Response to the Proposed NYCHA Draft FY2011 Annual Plan

8/9/2019 Response to the Proposed NYCHA Draft FY2011 Annual Plan

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Page 1 of 13 NYC Alliance to Preserve Public [email protected]

ALLIANCEtoPreserve Public HousingFormed with the

participation of: (List in

ormation)

Black Youth Council

Citizens Committee for

Children of New York

Citywide Council of

Presidents

Community Service

Society

Community Voices

Heard

FUREE

GOLES/PHROLES

Legal Aid Society

NYC Public Housing

Resident Alliance

Public Housing

Communities

Tenants and Neighbors

Urban Homesteading

Assistance Board

NYC Councilwoman

Gale Brewer

NYC Councilwoman

Margaret Chin

NYC Councilwoman

Letitia James

NYC Councilwoman

Rosie Mendez

NYC Councilman Ydanis

Rodriguez

NYS Assemblyman

Brian Kavanagh (Co-

ounder SOUND)

NYS Senator Daniel

Squadron (Co-founder

SOUND)

NYS Senator Tom

Duane

NYS Senator

Velmanette

Montgomery

Congresswoman Nydia

Velasquez

(list in formation)

June 30, 2010

Chairman John B. Rhea

New York City Housing Authority

250 Broadway

New York, NY 10007

Dear Chairman Rhea,

We, the members of the NYC Alliance to Preserve Public Housing, respectfully

submit the attached comments as our collective response to the proposed

NYCHA Draft FY2011 Annual Plan.

Public housing in New York City was born 76 years ago during the mostchallenging economic period this country has ever seen. The goal was to assure a

safe and affordable life for low and middle income New Yorkers with an overall

record of success. Over the decades the system has weathered many economic

downturns and mostly maintained true to its founding vision.

However in recent decades various administrations have made expedient

decisions which have resulted in a form of benign neglect. Buildings are

deteriorating, families are displaced, services are curtailed. The current deficit

continues this unfortunate trend towards surgical solutions that diminish both

the number of units available within this priceless public resource as well as the

quality of life for the residents.

We have an opportunity for renewal of our public housing and return to living

conditions that have sustained hope for generations. It would be a grave error

not to make the most of this opportunity to review and improve.

We offer our perspectives and ideas as tenants and partners with you in our

shared vision of a renewed New York City Housing Authority.

Respectfully submitted,

The New York City Alliance to Preserve Public Housing


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ALLIANCEtoPreserve Public HousingNYC ALLIANCE TO PRESERVE PUBLIC

HOUSING

Alliance Membership andSupport

The Alliance Response has the support of the following advocacy groups and elected

officials. (List in formation)

Advocacy GroupsBlack Youth Council

Citizens Committee for Children of New York

Citywide Council of Presidents

Community Service Society

Community Voices Heard

FUREE

GOLES/PHROLES

Legal Aid Society

Mothers on the Move

NYC Public Housing Resident Alliance

Public Housing Communities

Tenants and Neighbors

Urban Homesteading Assistance Board

Government Officials

US Congress

Congressman Charles B. Rangel

Congressman Jerrold Nadler

Congresswoman Nydia M. Velazquez

NYS Legislature

NYS Senator Velmanette Montgomery

NYS Senator Tom Duane

NYS Senator Daniel Squadron (Co-founder SOUND

Housing Campaign)

NYS Assemblyman Richard B. Gottfried

NYS Assemblyman Brian Kavanagh (Co-founder

SOUND Housing Campaign)

NYC Council

NYC Councilwoman Gale Brewer

NYC Councilwoman Margaret Chin

NYC Councilman Robert Jackson

NYC Councilwoman Letitia James

NYC Councilwoman Rosie Mendez

NYC Councilman Ydanis Rodriguez

NYC Councilman Jumaane D. Williams


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ALLIANCEtoPreserve Public HousingRESPONSETO THENYCHA DRAFT 2011 ANNUAL PLAN

June, 2010

The Alliance is a collaboration of resident leaders, housing advocates, and concerned elected officialsto press for policies to strengthen our public housing communities and extend housing opportunities

under the Section 8 voucher program. We seek a stronger resident and community voice in

government decisions that affect these communities, as well as greater openness and accountability

on the part of the New York City Housing Authority (NYCHA).

Alliance members have reviewed the NYCHA Draft FY2011 Annual Plan. This position paper describes

the key issues identified in the plan and puts forward our joint recommendations. Our concerns are

organized under the following Major Issues headings:

y The Section 8 Voucher $19 Million Shortfally How Public is a NYCHA Plan? How Significant is an Amendment?y Cant NYCHA Plan Before it Uproots Residents?y Stricter Standards for NYCHA Demolition/Dispositiony Replacement of Lost Public Housing Unitsy Safety and Security Issuesy Job and Training Opportunitiesy Getting Timely Repairsy Support the Community and Senior Centersy Programs/Services for Disabled Residents


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ALLIANCEtoPreserve Public HousingTHE SECTION 8 VOUCHER $19 MILLION SHORTFALL

NYCHA intends to plug its current $19 million dollar deficit on the backs of the low income New

Yorkers it serves. It plans to lower the subsidy it provides to Section 8 voucher holders, by

decreasing its payment standard to 95% of the Fair Market Rent (FMR). About 47,000 families

will be affected by this action, increasing their out-of-pocket rent by an estimated $100-$200 permonth.

Never in the 35-year history of NYCHA administration of the Section 8 program has there been

a mass reduction in the authoritys rent contributions. Voucher families are among the poorest in

New Yorkalmost all are extremely low income, up to 30% of area medium income. This

unprecedented action will put families in serious rent arrears, at risk of Housing Court action and

homelessness at enormous costs to the City. The City will be forced to use various entitlement

programsDRIE, SCRIE, FEPS or HRA emergency grantsto cover these increases. Either

way, the City will end up paying the bill.

We recommend:1) The City should act to prevent evictions and dislocations of voucher holders, by providing

interim, short-term funding to NYCHA to solve the immediate Section 8 crisis, until new federalfunds become available for Fiscal Year 2011. To the extent possible, the City should use localrent assistance programs like SCRIE, DRIE, FEPS, and EA grants to cover unaffordable rentincreases imposed on voucher holders.

2) The State should immediately raise public assistance shelter allowance levels for public housingfamilies to the full amount now received by private landlords. At present, the increases aregraduated and have not reached the full allowance level.

3) The City should abandon its appeal of the Casado v. Markus decision, 402267/08. This caseinvalidated the poor tax rent increase, which NYCHA paid for Section 8 voucher recipients inrent-stabilized apartments in 2008 and 2009. About $8 million for each year could be raised for

NYCHA's Section 8 program, totaling $16 million.


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ALLIANCEtoPreserve Public HousingHOW PUBLICIS A NYCHA PLAN? HOW SIGNIFICANTIS AN AMENDMENT?

The NYCHA proposal to demolish the remaining 267 vacant units at Prospect Plaza was not in its

Draft Plan when its June 2009 public hearing was held. It was later rushed through a September

30th Resident Advisory Board (RAB) meeting, without adequate time for review, without notice or

a public hearing, then sent to HUD in mid-October. NYCHA later explained at City Councilhearings that it did not consider the demolition a significant amendment.

The question remains: What constitutes a significant amendment? In a high-cost, low-vacancy

rental market like NYC, we believe any NYCHA proposal to demolish public housing must be

considered a significant amendment to its plan, requiring 45-day notice and a citywide public

hearing. .

Other amendments with significant consequences have been inserted into NYCHA plans without

adequate notice or public airing: In 2007, NYCHA amended its standard of admission to bar for

5 years any persons who lost their claims as remaining family members. In 2009, NYCHA

amended its pet policy without adequate notice or time to comply, before evictions were put intomotion. Despite a recent extension, many residents have not had enough time to comply and are

at risk of eviction.

What does NYCHA consider a significant amendment? On page 118 of the draft 2011 plan,

NYCHA says it is either: 1) the result of a change in federal law, or 2) any other event that the

Authority determines to be a significant amendment, in other words, whatever NYCHA

considers significant.

We Recommend:

NYCHAs definition is not acceptable. The Annual Plan is a public document, required under

federal law, to make housing authorities more accountable to residents and the concerned public.We strongly recommend that any NYCHA proposal that may result in

1) Demolition of public housing,2) Disposition of its property, or3) Resident evictions or changes in admissions policy,

be considered significant, and require 45-day notice and a citywide public hearing.


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ALLIANCEtoPreserve Public HousingCANT NYCHA PLAN BEFOREIT UPROOTS RESIDENTS?

In the past year, it has become clear that two major NYCHA redevelopment projectsProspect

Plaza in Ocean Hill-Brownsville, and A. Phillip Randolph Houses in Central Harlemresulted in

the uprooting and relocation of hundreds of residents who were promised return rights within a

few years. Relocated Prospect Plaza residents have been waiting since 1998, Randolph Houseresidents since 2002. In both cases, the proposed reconstruction has not yet taken place and is

still under design. In Whitman-Ingersoll Houses, where substantial rehabilitation is taking place,

many relocated residents are not clear on reasons for delays and when they can return to their

homes.

We recommend:

NYCHA must do a better job of planning for staged redevelopment in a way that assures timely,

forward movement of rehabilitation and redevelopment plans and minimizes the dislocation of

former residents. Large-scale relocation of residents should not be allowed to happen until plans

are certain. Prospect Plaza and Randolph Houses delays should never have happened.


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ALLIANCEtoPreserve Public HousingSTRICTER STANDARDS FOR NYCHA DEMOLITION/DISPOSITION

In addition to languishing demolition/redevelopment projects, the NYCHA 2011 Draft Plan

envisions the sale, transfer, or leasing of vacant land for housing and other redevelopment

purposes. Often residents claim they were not notified in advance, even when NYCHA claims

that resident consultationwith the established Resident Counciltook place. Opportunitiesfor consultation and review by the community at large are often minimal.

We recommend:

Any proposal that involves the demolition of apartments or the disposition of NYCHA property

should require:

1) Written notification by NYCHA to all affected residents concerning project plans and thescheduling of resident consultation.

2) NYCHA compliance with state and locally-mandated environmental review processes. Theauthority must also provide assurances that the terms of any disposition, and the revenuesit receives, represent fair value for the property transfer, sale, or lease.

3) In proposals that involve the demolition of housing units:a. 45-day notice and conduct a citywide public hearing, prior to including the proposal

in its Annual Plan.b. An analysis of the costs and benefits associated with preservation vs. demolition of

existing units and redevelopment.c. A redevelopment plan, in consultation with affected residents, including firm plans

for financing the project and replacing (one-for-one) any units to be lost.d. Written assurances to displaced residents of their right to return.


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ALLIANCEtoPreserve Public HousingREPLACEMENT OFLOST PUBLICHOUSING UNITS

Any NYCHA proposal for housing demolition must also address plans to replace the lost public

housing units, so that the size of this critical low-income housing resource is not eroded, but

preserved. Given the demolitions proposed in the 2011 Draft Plan, it is surprising that NYCHA is

not pursuing a replacement strategy, (as indicated on page 99 of the Plan where it fails to checkoff replacement as one of its key strategies.) NYCHA must give greater attention to replacement

of the units it is about to demolish,

We recommend:

For Prospect Plaza, Randolph Houses, and any other development currently slated for demolition,

there must be a plan forone-for-one replacement of lost units.


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ALLIANCEtoPreserve Public HousingSAFETY AND SECURITYISSUES

NYCHAs trespass policy has contributed to an environment of fear. Many residents report

harassment and maltreatment by the NYC police, the agency charged with their protection.

Senior citizens have received tickets while reading the paper or drinking coffee in the public

areas of their developments. Some resident leaders were threatened with arrest when theyspoke up for a neighbor unable to provide identification fast enough. Residents have been

arrested on the grounds of their development when visiting a friend or relative in another

building. Abuses of the trespass policy have become so widespread that the Citywide

Council of Presidents (CCOP) issued a position paper to Chairman Rhea and Police

Commissioner Kelly demanding program review. NYCHA pays $73 million a year to the

NYPD, for enhanced police services. Residents are not criminals, they are hardworking

New Yorkers. Harassment is not an enhanced police service, its an injustice! NYCHA

residents want their communities to be safe, without their being randomly targeted.

We recommend:

1) NYCHA install camera systems in all developments to monitor activity.2) NYCHA provide and maintain working entrance systems that allow guests to buzz residents

they wish to visit.3) NYPD/NYCHA hire a community liaison in each development to help officers distinguish

between residents and visitors.4) NYCHA employ security guards to ensure residents are safe entering and leaving their

building.


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ALLIANCEtoPreserve Public HousingJOB AND TRAINING OPPORTUNITIES

An estimated 20,000 to 30,000 working-age NYCHA residents are unemployed and seeking

work in this economic recession. While the data provided in the draft Annual Plan indicates

significant improvements in NYCHA compliance with HUD Section 3 requirements to use

federal funds to maximize resident job and training opportunities, there is still much more to bedone. In particular, NYCHA pays contractors hundreds of millions each year, yet residents face

contractor resistance in hiring. When they are hired, the work is often temporary and short-term,

landing workers back in the ranks of the unemployed.

We recommend:

1) NYCHA must do a better job of selecting, working with, and monitoring contractorsfor bothcapital improvements and servicesto promote maximum compliance with Section 3 andassure that opportunities lead to decent, sustainable jobs.

2) The $73 million paid annually by NYCHA to the Police Department should be used to open uptraining/job opportunities in enforcement and security work, as well as in related clerical jobs.This effort could be geared to a community policing model in NYCHA developments, ratherthan rotating NYPD assignments.

3) NYCHA should spell out its plan for coordinating its Section 3 job/training efforts as part of theambitious greening agenda and goals contained in the Plan 2030 for New York City.


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ALLIANCEtoPreserve Public HousingGETTING TIMELYREPAIRS

No repairs until 2011!!that is what many residents are told when they call the Centralized Call

Center (CCC) to request repairs. As a result, they must live for months or years in apartments

with holes in the wall and floor, faulty plumbing, chipped paint, or rodent infestation. Several

developments were without cooking gas for months. While NYCHA zealously pursues residentsfor short-term rent arrears, the authority has a more casual attitude toward its legal duty to

provide safe, habitable apartments, as required under federal and state law.

We recommend:

1) NYCHA establish in each borough a mobile repair capacity for timely response to residentsserious repair requests.

2) NYCHA develop, with resident consultation, a system to record repair requests, track the repairresponse time, and assess results.

3) As a disincentive to delayed repairs, NYCHA should issue rental credits to residents who arewithout critical servicessuch as cooking gas, heat, or waterfor more than a month.


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ALLIANCEtoPreserve Public HousingSUPPORTTHECOMMUNITY AND SENIORCENTERS

NYCHA developments are home to 134 community centers and 133 senior centers. In the

last decade, the budget of the NYCHA Community Operations Department has been

drastically reduced. As a result, many essential youth and senior programs have been

closed and critical services are not being provided.

We recommend:

1) NYCHA restore the budget of its Community Operations Department.2) HUD press for additional federal budget appropriations to increase annual operating

subsidies and ROSS grants for resident programs and services.


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Documents

Response to the Proposed NYCHA Draft FY2011 Annual Plan