Website, with focus on HUD Housing Vouchers, is HERE.
Originally created and posted on the Oregon Housing Blog.
Showing posts with label fair housing. Show all posts
Showing posts with label fair housing. Show all posts
Monday, January 27, 2014
Thursday, September 12, 2013
My Submitted Comments on Affirmatively Furthering Fair Housing Proposed Regulation.
Comments are due by Tuesday September 17th; I submitted my comment on Thursday. (Docket folder for this proposed regulation is HERE).
My MS Word comment letter is on my SkyDrive HERE, and embedded below:
Originally created and posted on the Oregon Housing Blog
My MS Word comment letter is on my SkyDrive HERE, and embedded below:
Originally created and posted on the Oregon Housing Blog
Friday, July 19, 2013
Proposed HUD Affirmatively Furthering Reg from Friday Federal Register.
Federal Register ink is HERE; comments due by September 17, 2013.
Originally created and posted on the Oregon Housing Blog.
Originally created and posted on the Oregon Housing Blog.
Saturday, June 22, 2013
OMB Completes Review of HUD Proposed Affirmatively Furthering Fair Housing Rule.
Review was completed on last day of spring, June 20th the SAME day it was received? Looks like no changes from rule as submitted were required.
No telling when proposed rule will be published in Federal Register, especially now that Supreme Court has take a disparate impact case for review. Here is paste in from OMB regulatory review website: (Active link shows history of rule going back to 2007).
Originally created and posted on the Oregon Housing Blog.
No telling when proposed rule will be published in Federal Register, especially now that Supreme Court has take a disparate impact case for review. Here is paste in from OMB regulatory review website: (Active link shows history of rule going back to 2007).
| AGENCY: HUD-HUDSEC | RIN: 2501-AD33 |
| TITLE: Affirmatively Furthering Fair Housing (FR-5173) | |
| STAGE: Proposed Rule | ECONOMICALLY SIGNIFICANT: No |
| ** RECEIVED DATE: 06/20/2013 | LEGAL DEADLINE: None |
| ** COMPLETED: 06/20/2013 | COMPLETED ACTION: Consistent without Change |
Originally created and posted on the Oregon Housing Blog.
Sunday, May 12, 2013
2013 OHCS QAP Includes Several Fair Housing/Housing Choice Improvements and Increased Transparency, Jump Starting Conversations for 2014 QAP/CFC.
The Housing Council package for the May 17th meeting contains the final
QAP for Council consideration as well as a summary of comments received
on the earlier draft and OHCS staff responses. [ A permanent link to all Housing Council meeting packets for 2013 is in the right pane under Oregon Housing Council Materials].
Along with the Fair Housing Council, for 2013 I had suggested the addition of a discretionary basis boost for project applications in low poverty neighborhoods. I had suggested also that the QAP expand the transparency of waivers, and add an explicit acknowledgement that they had the authority to grant waivers to affirmatively further fair housing.
I am pleased to see that those recommendations were incorporated in the 2013 QAP.
Moreover, I am pleased that OHCS acknowledges the need for an more extensive fair housing conversation and policy review for the 2014 QAP /CFC saying
In response to FHCO comments, OHCS has indicated the scoring panels will receive Fair Housing training. I anticipate this will include examples of how an application in a low income area can claim points in the scoring criteria.
Note: For non QAP policies, OHCS will be adopting temporary administrative rules and producing other related policy guidance. The OAR chapter for OHCS is HERE; looks like Division 90 contains the rules for the LIHTC program (but rule changes might also occur in other Divisions of the OHCS rules).
Originally created and posted on the Oregon Housing Blog.
Along with the Fair Housing Council, for 2013 I had suggested the addition of a discretionary basis boost for project applications in low poverty neighborhoods. I had suggested also that the QAP expand the transparency of waivers, and add an explicit acknowledgement that they had the authority to grant waivers to affirmatively further fair housing.
I am pleased to see that those recommendations were incorporated in the 2013 QAP.
Moreover, I am pleased that OHCS acknowledges the need for an more extensive fair housing conversation and policy review for the 2014 QAP /CFC saying
" Within the next six months OHCS will facilitate a work group to research and recommend Fair Housing policies for program adoption that will be incorporated into Permanent Rules."(My 2013 QAP comments included a listing of the kinds of topics I think should be included in that conversation and policy review).
In response to FHCO comments, OHCS has indicated the scoring panels will receive Fair Housing training. I anticipate this will include examples of how an application in a low income area can claim points in the scoring criteria.
Note: For non QAP policies, OHCS will be adopting temporary administrative rules and producing other related policy guidance. The OAR chapter for OHCS is HERE; looks like Division 90 contains the rules for the LIHTC program (but rule changes might also occur in other Divisions of the OHCS rules).
Originally created and posted on the Oregon Housing Blog.
Friday, March 22, 2013
My Comments on Clackamas County HA Annual Plan.
My written testimony is HERE; video of my oral testimony is HERE and embedded below. (Is my cabeza really that large?)
MY HACC testimony focused on public housing and voucher comments that I had already included in the February 25th comments I made on the County draft 2012 Analysis of Impediments.
I believe the Civil Rights certification from the county will be subject to challenge if the fair housing impediments and corrective actions I have identified are not addressed in the final HACC plan scheduled to go to the County Commissioners on April 4th. (I have a similar view about the pending county annual Community Development application for HUD HOME and CDBG funds).
Originally created and posted on the Oregon Housing Blog.
MY HACC testimony focused on public housing and voucher comments that I had already included in the February 25th comments I made on the County draft 2012 Analysis of Impediments.
I believe the Civil Rights certification from the county will be subject to challenge if the fair housing impediments and corrective actions I have identified are not addressed in the final HACC plan scheduled to go to the County Commissioners on April 4th. (I have a similar view about the pending county annual Community Development application for HUD HOME and CDBG funds).
Originally created and posted on the Oregon Housing Blog.
Monday, March 11, 2013
In Advance of Fair Housing Month: One Easy Thing HUD Could Do to Promote Fair Housing in LIHTC Program.
HUD publishes an annual database of LIHTC projects placed into service HERE. It includes a data field showing the 2010 Census Tract ID as well as the zip code. (Most recent data dictionary is HERE).
ACS 5 Year poverty data is available at the census tract AND zip code level.
My prior post HERE has an Excel file that matches up Oregon LIHTC projects with ACS 5 Year poverty rates at the census tract level.
HUD could do a similar match each year to include the most recent poverty rate (and counts) at the zip code AND census tract level for all LIHTC projects in their database. This would allow users and researchers to parse out the percentages and counts of LIHTC projects and units in a given locality that are located in areas with high or low poverty rates.
In addition to assisting in evaluating access to opportunity it would also help evaluate housing choice available to voucher holders who are a key eligible population for LIHTC projects.
Originally created and posted on the Oregon Housing Blog.
ACS 5 Year poverty data is available at the census tract AND zip code level.
My prior post HERE has an Excel file that matches up Oregon LIHTC projects with ACS 5 Year poverty rates at the census tract level.
HUD could do a similar match each year to include the most recent poverty rate (and counts) at the zip code AND census tract level for all LIHTC projects in their database. This would allow users and researchers to parse out the percentages and counts of LIHTC projects and units in a given locality that are located in areas with high or low poverty rates.
In addition to assisting in evaluating access to opportunity it would also help evaluate housing choice available to voucher holders who are a key eligible population for LIHTC projects.
Originally created and posted on the Oregon Housing Blog.
Monday, February 25, 2013
My Comments on Clackamas County Analysis of Fair Housing Impediments.
The draft AI is HERE; my comments, with 10 identified problems and 13 suggested corrections, is HERE.
Originally created and posted on the Oregon Housing Blog.
Originally created and posted on the Oregon Housing Blog.
Friday, February 15, 2013
Tuesday, February 12, 2013
Video from Lake Oswego Council Meeting Terminating Foothills Urban Renewal, Including Affordable Housing Funding.
My prior post on the repeal is HERE; video I created and posted to the Internet Archive is HERE and embedded below. [My testimony is at 1:08:50 and the testimony of Pegge McGuire is at 1:33:02].
(Post with video of prior Council approval of Foothills Urban Renewal Plan and Area, from December 4, 2012, is HERE).
Note that file can be viewed on line or downloaded, but that download size is VERY large at 1.7 GB's.
Originally created and posted on the Oregon Housing Blog.
(Post with video of prior Council approval of Foothills Urban Renewal Plan and Area, from December 4, 2012, is HERE).
Note that file can be viewed on line or downloaded, but that download size is VERY large at 1.7 GB's.
Originally created and posted on the Oregon Housing Blog.
Friday, February 8, 2013
Saturday, February 2, 2013
First Term HUD Scorecard on Fair Housing is Mixed.
Report from Poverty and Race Research Action Council is HERE. Excerpt:
Originally created and posted on the Oregon Housing Blog.
..while fair housing enforcement at the agency has increased noticeably, the task of reforming HUD’s own programs has been painstakingly slow. A flurry of positive activity inside the agency during the first term has not yet been reflected in final program regulations or guidance, even though some of this work has been underway for years
Originally created and posted on the Oregon Housing Blog.
Tuesday, January 15, 2013
Clackamas County Publishes Long Delayed Fair Housing Analysis of Impediments.
Out of blue this long delayed report has appeared on the Clackamas County Community Development Department website.
The Executive summary is HERE; full AI is HERE , with action items found on pages 56-58. This will take some time to digest; I don't see any opportunity to comment shown in these documents, nor does it appear that this has been on any prior County Commission agendas.
Originally created and posted on the Oregon Housing Blog.
The Executive summary is HERE; full AI is HERE , with action items found on pages 56-58. This will take some time to digest; I don't see any opportunity to comment shown in these documents, nor does it appear that this has been on any prior County Commission agendas.
Originally created and posted on the Oregon Housing Blog.
Monday, November 26, 2012
Clackamas County: No Draft Analysis of Impediments to Fair Housing, 90+ Days After Last Advisory Committee Meeting.
Not sure what the hang up is, but Clackamas County still has not published a new draft Analysis of Impediments to Fair Housing 90+ days after the final Advisory Committee meeting (August 21st). (I particpated in last two of three Advisory Committee meetings).
CC Community Development staff continue to respond to repeated inquiries with indication that consultant draft prepared months ago is still "under review". Their HUD Consolidated Plan indicated that AI would be completed in "Fall 2012".
Originally created and posted on the Oregon Housing Blog.
CC Community Development staff continue to respond to repeated inquiries with indication that consultant draft prepared months ago is still "under review". Their HUD Consolidated Plan indicated that AI would be completed in "Fall 2012".
Originally created and posted on the Oregon Housing Blog.
Monday, October 29, 2012
Updated: ProPublica Story from Former Oregonian Reporter: Living Apart, How the Government Betrayed a Landmark Civil Rights Law.
Updated to include links to ebook versions:
-----------------
Story from Nikole Hannah-Jones is HERE, includes an e-book version(but link within story doesn't currently work properly); iBooks version is HERE, Kindle HERE.
Story does not include an references that I can see to Portland.
Originally created and posted on the Oregon Housing Blog.
-----------------
Story from Nikole Hannah-Jones is HERE, includes an e-book version
Story does not include an references that I can see to Portland.
Originally created and posted on the Oregon Housing Blog.
Thursday, September 20, 2012
HUD Release of LIHTC Tenant Demographic Data: Not This Year or Anytime Soon that I Can See.
2008 Recovery Act legislation required state Housing Finance Agencies (HFA's) to submit LIHTC tenant demographic information to HUD (see statutory reference HERE). The HFA submissions to HUD in the fall of 2011 was at least the second year the data was submitted to HUD.
After waiting for several months for state level summaries of tenant demographic data from HUD, I asked HUD HQS staff this week via email and was advised that because of funding constraints HUD would NOT be doing any state level summaries of the LIHTC tenant data submitted by HFA's in the fall of 2011. (In my prior post HERE I linked project (not tenant) LIHTC data that HUD has recently updated with 2010 poverty data from ACS).
With HUD appropriations not likely better in FY 2013 than in FY 2012, it seem highly unlikely that HUD will produce summaries of LIHTC tenant demographics any time soon, rendering the statutory reporting requirement somewhat meaningless. It also appears that HUD is out of statutory compliance with the requirement that :
With HUD's failure to post already collected LIHTC tenant demographic data, I expect the better local approach to find out who is served by LIHTC projects will be to refocus attention on getting OHCS to compile and publish state and LIHTC tenant demographic local summaries, since they are still required to submit data annually to HUD. (My prior post on OHCS tenant data collection efforts is HERE).
Originally created and posted on the Oregon Housing Blog.
After waiting for several months for state level summaries of tenant demographic data from HUD, I asked HUD HQS staff this week via email and was advised that because of funding constraints HUD would NOT be doing any state level summaries of the LIHTC tenant data submitted by HFA's in the fall of 2011. (In my prior post HERE I linked project (not tenant) LIHTC data that HUD has recently updated with 2010 poverty data from ACS).
With HUD appropriations not likely better in FY 2013 than in FY 2012, it seem highly unlikely that HUD will produce summaries of LIHTC tenant demographics any time soon, rendering the statutory reporting requirement somewhat meaningless. It also appears that HUD is out of statutory compliance with the requirement that :
(c) Public availability: The Secretary shall, not less than annually, compile and make publicly available the information submitted to the Secretary...
With HUD's failure to post already collected LIHTC tenant demographic data, I expect the better local approach to find out who is served by LIHTC projects will be to refocus attention on getting OHCS to compile and publish state and LIHTC tenant demographic local summaries, since they are still required to submit data annually to HUD. (My prior post on OHCS tenant data collection efforts is HERE).
Originally created and posted on the Oregon Housing Blog.
Tuesday, September 4, 2012
Update: Baltimore Regional AI Demonstration Notice Coming Tomorrow, Using FHA Multfamily Financing Incentives as Carrot.
Update:
Have added link to Court Settlement item in NLIHC Memo to Members that provides more context for regional AI demonstration
--------
Notice will be in Federal Register on Wednesday, I have posted advance notice HERE.
Notice indicates FHA financing incentives will be offered for projects that either project base vouchers or offer below market rents for 2 or more bedroom non elderly units. Projects participating in the demonstration will also be required to accept voucher holders (appears similar to the requirement for LIHTC projects, but all units in these projects may not have rents affordable to voucher holders).
Eligible projects will also be limited to "areas of opportunity" that are part of a prior court settlement. NLIHC Memo to Members court settlement update is HERE.
Originally created and posted on the Oregon Housing Blog.
Have added link to Court Settlement item in NLIHC Memo to Members that provides more context for regional AI demonstration
--------
Notice will be in Federal Register on Wednesday, I have posted advance notice HERE.
Notice indicates FHA financing incentives will be offered for projects that either project base vouchers or offer below market rents for 2 or more bedroom non elderly units. Projects participating in the demonstration will also be required to accept voucher holders (appears similar to the requirement for LIHTC projects, but all units in these projects may not have rents affordable to voucher holders).
Eligible projects will also be limited to "areas of opportunity" that are part of a prior court settlement. NLIHC Memo to Members court settlement update is HERE.
Originally created and posted on the Oregon Housing Blog.
Sunday, August 26, 2012
Under Court Order Westchester Inching Forward Toward Source of Income Legislation.
Tuesday, August 7, 2012
HUD Publishes Project Based Tenant Characteristics Report, National Data Only.
Unlike public housing, getting tenant demographic information for HUD's project based multifamily family programs has been next to impossible.
I ran across a new national summary report HERE that shows some very limited demographic data through June 30, 2012 for HUD multifamily project based rental programs. This PDF reports includes some income and race/ethnicity data, and a breakout of households with children and the elderly, but no data on female heads of households.
Unfortunately, total female heads of household data is also missing from HUD's public housing and voucher Resident Characteristics Report, although that data IS reported by housing authorities. Public data from this source is also available down to the public housing authority level.
HUD also annually collects LIHTC demographic data and should be releasing that data soon for last year, hopefully at the state level and hopefully including data on female heads of households.
Monday, July 30, 2012
US Attorney Asks Court to Compel Westchester County (NY) to Comply with Settlement Agreement.
NLIHC summary (and links to more materials) is HERE.
Originally created and posted on the Oregon Housing Blog.
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