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Jenny Werwa
Director of Communications
202-638-1300 X 120
jwerwa@clpha.org
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Statement from CLPHA Executive Director Sunia Zaterman
WASHINGTON (September 21, 2018) – In support of housing authorities and residents impacted by Hurricane Florence, Sunia Zaterman, Executive Director of the Council of Large Public Housing Authorities, issued the following statement:
“Though the storm itself is behind us, flooding and other destructive impacts of Hurricane Florence may take weeks or months to subside. As we consider the ongoing damage to Virginia and the Carolinas, our thoughts immediately turn to the most vulnerable segments of our population: low-income families and those who risk displacement from their homes.
“The Council of Large Public Housing Authorities (CLPHA) and its entire membership supports providing assistance in any way we can to colleagues, partners, friends, and housing residents who have been affected by the devastation caused by Hurricane Florence. We will make available to the fullest extent any vital resources and support services we have at our disposal to help cities, PHAs, and residents recover from the storm.
“Please know that our thoughts are with all those who have suffered losses from the hurricane and its aftermath. CLPHA and its entire network of affordable housing professionals stands ready to work across all sectors to extend both short-term and long-term assistance to anyone in need. As we have in the past, we will advocate for HUD and FEMA programs such as DHAP and CDBG-DR that help disaster-impacted low-income Americans establish housing stability and improve their life outcomes.”
About the Council of Large Public Housing Authorities
The Council of Large Public Housing Authorities is a national non-profit organization that works to preserve and improve public and affordable housing through advocacy, research, policy analysis and public education. CLPHA’s 70 members represent virtually every major metropolitan area in the country. Together they manage 40 percent of the nation’s public housing program; administer 26 percent of the Housing Choice Voucher program; and operate a wide array of other housing programs. Learn more at clpha.org and on Twitter @CLPHA.
For Immediate Release
Wednesday, September 19, 2018
HUD’s Rental Assistance Demonstration Program is a Proven Means of Securing the Future of the Nation’s Public Housing Stock
Washington, D.C. – Today, U.S. Department of Housing and Urban Development Secretary Ben Carson and Federal Housing Commissioner Brian Montgomery joined the Housing Authority of the City of Austin, its development partners Atlantic | Pacific Communities and Madhouse Development Services, and the Austin community to celebrate the groundbreaking of HACA’s most recent redevelopment of one of its public housing properties, Goodrich Place, which also represents the 100,000th public housing unit being converted through HUD’s Rental Assistance Demonstration program.
In recognition of this important milestone, Sunia Zaterman, Executive Director of the Council of Large Public Housing Authorities and Patrick Costigan, Strategic Advisor to the RAD Collaborative, issued the following statement:
Today we are celebrating an important milestone addressing the critical need for affordable housing by enabling housing authorities to convert public housing to more stable long-term Section 8 based contracts that will serve PHAs and residents for years to come.
Through the Rental Assistance Demonstration program, agencies across the country can leverage private financing to complete capital improvements needed to preserve and improve the public housing stock, without giving up control of the asset. RAD engenders creative local partnerships, stimulates ongoing economic activity, and leads to improved housing quality for low-income seniors and families.
As we celebrate the 100,000th RAD unit, it’s clear that we have proof of concept. To give PHAs greater certainty, HUD’s program should be permanent with unlimited opportunity for conversions to agencies meeting the requirements.
Congratulations to HUD at this significant juncture, and to HACA and the residents of Goodrich Place who will soon have access to improved units in one of Austin’s highest opportunity neighborhoods.
About the Council of Large Public Housing Authorities
The Council of Large Public Housing Authorities is a national non-profit organization that works to preserve and improve public and affordable housing through advocacy, research, policy analysis and public education. CLPHA’s 70 members represent virtually every major metropolitan area in the country. Together they manage 40 percent of the nation’s public housing program; administer 26 percent of the Housing Choice Voucher program; and operate a wide array of other housing programs. Learn more at clpha.org and on Twitter @CLPHA.
About the RAD Collaborative
The Council of Large Public Housing Authorities (CLPHA)—with the support of the National Equity Fund (NEF), HAI Group, Reno & Cavanaugh, and CF Housing Group—organized the RAD Collaborative for interested Public Housing Authorities, their partners and residents using the Rental Assistance Demonstration to preserve and revitalize public housing properties. Our focus also includes extending RAD to multifamily housing at risk of being lost from the affordable inventory--including Rent Supp, RAP, Mod Rehab and Section 202 PRAC properties. Learn more at radcollaborative.org and on Twitter @SucceedwithRAD.
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CLPHA participated in a call this morning with HUD to discuss next steps in the implementation of the Small Area Fair Market Rent Rule (“Rule”) in light of the preliminary injunction was granted in the Open Communities Alliance litigation challenging HUD’s suspension of the Rule (see CLPHA Update 1/3/18). Participants on the call included officials from HUD’s Offices of Policy Development and Research (“PD&R”), Public and Indian Housing (“PIH”), Housing Choice Vouchers, and General Counsel. Below are the major takeaways from the call:
- Effective date of April 1, 2018: HUD announced that full implementation and compliance with the Rule and the to-be-issued guidance will be effective as of April 1, 2018.
- Comments due January 11, 2018: HUD encouraged all interested parties to submit comments in response to HUD’s December 12, 2017 “Notice for Suspension of Small Area Fair Market Rent (Small Area FMR) Designations; Solicitation of Comment” Docket No. FR-6070-N-01. Comments are due by January 11, 2018 and may be submitted by mail or electronically atwww.regulations.gov. We will be submitting comments accordingly. We request members to provide us information regarding adverse rental housing market conditions specific to your area so that we can, in turn, include in our comments to HUD.
- Substantive Issues Addressed
- Request for suspension of Small Area FMR designation – HUD noted that the Court in theOpen Communities Alliance litigation did not invalidate any portion of the Rule, but rather concluded that HUD did not properly suspend the Rule’s implementation. HUD went on to clarify, however, that HUD still has the discretion, on a case-by-case basis, to suspend a Small Area FMR designation for a particular area or temporarily exempt a PHA from using the Small Area FMRs based on documented findings of adverse rental housing market conditions. While HUD is working on guidance to instruct PHAs on how to request such a suspension or exemption, HUD is aware of the difficulties PHAs face given the short implementation timeframe and encourages PHAs not only to highlight these difficulties by submitting comments to its December 12, 2017 Notice, but also to submit these difficulties in any forthcoming suspension or exemption request for HUD’s consideration.
- Administrative fees – PIH was not able to provide feedback regarding whether PHAs will be provided increased administrative fees to assist in the implementation efforts, as was done for the demonstration project participants using extraordinary administrative fees.
- FMR “groupings” – While HUD will continue to issue Small Area FMRs at the zip code level, HUD also encourages PHAs to create Small Area FMR bands using the surrounding zip codes that fall within the 90%-110% FMR range. HUD acknowledged that such groupings are not specifically authorized under the Rule but noted that they will be addressed in the forthcoming guidance materials.
- Guidance forthcoming: HUD anticipates issuing implementation guidance materials by mid-January. This guidance will include:
- PIH guidance document(s)
- Technical assistance task order(s)
- A dedicated technical assistance page on HUD Exchange
- FAQs document(s)
- Guidance regarding the process for requesting Small Area FMR suspensions
The guidance materials will include information on best practices, outreach to tenants, managers, and owners, impact on current technical and organizational systems, and other similar information. HUD also committed to using the findings from the Small Area FMR demonstration project to inform such guidance materials.
If you have any questions about HUD’s Small Area FMR Implementation, you can email or call (202-638-1300) Research & Policy Analyst Nicole Barrett (nbarrett@clpha.org) or Deputy Director Deb Gross (dgross@clpha.org).
Yesterday, CLPHA and counsel Reno & Cavanaugh submitted public comments in opposition to the U.S. Department of Homeland Security's (DHS) proposed rulemaking titled “Inadmissibility on Public Charge Grounds” (83 FR 51114) (the “Notice”). The Notice proposes to expand the basis upon which a non-citizen seeking adjustments to their residency or visa status are likely to become a “public charge.”
The proposed public charge definition would include, among other things, public housing, Section 8 Housing Choice Vouchers, and Section 8 Project-Based Rental Assistance. In other words, receiving federal housing assistance could negatively impact a non-citizen program participant’s visa status.
The practical result of the Proposed Rule is to penalize families for participating in the very housing programs that are meant to serve them. Because this directly contradicts the mission of PHAs, our comments call on DHS to abandon the Proposed Rule in its entirety.
Our detailed comments focus on the following concerns:
- The inclusion of housing assistance in the determination of a public charge, when eligible
- status is an existing pre-requisite for program participation, creates confusion among residents and otherwise
- undermines the mission of those programs.
- The Proposed Rule is increasing the administrative burden on PHAs across the country,
- despite proposing no direct changes to the housing programs administered by PHAs.
- Access to decent, safe, affordable housing is necessary for building healthy communities
- and increasing family self-sufficiency.
On October 10, 2018, the U.S. Department of Homeland Security (DHS) published a notice of proposed rulemaking titled “Inadmissibility on Public Charge Grounds” (83 FR 51114) (the “Notice”). The Notice proposes to expand the basis upon which a non-citizen seeking adjustments to their residency or visa status are likely to become a “public charge.”
Currently, a “public charge” is defined as an individual who is “primarily dependent on the government for subsistence,” as demonstrated by the individual’s receipt of certain public cash assistance or long-term institutionalized care at the government’s expense. The Notice proposes to expand the list of benefits considered in the public charge analysis to include, among other things, public housing, Section 8 Housing Choice Vouchers, and Section 8 Project-Based Rental Assistance. In other words, receiving federal housing assistance could negatively impact a non-citizen program participant’s visa status.
After a November 19 conference call with CLPHA members who shared feedback on the proposed rule, CLPHA and counsel Reno & Cavanaugh drafted public comments in opposition for the following reasons:
- DHS appears, by definition, to attack and punish the successful administration of Section 8 and Public Housing programs to the individuals for which they are intended. In other words, the litmus test is no longer whether an individual is “primarily dependent” on government assistance. Rather, it is whether an individual participates in these housing programs at all.
- The Proposed Rule seems to demand that eligible families decide between accessing essential housing assistance or maintaining their ability to enter or remain in the United States. Either choice will have detrimental results—the family foregoes access to decent, safe, affordable housing or is deemed a public charge.
- The practical result of the Proposed Rule is to penalize families for participating in the very housing programs that are meant to serve them. This directly contradicts the mission of PHAs, and as such, we respectfully submit that the Proposed Rule be abandoned in its entirety.
- The Proposed Rule, even at this stage, holds a detrimental impact on the communities we serve.
- PHAs across the country are experiencing increased demands on their already limited and underfunded resources because of the ambiguity and confusion caused by the Proposed Rule.
Final comments are due Monday, December 10, 2018. If you have any questions about our comments or the proposed public charge rule, please contact CLPHA Research & Policy Analyst Emily Warren, ewarren@clpha.org, or 202-638-1300 ext. 103.
On November 29, CLPHA attended a meeting at HUD headquarters with other industry groups to discuss changes to the inspection process. Recent news coverage has highlighted instances in which inspection scores do not accurately reflect living conditions and overall declines in the number of inspections for properties.
At the meeting, an official from HUD’s office of public affairs noted that the department has received an increased number of media and FOIA requests related to inspections in the last few years. HUD officials also acknowledged that the current inspection standards are 20 years old and an update and review of those standards is needed in order to maintain safe environments for residents and to ensure that scores accurately reflect housing conditions.
In addition to flaws in the scoring system, the group discussed other factors that may be contributing to inaccurate scores, such as lack of capacity at HUD field offices to monitor inspections and inadequate inspector training. Senior HUD PIH officials discussed some potential changes to the scoring system and protocol, as well as measures to increase enforcement including shorter inspection notification periods and requiring inspections of properties currently undergoing rehabilitation.
CLPHA remains concerned about the current inspection protocol’s ability to distinguish between safe and unsafe properties, and HUD’s lack of oversight for owners whose properties receive failing scores. HUD should also acknowledge that reduced capital and operating funds for public housing have greatly affected the ability of PHAs to maintain safe living conditions for their residents and that a comprehensive approach is needed through inspection protocol changes, stricter enforcement, and adequate funding for maintenance and repairs.
HUD officials reported that they will continue to explore possible changes and are considering holding listening sessions with PHAs and property owners in the spring, with a potential demonstration project for a new inspection protocol beginning in summer 2019.
In other news, HUD officials also reported at the meeting that a notice on the Annual Contributions Contract (ACC) is expected shortly. CLPHA strongly advocated for reconsideration of HUD’s earlier changes to the ACC.
Contact CLPHA Research & Policy Analyst Emily Warren for questions or further information at ewarren@clpha.org.
On November 19, CLPHA hosted a member call to receive feedback regarding comments on the Department of Homeland Security’s proposed rule, “Inadmissibility on Public Charge Grounds.” “Public Charge” is a term used by U.S. immigration officials to refer to an individual who is “primarily dependent on the government for subsistence.” An immigrant who is found to be “likely . . . to become a public charge” may be denied admission to the U.S. or lawful permanent resident status.
The current public charge definition only considers cash assistance and long-term institutionalized care, while the new rule proposes expanding the list of benefits considered under this definition to include, among others, public housing, Housing Choice Vouchers, and Project-Based Rental Assistance. During the call, CLPHA members expressed concern about the proposal’s lack of clarity, the potential for additional burdens required of PHAs, and the overall chilling effect that the rule could have among residents and their families, as well as their decision to maintain housing assistance.
CLPHA will be submitting comments to the proposed rule, which are due on December 10, 2018.
On November 21, HUD announced awards for the Family Unification Program (FUP), a partnership between PHAs and child welfare agencies that provides housing assistance to foster youth at risk of homelessness and families whose lack of housing is a reason for their child’s foster care placement or is preventing family reunification. HUD awarded $30 million in funding to provide 3,000 vouchers. 15 CLPHA members received awards:
Akron Metropolitan Housing Authority • Chicago Housing Authority • Housing Authority of Cook County • Columbus Metropolitan Housing Authority • District of Columbia Housing Authority • Home Forward • Houston Housing Authority • King County Housing Authority •Housing Authority of the City of Los Angeles • Housing Authority of the County of Los Angeles • Housing Opportunities Commission of Montgomery County • New York City Department of Housing Preservation & Development • Housing Authority of the City of Pittsburgh •Seattle Housing Authority • Vancouver Housing Authority
Congratulations to our members that received FUP awards!
On December 13, CLPHA and CSH-One Roof will host "FUP Vouchers: Opportunities and Best Practices for Implementation," a free webinar for staff at PHAs, Public Child Welfare Agencies (PCWAs), and continuum of care and coordinated entry staff in communities that have received FUP vouchers.
HUD’s Family Unification Program offers new opportunities for PHAs, PCWAs, Homeless Response Systems, and other community partners to serve families in need. This free webinar will provide an overview as well as implementation lessons learned and best practices from PHAs that have successfully implemented FUP vouchers. Speakers, including staff from King County Housing Authority, the Housing Authority of Kansas City, and Minneapolis Public Housing Authority, will discuss strategies for creating a cross-system collaboration structure, a multi-agency referral system and engagement process, and securing housing while facilitating move-in for families.
Date: Thursday, December 13, 2018
Time: 1:00 pm ET
The Municipal Housing Authority for the City of Yonkers (MHACY) Executive Director Joseph Shuldiner and Yonkers Mayor Mike Spano showed off the first completed phase of MHACY’s Schlobohm Houses revitalization on a tour with the press and New York State Sen. Andrea Stewart-Cousins. With mixed financing made possible by the RAD program, MHACY will renovate 411 units across eight buildings at a cost of $50 million. The work is part of MHACY’s three-year plan to renovate more than 1,700 units of affordable housing across the city.
The San Diego Housing Commission (SDHC) awarded $760,000 in funding via its Housing First San Diego initiative to National Community Renaissance developers for the construction of San Ysidro Senior Village, a future supportive housing community for seniors experiencing homelessness, including senior veterans. Under Housing First San Diego, SDHC plans to fund $80 million in housing between 2018 and 2020.
Connecticut’s Competitive Housing Assistance for Multifamily Properties program awarded Elm City Communities $7.8 million to redevelop 276 units of affordable housing in New Haven.
At a recent meeting of New Haven’s Affordable Housing Task Force, Elm City Communities (ECC) Executive Director Karen Dubois-Walton advocated for new strategies to remedy New Haven’s shortage of affordable housing, including subsidies for single-room occupancy units and having individuals pay what they can afford for rent.