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DHC Letter on Moving to Work
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October 6, 1999
Susan Frank, Director
Delaware State Housing Authority, Inc.
18 The Green
Dover, Delaware 19901
RE: Moving to Work Annual Plan for FY00
Dear Ms. Frank:
This letter is in response to the request for comments on the FY2000 Annual Plan
for the Moving to Work (MTW) Demonstration Program of the Delaware State Housing Authority
(DSHA). These remarks are complementary to those which you have received from the members
of the Statewide Association of Tenants, which, in our opinion, deserve your foremost
attention, since they represent a thoughtful response by residents to the MTW Annual Plan.
Our remarks pertain to issues related to the process of implementation and to
issues affecting the likelihood of success of the program and of the resident families.
Since this demonstration program changes the landscape of public and assisted
housing in Delaware – and may well be the precursor to similar nationwide efforts
– our reservations about certain aspects of MTW are serious ones.
We have included sincere recommendations, as well, which come from a great deal of
internal dialog and consultation with residents. Our object is not to stall MTW, but
rather to offer means to transform it.
Resident Participation
Resident influence in the formation of this program has been cursory. Public comment
meetings have met the bare minimum standards for due process. Consultation with residents
has not been actively engaged. This makes MTW a predominantly managerial project, contrary
to one of the stated goals of MTW, which is to encourage mutual responsibility. For this
program, above and beyond the normal workings of a PHA, to have its best results, resident
agreement and cooperation with the assumptions and programmatic consequences of MTW is
required.
Contract
Following from the first point, the difficulty of asking residents to enter into a free
contract to become involved in MTW stems, not only from their lack of understanding of the
program goals or from the vagueness of some of the responsibilities undertaken by DSHA,
but even more from the power differential which exists between manager and resident. We
understand that MTW is an experiment, one of the objects of which is the transformation of
the institutional nature of PHAs. However, the most basic level on which PHAs –
including DSHA, unfortunately – function as institutions is in their treatment of
residents as passive objects rather than as active agents in the improvement of their own
housing units, neighborhoods, and lives.
We know of many residents who are entering into MTW with a sense of resignation
and discouragement. They not only feel that they have no choice but to sign a contract
about which they have grave concerns. In some cases, they do not even have the luxury of
reading the contract carefully or consulting with a third party. Site managers, hastening
to sign, seal, and deliver, have given residents the distinct impression that they are
being given an offer they cannot question, much less refuse. As the folk singer, Utah
Phillips reminds us, "The essence of contract is agreement, not coercion or
obedience." With so much at stake for residents, a fundamentally different attitude
should be adopted toward the contract.
The Waiting List
The Delaware Housing Coalition is receiving calls from applicants to the DSHA waiting list
already who are being told about "three strikes and you’re out," and are
puzzled by this initial warning. In some cases, the applicants would be exempt from MTW.
Reducing the waiting list by being able to move families and individuals into public or
assisted units is one thing. It is another to scare applicants away by tough language.
Another concern revolves around exactly how the unified waiting list will work. Might an
applicant from Kent County, for example, be asked to relocate to an available unit in
Sussex and then dropped from the waiting list if she did not accept it and the consequent
relocation? Again, to use the unified waiting list in this fashion – whatever the
efficiencies for management – would discourage applicants and potential applicants,
as well as raising questions about the effect of MTW on communities.
Annual Plan Requirements
Although DSHA is exempt from almost all the provisions of QHWRA, we believe that an annual
plan which addressed the significant categories mandated by the 1998 act would provide a
stronger strategic planning document: one which offered a clearer analysis of the
perceived needs and proposed solutions, one which would be a better basis for public
comment, and one which would instill greater confidence in residents and advocates as to
the direction of MTW.
Employment and Housing
One of the most worrisome aspects of MTW is the nature of the provisions being made to
help people "move to work." Since MTW proposes to make residence in public and
assisted housing a three-year "graduation" process, an ongoing stream of
low-income families will be seeking other housing opportunities, presumably in Kent and
Sussex Counties, for the most part.
The median household incomes (and corresponding hourly wage rate) for the two
counties are:
Median Household Incomes (& Hourly Wage
Equivalent)
Kent $ 34,917 ($16.79)
Sussex $ 31,367 ($15.08)
Since the majority of residents of public and assisted housing are there because
of incomes that are at or near 30% of median income – and since it has been part of
the historic mission of PHAs to provide affordable housing for this very vulnerable part
of our citizenry – MTW raises the obvious question as to whether residents are going
to be placed "at risk" by the process. While some residents may be able to
afford tax-credit units, such projects normally are affordable for families no poorer than
50% of area median income. However, just to get residents up to 50% of median requires a
healthy income.
30% and 50% of Median Household Incomes (&
Hourly Wage Equivalent)
30% of Area Median
50% of Area Median
Kent $ 10,475 ($ 5.04)
$ 17,458 ($ 8.39)
Sussex $ 9,410 ($ 4.52)
$ 15,683 ($ 7.54)
Are there adequate jobs at those wage levels to support MTW "graduates,"
and, in the absence of special homeownership programs and tax credit housing, what real
incomes are necessary for residents to succeed? We believe that additional resident
support services, such as casework and job readiness training, even at their best, will
not be able to keep up with the challenge that MTW poses. This question, of course, is the
one which provokes the greatest fear and eventual discouragement among residents regarding
MTW.
Affordable Housing Supply
A critical issue is what steps are being taken to increase the supply of "very
affordable" housing units throughout Kent and Sussex. The new Low Income Housing Tax
Credit (LIHTC) allocation plan suggests that certain downstate communities might be
saturated and should be excluded from further development (e.g., Seaford). Do these
potential policy changes take into account the transition of very low-income households
from public housing into Kent and Sussex?
Also, there is an evident need to provide more deeply subsidized housing
opportunities for residents making the transition from public housing. The standard LIHTC
project simply may not reach down far enough to serve MTW residents. New funding and
creative mechanisms should be a fundamental component of MTW provisions. If this does not
happen, the danger is that residents will be forced to move into overcrowded, rent
burdened, or substandard housing, thus defeating HUD’s goal of offering improved
housing opportunities.
Income Deconcentration and Serving the Extremely Low Income
Related to this issue, it is unclear how DSHA intends to reconcile the potentially
conflicting demands of deconcentrating poverty and serving the poorest families. Public
and Section 8 housing are the programs which have historically allowed the poorest
families to afford decent housing. If there is to be a greater preference for working
families, this will provide for a greater mix of incomes in developments and communities
and may help improve the success rate of MTW "graduates." But it raises the same
question, touched on above, of "at risk" households. If the waiting list is
shortening – even if only by virtue of movement through public and assisted units
– what is the net effect on the most vulnerable?
Effect on Developments and Neighborhoods as Communities
MTW essentially makes DSHA programs and units into one large, service-enriched
transitional housing program. In the light of the remarks above, the management of DSHA is
going to have an even greater challenge before it in the area of promoting resident sense
of ownership of public housing developments and scattered site neighborhoods. Given a
three-year limit to tenure in public or assisted housing, and without more meaningful
resident influence consciously built into the process, involvement in community life and
desire to address community problems will quite probably lessen.
Supportive Services and Interagency Collaboration
It seems that DSHA has developed the MTW program without valuable guidance and input from
all of the partnering organizations that will no doubt eventually be called to help make
the program a success. This is an unhappily familiar approach, excluding potential
partners up front and therefore not looking at all the policy ramifications when making
such momentous programmatic changes. Let us address just two examples.
Plans should have been made at an early stage to assure that residents attempting
to make a successful move would receive the case management and counseling that is
necessary. The cost of all aspects of the program should have been counted during the
initial planning stages. Even now that MTW has begun, such services are not fully in
place.
DSHA must look into the resident "credit" issues. Good credit will be
required by all credible sources of housing to which MTW residents may make the
transition. Virtually all apartment complexes serving all incomes check credit. Credit
repair can be a lengthy process, sometimes taking years. The "credit barrier"
may be a very real impediment and substantial barrier that to date we see no evidence that
DSHA has addressed.
Preliminary Recommendations:
We have some initial recommendations, mostly of a procedural nature.
We urge DSHA to implement a genuine vehicle for resident comment and initiative,
such as the Resident Advisory Board (RAB) mandated by the 1998 Quality Housing and Work
Responsibility Act (QHWRA). Even though DSHA is exempt from this requirement, it would
build a significant correction mechanism into the MTW process. The RAB could be
jurisdiction-wide and deal with many other issues in addition to the progress of MTW. The
Delaware Housing Coalition would be an enthusiastic partner in helping to make an RAB come
about.
We also strongly recommend that measures be taken to elicit greater resident
comment from specific developments. This might work in hand with the emerging resident
councils which the Statewide Association of Tenants has been working with DSHA, the League
of Women Voters, and others to establish in the multi-family public housing sites in Kent
and Sussex.
A set of third-party resource people should be gathered who can serve as monitors
to contract signings and subsequent meetings of residents and DSHA. The role of the
monitors would be to ensure that a procedure was observed that allowed fully informed
individual resident involvement in the contractual and casework aspects of MTW. Such a
device would allow DSHA to put itself "at arms length" from some MTW
transactions in which it might be viewed as overly eager to bring closure. Groups such as
the National Association for the Advancement of Colored People, the League of Women
Voters, the Center for Community Justice, and other groups would be potential pools of
volunteer monitors.
The Annual Plan needs revision and elaboration in regards to several areas upon
which we have touched above. Pains should be taken to publicize changes to the plan and to
provide clear explanations of areas of concern. Above all, resident comment should be
vigorously encouraged, with revisions and elaborations stemming from consultation with
residents.
Seek the guidance of the network of agencies and groups whose histories include
successfully figuring out how to implement many of the steps necessary to provide a firm
bridge for MTW residents.
The remarks above are a beginning at addressing concerns which have arisen in our
discussions both within the Delaware Housing Coalition and in consultation with residents
and advocates. They address the larger contours of the challenge that MTW poses. We could
extend these remarks considerably with a discussion of specific issues such as ceiling
rents, escrow account management, employment opportunities, transportation, education and
training, parenting, stress management, and community improvement.
However, we trust that the current public comment period, rather than the close of
discussion, is the beginning of an extended examination of how to improve upon MTW and
DSHA programs and procedures, in general. We are eager to have further opportunities to
work with you on these areas of great mutual interest.
Very kind regards,
Ken Smith
Director
cc: William Apgar, Assistant
Secretary/Federal Housing Commissioner, HUD
Malinda Roberts, OPIH,
HUD Regional Office, Philadelphia
Rob Solomon, Deputy
Assistant Secretary, Office of Policy, Program & Legislative Initiatives
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