On November 24, PHADA submitted the following memo to the Biden-Harris transition team, outlining priorities for the new administration’s first 100 days. Below is an excerpt of PHADA’s correspondence. The full memo is available here.
PHADA Memo to Transition Team Calls for Funding, Flexibility
The Biden-Harris Transition Team for HUD reached out to PHADA seeking input in planning for the first 100 days of the new administration. PHADA’s memo highlights the following Priorities and Recommendations:
- Include substantial Public Housing Capital Funding in an Infrastructure Package. Citing ARRA, emphasizing that Public Housing Authorities will be able to quickly deploy construction funding, helping to address all four of the Biden-Harris Team’s priorities of COVID-19, Economic Recovery, Racial Equity, and Climate Change.
- Additional Emergency Relief Funding including Public Housing Operating and Capital Funds, Housing Choice Voucher Program Housing Assistance (HAP) and Administrative Fee Funding.
- Extension of all CARES Act waivers, including funding flexibility, through the end of 2021, and a review of waiver use to identify waivers for permanent adoption.
- Reinforce administration’s commitment to the Annual Contributions Contract (ACC).
- Initiate research on racial equity impacts of HUD policies and programs.
- Revoke harmful rules, and immediately begin new rulemaking where necessary, including:
- The Mixed Family Status rule.
- The Public Charge Rule.
- The Disparate Impact Rule.
- The Preserving Community and Neighborhood Choice Rule (which replaced the Affirmatively Further Fair Housing Rule). New rulemaking was urged rather than immediate return to the prior AFFH Rule.
- The Office of the Controller of the Currency’s Community Reinvestment Act Rule.
- Begin a review of Public Housing Conversion Options and tools to simplify conversion options and ensure cost effectiveness, long-term affordability, and protection of public assets.
- Robust Funding in FY 22 Budget, including establishing a floor for 4% affordable housing bonds, expansion of the 9% Low Income Housing Tax Credit (LIHTC), and funding for the FSS Program.
- Address HUD’s Human Capital and Technology Challenges to improve operations and data collection.
PHADA is a membership organization representing approximately 1,900 public housing authority (PHA) executives from across the nation. Our membership includes public housing agencies of all types, from the largest in the country to some of the smallest.
PHADA is impressed by the quality and knowledge of the HUD transition team and is pleased to provide this response to the team’s request. This memo assumes team members are aware of the pre-pandemic housing crisis, how it has been exacerbated and accelerated by the pandemic, the crucial role housing plays in health, and many of the challenges and opportunities of our existing housing programs. If desired, additional background and information can be provided on all aspects of federal housing policy and funding covered in this memorandum.
1. Addressing Biden-Harris Priorities of COVID-19, Economic Recovery, Racial Equity, Climate Change
All the activities outlined in this memorandum will address parts of the priorities identified by the Biden-Harris Team, and PHADA believes public housing funding is an essential part of these initiatives.
Substantial public housing capital funding, specifically, would be a significant first step in addressing all four priorities. Capital funding will help PHAs address COVID19 by bringing additional units on-line, improving the quality and condition of additional units, and support PHAs to make other operational improvements to enhance their COVID19 response capacity and their ability to support households in response to the economic fallout of the pandemic. Capital funding for public housing is a proven economic stimulus, demonstrated from its origins right up to the American Reinvestment and Recovery Act of 2009 (ARRA) and the current crisis. The disinvestment in public housing also represents a significant disinvestment in low income communities which has a disparate impact on minority households. Providing substantial additional capital funding represents reinvestment in those communities. Finally, capital funding will allow PHAs to upgrade the energy efficiency and reduce the carbon footprint of public housing, and PHAs can demonstrate the effectiveness of climate change mitigation improvements to our housing stock. PHADA’s position paper on why funding for public housing through an infrastructure bill makes sense and addresses key priorities of the Biden administration can be provided.
2. Priorities & Recommended Focus Areas for the First 100 Days
Additional Emergency Relief Funding. The need for additional funding to ensure people can remain housed, and that landlords remain solvent, is urgent. However, because local need and capacity vary significantly across the nation, additional funding for multiple programs is necessary. In addition to increased funding and other actions to prevent homelessness, PHADA recommends that the following be included in any relief package:
- Public Housing Operating and Capital Funds. The Public Housing Operating and Capital funds are the two main federal sources of financial support for the physical units and operators of public housing. The CARES Act provided additional funding, along with fungibility between those two accounts, to enable PHAs to conduct a variety of activities to maintain and/or modernize housing, continue and enhance operations to accommodate remote work and other coronavirus-related management changes, and provide additional support to families sheltering-in-place during the pandemic. Additional funding will ensure PHAs can continue close-to-normal operations and enhanced resident supports as record-breaking virus transmission and a new round of public health restrictions sweep the nation. Specifically, additional capital funding will enable PHAs to bring vacant units on-line, improve the quality and safety of existing housing, counter the loss of crucial affordable housing stock, and provide economic stimulus to local and national economies.
- Housing Choice Voucher (HCV) Housing Assistance Payment (HAP) Funding. This year brought unprecedented cost increases to the HCV program. A combination of increased housing costs and decreased tenant income raised subsidy expenses for PHAs across the country. Additional funding is likely needed to prevent the termination of assisted households and should be a priority. Additionally, PHADA proposed an Emergency COVID-19 Voucher program to provide unassisted families with housing security both through the pandemic and as the nation recovers. The economic fallout from the pandemic will likely continue for years, and short-term assistance (via Emergency Solutions Grants, for example) will fail to provide families with the support they need to maintain their health, continue their education, and regain their economic stability.
- Housing Choice Voucher Administrative Fees. The funding PHAs receive to operate the HCV program, called Administrative Fees, have been severely underfunded for many years. Through the CARES Act, PHAs received additional funding to support voucher utilization, modify administrative operations, retain and recruit landlords, and provide additional support to tenants, including to secure housing.