NYHC, Legal Aid Society, Community Service Society and 47 additional organizations signed on to joint comments voicing concerns regarding HUD’s proposed SAFMR changes to the Section 8 Housing Choice Voucher Program. It is estimated that nearly 56,000 NYC households would see their Section 8 subsidy decrease, forcing tenants to move in a tight rental market or pay more of their income towards rent to stay in their current home.

Click here to view full comment submission.

Overview of HUD Proposal:

HUD proposes to introduce Small Area Fair Market Rents (SAFMR) to New York City. With promising outcomes in a Dallas demonstration program, HUD proposes new rules for New York City and other regions with high levels of voucher concentration to both encourage and enable voucher holders to move to areas of higher opportunity and lower poverty. Instead of a citywide fair market rent (FMR), rents will be set by zip code. This “cost effective” proposal will raise allowable rents in some zip codes and lower them in others to more accurately reflect housing sub-markets within a region. This proposal is full of promise and may work well in some localities but in a high-cost, extremely low-vacancy city like New York, it will have disastrous consequences. Nearly 56,000 voucher holders’ rental assistance payments would go down.

HUD’s proposal is made without a Section 8 budget increase, so housing “opportunity” for some low-income families will come at the expense of others.  Families who choose to stay in their current homes in low-income areas or those who are unable to move, will literally pay the price of higher rents for families using their voucher in more expensive neighborhoods.  Half of impacted households are elderly and/or disabled with average annual income of less than $15,000. In a red hot real estate market which has driven homelessness to all-time heights and a vacancy rate of 3.4%, classified at emergency level by HUD, finding an apartment at all will be a challenge, even in an only marginally lower-poverty neighborhood.

With 246 zip codes in New York City, this proposal would also be a very complicated and confusing system for new voucher holders and landlords to navigate.

Overview of Recommendations in Joint Comments:

  1. HUD should add vacancy rate to its methodology for selecting SAFMR areas and exempt all areas with vacancy rate below 5%.
  2. HUD’s hypothetical SAFMR should be revised to reflect current market conditions in New York City’s rapidly gentrifying neighborhoods.
  3. HUD should hold harmless all current tenants.
  4. Project based vouchers should be exempt from these new rules.
  5. HUD should delay implementation until a significant budget is available to accompany this proposal and also to allow more time to study a more effective approach to achieve stated goals in low-vacancy areas.

Additional Information:

THANK YOU TO OUR ENDORSERS:

Associated Builders and Owners of Greater New York * Association for Neighborhood & Housing Development (ANHD) * Barrier Free Living * Benchmark Title Agency * Brooklyn Defender Services * Center for Independence of the Disabled (CIDNY) * Coalition for the Homeless * Community Action for Safe Apartments (CASA) * Community Voices Heard * Cooper’s Square Committee * Diego Beekman Mutual Housing Association, HDFC * Dunn Development Corp. * Fifth Avenue Committee * Flatbush Tenants Coalition * Fund for Public Housing * Goddard Riverside Law Project * HAP Investments * HOMECONNECT * Homeless Services United * Housing Conservation Coordinators (HCC) * Housing Court Answers * JASA/Legal Services for the Elderly in Queens * Legal Services NYC * Lenox Hill Neighborhood House * Make the Road NY * MFY Legal Services * Mutual Housing Association of New York (MHANY) * Nazareth Housing Inc. * Neighborhood Restore HDFC * Neighbors Helping Neighbors * New Destiny Housing Corporation * New York Affordable Housing Management Association (NYAHMA) * New York Communities for Change * New York Legal Assistance Group (NYLAG) * Northern Manhattan Improvement Corporation (NMIC) * NYC Housing Partnership * NYSAFAH * Shinda Management Corporation * Tenants & Neighbors * The Bronx Defenders * United Cerebral Palsy of NYC * Urban Homesteading Assistance Board * Urban Justice Center—Community Development Project * Urban Justice Center – Safety Net Project * Vocal NY * Volunteers of Legal Services * West End Residences HDFC, Inc