March 15, 2007
Tina Brooks, Undersecretary
Department of Housing and Community Development
100 Cambridge Street, Suite 300
Boston, MA 02114
Dear Undersecretary Brooks:
As the Department of Housing and Community Development (DHCD) begins the process of redrafting the Department’s Analysis of Impediments to Fair Housing Access and Action Steps to Mitigate Impediments (AI), United Disability Housing Partnership would like to take the opportunity to express some concerns with the original draft document and to offer suggestions as you move forward.
United Housing is a cross-disability coalition of 60 member organizations from across Massachusetts dedicated to expanding housing opportunities for persons living with disabilities. Our member organizations serve a wide range of disability constituencies, including those living with HIV/AIDS, developmental disabilities, mental health concerns, head injuries, and mobility impairments.
For the past two years, we have been meeting regularly with DHCD on a variety of issues, including rental vouchers, the development of regulations for the Community Based Housing program, and fair housing issues. These meetings have been extremely productive and we would like to continue them in the future.
The AI, as drafted last year, represents a good starting point for discussion of fair housing barriers confronting persons with disabilities. While the document identifies certain impediments and offers some solutions, far greater specificity is needed in DHCD’s plan to respond if it is to effectively address impediment issues.
The following outlines our specific concerns with the document:
Data Collection
Page 99 of the Analysis of Impediments to Fair Housing Access (AI) states that, “There is a Paucity of Data on Occupants of Subsidized Housing.” To address this issue, the AI proposes that DHCD “Collect, analyze, and report on relevant data pertaining to racial / ethnic minorities and other protected classes in subsidized housing programs and report on DHCD fair housing initiatives.”
United Housing is in complete agreement with the need to have information on the residents of DHCD housing. However, we are concerned about a lack of specificity in the AI about the type of information to be gathered, particularly with respect to persons living with disabilities and the housing units that are available within the Commonwealth. The following are United Housing’s suggestions about some of the types of data that should be collected:
The number and location of all accessible housing units funded or administered by DHCD, Mass Housing, and Mass Development.
The number and location of all accessible housing units which are either vacant or occupied by residents who do not need accessible features.
The number of individuals or families who require housing units with accessible features who are living in inaccessible units.
The number of individuals and families who receive MRVP assistance (or who are on the waitlist) who have a family member with a disability and the number of these families who have a head of household with a disability.
The number of individuals and families who require housing units with accessible features and are on waiting lists for state-funded public housing.
The percentage of younger persons with disabilities and elders living in state-aided elderly/disabled housing. This will better ensure the state is in compliance with statutes dividing up these resources among the two groups of people and will help people with disabilities and elders improve their housing search.
Community-Based Housing
Page 95 of the AI states, “There Exists Ongoing Segregation and Stigmatization of People With Disabilities.” Through expanded utilization of current DHCD housing construction and rental voucher programs, and proactive implementation of universal design/visitability standards in state-funded housing, the Department has an opportunity to dramatically reduce segregation and stigmatization for this group.
Persons living with disabilities are a diverse population with individualized needs and preferences. A majority of respondents to an MRC survey indicated a preference to live independently in the community. Others, however, either prefer or require a more congregant setting such as a group home or nursing facility.
DHCD can help increase the housing options available to persons living with disabilities by expanding both the Community Based Housing (CBH) program and the Facilities Consolidation Fund. For CBH in particular, expanding the funding available for this program would help facilitate the construction of housing units for persons with disabilities that are integrated into the larger community. United Housing recommends that the Department double the bond cap allocation for CBH over the next four years.
Beyond those programs targeted at persons living with disabilities, United Housing would ask that all DHCD and Mass Housing programs ensure that they are inclusive of persons with disabilities. For example, programs such as the Affordable Housing Trust Fund, which also serves this diverse population, should include language in its regulations to make them better able to meet the needs of diverse populations.
Proactively implementing principles of universal design and visitability in all state-funded housing and federal units administered by DHCD would represent a major step in ending the isolation and segregation of persons living with physical and sensory disabilities. Universal design standards allow housing units to be flexible to meet the changing needs of residents rather than forcing residents to move out. Effective implementation of these standards will allow older persons to age in place and are beneficial to the specific needs of all protected classes. Visitability allows persons with disabilities to become full members of their community by increasing the access to their neighbors. This is done by instituting design standards that allow persons with disabilities to visit their neighbors through the provision of such low-level accessibility as zero grade entrances, wide hallways, etc.
United Housing encourages DHCD to work closely with fair housing organizations here in Massachusetts to develop trainings and materials that would establish meaningful standards of universal and accessible design for all new residential state-funded construction.
While expanding the number of housing units available to persons living with disabilities is vitally important, the lack of affordability of housing in our area often keeps individuals with disabilities from being able to live independently. For many people with disabilities, SSI is their sole source of income. A monthly SSI payment is $730 a month, while the average fair market rent in Massachusetts is $987. For a person relying on SSI for income, rent is unaffordable without rental assistance.
Increased funding of the state’s primary rental voucher programs (MRVP and AHVP) will provide significant relief in the affordability crisis facing persons living with disabilities trying to find housing. Current funding for both of these rental assistance programs is inadequate to support the number of vouchers needed. We recommend that DHCD work with the legislature to secure sufficient appropriations for both MRVP and AHVP that would at least restore each program to their highest historic funding levels.
Transportation Access and Interdepartmental Coordination
Page 125 of the AI recommends that, “DHCD encourage smart growth development near mass transit.” Access to transportation is extremely important for persons living with disabilities, many of whom depend on mass transit to get to jobs, medical appointments, and to be fully participating members of the community.
However, there are an extremely limited number of communities in Massachusetts that have a sufficient mass transit infrastructure to support significant transit-oriented development. To address this, there must be a coordinated effort to improve public transportation in metropolitan areas across the Commonwealth.
United Housing recommends that DHCD work closely with the Department of Transportation to develop transit-oriented housing around newly-created public transportation hubs. This fits well with Governor Patrick’s goal to improve coordination across state agencies.
DHCD Staff Structure
While not specifically addressed within the AI, United Housing strongly recommends that DHCD establish a senior-level staff position within the Department with responsibility over all fair housing concerns. By establishing such a position with clear authority, it would signal in a meaningful and concrete way that DHCD is committed to ensuring that the specific housing needs of persons living with disabilities are met.
Thank you for this opportunity to provide comments on DHCD’s AI. This is an extremely important document to many of United Housing’s member organizations and we would welcome the opportunity to work closely with the Department to create an action plan that will effectively address the housing needs of our consumers.
If you have any questions or would like to discuss ways in which United Housing can continue to work with DHCD on these issues, please contact Matt Noyes at 617-927-0088 x26 or mnoyes@ahc.org.
Sincerely,
The Undersigned Members of United Disability Housing Partnership