CONN-NAHRO
2007 Legislative Agenda
Adopted: 12/14/2006
Definition of Issue Priority Levels:
● Priority Level A — the highest priority for CONN-NAHRO,
representing a significant commitment of membership involvement
and staff time. Encompasses legislative and / or
regulatory practices that the organization deems important
to advocate changing in the forthcoming year.
● Priority Level B — a secondary priority, that needs to be addressed
in subsequent legislative sessions or needs to be undertaken
as part of a broader coalition involving other organizations.
● Priority Level C — an endorsement in the name of CONNNAHRO
with minimal resource commitment. Anticipates
internal discussion and / or study prior to public advocacy.
Talking Points - Level A:
* Establish an Emergency Repair fund for state-aided public housing.
There is a $4.0m
bond authorization for this purpose which has not yet been made available. This should be doubled
to an $8.0m revolving fund and replenished in future years whenever the fund is projected to sink
below $2.0m on hand. DECD’s and CHFA’s current system to get “emergency” repair funds in the
form of a grant can take six months as the grant requires processing under the Small Cities Program
(CDBG) for which a housing authority is not an eligible applicant. The local municipality must apply
on behalf of the housing Authority and is not required to do so. The other “immediate” alternative
are loans from CHFA, but these come with debt service and even these cannot be put in place
quickly. Both the current options (grants or loans) require a determination that reserve operating
levels available for the development are not sufficient. This determination has the potential on a
number of levels to be subjective and controversial thus delaying the availability of funds. Until a
more comprehensive determination of the future of the state-aided portfolio can be made, this type
of fund under which grants (which may require certain commitments or trigger repayment) or loans
would be available on an expedited basis (days or weeks not months), can be an important interim
portfolio preservation tool.
* Authorize at least $2m for accessible unit compliance or new conversion in the stateaided portfolio.
CT has obligations for its state-aided housing programs under ADA Title II. To date, neither DECD nor CHFA have looked at the issue and its implications for the state-aided programs.
ADA Title II sets out as the compliance standard meeting the intent of Section 504. HUD has developed a set of regulation for Section 504 compliance that can be found at 24 CFR 8.
* Authorize and fund some form of study/commission to look at the short term and medium term capital and operating needs of the portfolio.
Given the age of the portfolio and the increasing oversight burden being implemented by CHFA, increased utility costs, increased
benefit and insurance costs, diminishing household income levels as low income households with
choices “vote with their feet” about their housing preferences, and operating and capital reserves
levels that for historic reasons have never kept up with current underwriting standards, the entire portfolio is at risk. Without a preservation strategy and program, the portfolio may not have a long term to consider.
* Increase the "value" of a supportive housing unit to 2.0 in terms of the municipal count under CGS 8-30g.
The need to increase the number of supportive housing units is being
driven by a number of factors. These units need to available state-wide and not just in the urban
areas that are already so crowded with the full array of affordable housing. While access to services
can be an issue, many with supportive needs do not need weekly access to services, they need a stable
living environment that can be provided by supportive housing. This type of “weighting” indicates the value of these units and provides an incentive for communities.
Talking Points - Level B:
* Consolidate state low and moderate income housing program administration underone umbrella.
At the current time the divided roles with the statutory authority residing with DECD and the outstanding program debt residing with CHFA has created a bifurcated administrative
structure that is not balanced nor appropriate to needs and resources provided to the portfolio.
The issues of level and type of oversight can only be addressed once the lines of authority for the
portfolio are clear and based on statutory and regulatory clarity.
This issue is a subset of a larger set of issues concerning State level housing policy. While there are
many variations in States across the nation as to how administration for housing programs is distributed,
finding more than two major state level entities is rare. With the state allocation of housing
Choice Vouchers administered by DSS, Connecticut has three major agencies involved in housing
(CHFA and DECD being the other two) as well as other peripheral agencies such as DMHAS and DMR, who administer a network of community residences and permanent housing solutions for their clientele. The development of this initiative requires a clear understanding of the relationship
between the various roles: regional planning (including coordination with economic development
and transportation initiatives), financing (grants and loans ideally under a “one-stop” model), operational oversight (compliance) and asset management (physical plant renewal and housing market issues).
* Fund and implement an accessible unit registry/clearinghouse that will help matchlow income households that require units with unique features to existing product.
This type of registry helps to reduce access impediments and to maximize the proper use of accessible units by households who require the unique features of an accessible unit.
Talking Points - Level C:
*Fund and implement a state-wide waiting list for the CT state-aided program.
This
would be an online system that would allow an applicant to complete a “one-stop” application and
to indicate either a list of preferred communities or first available unit. After implementation, it
would remove barriers to program access, reduce administrative burden, increase compliance and if
expended to then collect information on households admitted to the program, would provide the
oversight agency with demographic and other profile data with substantially reduced reporting burden
by housing authorities. This technology is readily available and well proven. The list could also
be expanded for use by the State’s Housing Choice Voucher Program and on a voluntary basis to
other affordable housing program.
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