How to Manage a Housing Authority Construction Gantt Chart
The Problem: Housing Authority Construction Carries Federal Compliance Overhead That Doubles the Timeline
A housing authority developing new affordable units or rehabilitating existing stock isn't just managing construction — it's managing a federal compliance environment that includes environmental review under HUD's Part 58 requirements, Davis-Bacon prevailing wage monitoring for every construction worker, Section 3 hiring goals for low-income residents, and Fair Housing Act design standards. Any one of these can stop a project: an environmental review finding, a wage restitution order, a Section 3 non-compliance determination.
The environmental review alone — even for a straightforward rehabilitation project — requires a Responsible Entity to certify environmental conditions, publish a finding for public comment, and obtain HUD's Approval to Use Grant Funds (AUGF) before any project costs can be incurred. Starting construction before the AUGF is received is a fatal compliance error that can require returning all grant funds. Housing authorities that haven't done this before routinely underestimate these timelines by 6 months. gantt-chart.io maps the compliance milestones alongside the construction schedule so nothing proceeds out of sequence.
Prerequisites
- HUD grant agreement or financing commitment letter received
- Responsible Entity designated for Part 58 environmental review
- Davis-Bacon wage determination obtained from SAM.gov for project trade categories
- Section 3 hiring plan developed and submitted to HUD if required
- Architect and contractor selection process planned per HUD procurement requirements
- Relocation plan developed if existing tenants will be displaced during construction
Housing Authority Construction Gantt Chart Template
Phase 1: Environmental Review and Pre-Development (Months 1–4)
- [ ] Complete all environmental review studies: Phase I ESA, flood zone determination, noise, historic
- [ ] Publish combined FONSI/Notice of Intent to Request Release of Funds for public comment (15-day period)
- [ ] Respond to any public comments; obtain local certifying official signature
- [ ] Submit Request for Release of Funds (RROF) to HUD; await AUGF (15-day waiting period)
- [ ] Receive Approval to Use Grant Funds — NO project costs may be incurred before this date
- [ ] Complete relocation notices to affected residents; begin relocation assistance
Phase 2: Design and Procurement (Months 3–8)
- [ ] Issue RFQ for architectural services; evaluate and select design firm per HUD procurement standards
- [ ] Complete schematic design and design development; submit for HUD and local review
- [ ] Complete construction documents; obtain all required permits
- [ ] Obtain Section 3 business registry listings for targeted subcontractor outreach
- [ ] Issue invitation for bids with required Davis-Bacon wage rates included in specifications
- [ ] Conduct public bid opening; verify low bidder's license, bonding, and Section 3 compliance
- [ ] Execute construction contract; obtain performance and payment bonds
Phase 3: Construction (Months 8–20)
- [ ] Conduct pre-construction meeting; brief contractor on Davis-Bacon, Section 3, and reporting requirements
- [ ] Collect certified payrolls weekly from contractor and all subcontractors
- [ ] Review payrolls for Davis-Bacon compliance; issue wage interviews with workers on site
- [ ] Track Section 3 hiring against goals monthly; document new hire certifications
- [ ] Process monthly pay applications; verify progress against schedule before approving
- [ ] Conduct HUD required inspections at critical construction milestones
- [ ] Document all change orders with justification before authorizing additional work
Phase 4: Completion and Occupancy (Months 18–24)
- [ ] Obtain certificate of occupancy from local building department
- [ ] Conduct HUD inspection (REAC or equivalent) before occupancy
- [ ] Process tenant applications and certify income eligibility per HUD standards
- [ ] Execute leases and move residents in per relocation plan
- [ ] Submit final Davis-Bacon compliance certification to HUD
- [ ] Complete Section 3 final report documenting hiring outcomes
Phase 5: Grant Closeout (Months 22–26)
- [ ] Submit final financial report to HUD; reconcile all project costs
- [ ] Complete HUD grant closeout documentation
- [ ] Archive all project records for HUD record retention requirements (typically 10 years)
- [ ] Conduct post-construction debrief; document lessons for next development project
Common Pitfalls
- Incurring costs before AUGF: Any project cost — design fees, studies, legal costs — incurred before the Approval to Use Grant Funds is received may be declared ineligible and require repayment. The AUGF is a hard start gate.
- Davis-Bacon enforcement gaps: Contractors who don't receive certified payroll requirements at contract execution often don't maintain the records needed. Brief contractors on Davis-Bacon at award, not mid-construction.
- Section 3 documented but not achieved: HUD expects documented good faith efforts toward Section 3 goals, but actual hiring outcomes matter. Track Section 3 hiring monthly and address shortfalls proactively.
- Relocation plan delayed: Residents who aren't given adequate relocation notice and assistance have legal remedies that can delay construction. Initiate relocation as soon as the environmental review allows.
What Good Looks Like
A successful housing authority construction project delivers quality affordable housing on schedule, completes HUD closeout within 6 months of project completion, and produces a Davis-Bacon and Section 3 compliance record that supports future HUD grant awards. Residents in the completed units have stable, affordable housing — which is the outcome everything else exists to deliver.