a number of modules and skill areas that
   must be studied and tested before the participant is accredited in one of the industry-
   recognized construction certification programs. Modules are specific training sections within
   each of the industry-recognized credentials that relate to specific skill areas of construction.
   These skill areas could include brick masonry, carpentry, painting, or plumbing, just to name
   a few.

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   While it may be allowable for programs to also provide more general rehabilitation work,
   such as deconstruction, landscaping, screen repair, fence building, etc., none of these
   activities qualifies without also including experience in two or more modules within two or
   more skill areas. Any work site that does not include exposure to multiple modules and skill
   areas will not be considered a qualifying work site. For example, painting alone or painting
   in addition to landscaping would not qualify as significant rehabilitation for YouthBuild
   participants. Work sites must provide the opportunity for youth to have hands-on training
   and experience of both breadth and depth in order to qualify. While it may not be possible to
   provide experience in all modules within all skill areas when training on rehabilitation work
   sites, the work site must still offer significant hands-on training and experience. Participants
   are provided a depth of training by studying multiple modules of the chosen industry-
   recognized credential program and they are provided breadth of training by applying training
   learned across multiple skill areas while they are at the work site.

   All work sites must still adhere to the allowable construction and other capital asset costs, as
   defined in TEGL 05-10, “Match and Allowable Construction and Other Capital Asset Costs
   for the YouthBuild Program,” in determining what work site activities are allowable with
   YouthBuild grant funds. All grantees must utilize the required Work Site Description form
   (ETA-9143) in submitting proposed work sites for review and approval. The Work Site
   Description form requests specific information on the property to be built or rehabilitated, the
   construction activities to be undertaken by participants, the source of funds for the
   construction, and demonstration of ownership or access to the site. For information on how
   to secure qualifying work sites and correctly prepare the Work Site Description for approval,
   please see this archived Webinar:
   https://www.workforce3one.org/view/5001422339945839197/info. The ETA-9143 form
   must be used at the time of grant application, and also when new work sites are requested for
   approval through a statement of work modification.

5. Suggested Partnerships.
   Many YouthBuild programs may partner with community agencies, such as Rebuilding
   Together and Brush of Kindness, which support housing rehabilitation for low-income
   homeowners. These partnerships are an excellent addition to the goals of the YouthBuild
   program and should be considered as community service activities for participants. These
   partnerships can be very beneficial in developing leadership skills in youth and supporting a
   commitment to community development, but they do not generally meet the level of
   rehabilitation necessary to qualify as a required work site. However, where they provide a
   sufficient opportunity for hands-on experience in two or more modules across several of the
   skills areas, they may be considered for qualification as work sites.

   Many YouthBuild grantees have successfully partnered with local Habitat for Humanity
   affiliates to provide the work site for participants. This is mutually beneficial as Habitat
   seeks community volunteers to complete the needed construction and it allows participants to
   participate in all allowable aspects of new construction that will go to low-income or
   homeless individuals or families. However, this is not the only option for grantees. Many
   grantees have also found success partnering with other community associations that do

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intensive rehabilitation or new construction similar to what Habitat does, as well as
partnering with local Housing Authorities that are rehabilitating housing or building new
housing. Some YouthBuild grantees have also brought the construction in-house as the
owner of the properties to be built or rehabilitated.

YouthBuild grantees have successfully partnered with City and/or County Housing
Community Investment Departments, Non-Profit Community Housing Development
Organizations, and Community Development Corporations to expand the market of
affordable housing for low-income or homeless individuals. For example, some grantees that
have partnered with City and/or County Housing Community Investment Departments
(CHCID) have been afforded the opportunity to work on a HUD-funded housing project
called the “Healthy Homes Program.” The overall goals and objectives of the Healthy
Homes Program are to: (1) mobilize public and private resources, involving cooperation
among all levels of government, the private sector, grassroots community-based
organizations, including faith-based organizations, and other non-profit organizations, to
develop and implement the most promising, cost-effective methods for identifying and
controlling housing-related hazards; and (2) build local capacity to operate sustainable
programs that will continue to prevent, minimize, and control housing-related hazards in low-
and very low-income residences. YouthBuild participants that work on Healthy Homes
Programs gain a multitude of construction skills that include learning to install doors,
repairing and/or rebuilding water-damaged walls, caulking and painting various surfaces
within a residence, inside demolition, repairing and replacing loose siding, replacing
bathroom vents, windows, doors and screens for proper ventilation, repairing or replacing
plumbing fixtures and lastly, repairing leaking roofs at homes owned by low-income
residents within the community.

Grantees have also successfully partnered with organizations like Grid Alternatives. Grid
Alternatives Solar Program is designed to create an on-the-job training opportunity. It first
educates YouthBuild participants on basic solar installation and electrical science, and then
provides participants with a variety of real-time skills as they work to install solar panels on
low-income residents’ homes alongside staff from the Grid Alternatives organization. The
construction skills they gain include laying out conduits and bending, measuring, and
installing runs, brackets and ground wiring from tracks to the roof. By the end of the project,
the participants have installed 8 kW and 2.6 kW photovoltaic solar power systems on a
number of low-income residents’ homes within their community. Lastly, other YouthBuild
grantees have partnered with organizations that specialize in building “micro or tiny” homes
for homeless individuals. The tiny homes typically range from 64 to 300 square feet and are
considered affordable and energy efficient, aid in reduced materials consumption, and can
substantially cut down our carbon footprint.

The Department released a joint guidance letter in 2014 encouraging partnerships between
Registered Apprenticeship sponsors, contractors, and YouthBuild program administrators to
work together to create local Registered Apprenticeship opportunities for YouthBuild
participants upon graduation on HUD-funded construction projects. Section 3 requires
recipients of certain HUD funding to direct jobs, training, and contracting opportunities to

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   local low-income persons and businesses that substantially employ those persons. By having
   these partnerships in place, YouthBuild grantees will be connected at the local level to
   Registered Apprenticeship sponsors and contractors that have access to local work sites that
   may be suitable for YouthBuild participants. The Department strongly encourages
   YouthBuild grantees to search the Registered Apprenticeship sponsor database to find
   sponsors in their community that might help them make these connections at:
   http://www.doleta.gov/oa/contactlist.cfm. In addition, you can locate your nearest Public
   Housing Authority at:
   http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/pha/conta
   cts.

6. Role in Training. There are additional considerations to take into account when developing
   work sites. The work site provides the opportunity to apply skills learned in the classroom
   while also fulfilling the key purposes of the YouthBuild program. The work site is the main
   source of experiential training for participants and it is directly tied to the minimum time
   devoted to educational services and activities, as described in the Additional Program
   Requirements section of the YouthBuild Transfer Act. This section requires that participants
   be offered a minimum of forty percent of their time in the program engaging in work
   experience and skills training, including hands-on construction training on the work site,
   making work site experience a required component of the program model. Participants who
   do not receive this hands-on work site training have not received the complete YouthBuild
   program curriculum and will not be considered as successful exiters because they have not
   completed their training (as described in the Background section). On average, YouthBuild
   participants will require as much as 120 hours to complete industry-recognized credential
   training curricula; however, a minimum of 500 hours of actual hands-on construction training
   at an approved residential work site is recommended to ensure that their skills and
   competency levels meet the minimum requirements and standards for entry into the
   construction industry.

7. Inquiries. Questions on this TEGL may be addressed to the appropriate ETA regional office.

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