Comments prepared by
Director,
718.636.3494 [phone]
718-636-3709 [fax]
COMMENTS
ON LOWER MANHATTAN DEVELOPMENT CORPORATION
DRAFT
ASSISTANCE PLAN FOR INDIVIDUALS
My name is
PICCED has been engaged in the Community Labor Advocates Advocacy Network
with community-based organizations, new immigrant groups, researchers, housing
and work force development specialists, environmental justice advocates and
labor leaders. This coalition has focused on issues of social, economic, and
environmental justice, and is concerned about the short- and long-term impacts
the events of September 11th and the recession will have on
low-income neighborhoods and communities of color. From the discussions we have
convened or participated in, the three underlying principles we feel must
inform the recovery effort have become more clear: [1] inclusion, transparency, and democracy;
[2] economic and social justice; and [3] environmental justice and
sustainability.
In addition, PICCED is helping to convene a series of meetings with the
Office of Regional and Community Affairs of the Federal Reserve Bank of New
York
in an
effort to launch Imagine New York
Initial Criteria for Individuals
Housing Assistance Plan
General Comments:
The
In addition, the program initiatives should be crafted to assist those whose communities were, and are, adversely affected because of the events of September 11th. Those whose housing accommodations are in jeopardy should benefit from the Community Development Block Grants (CDBG) assistance as well.
An overriding concern is that the City, State and Federal
government must take every step to assure residents of lower
Specific Comments
Re: Item 1 and Item 2. The minimum grant should be raised to $9,600 per assisted housing unit, over two years, in the Immediate Impact Zone; and the minimum grant should be raised to $4,800 per assisted unit in the area outside the Immediate Impact Zone.
There are fixed costs associated with overcoming the impact of the attack and the burden of curtailed services. Therefore, the percentage of income scale makes sense only after a reasonable floor has been established. The fixed costs, such as temporary relocation, access to affordable shopping, and clean up are far easier for wealthier families to absorb than for low- and moderate-income families to assume. Also, these costs are in no way associated with either the size or the rental level of the apartments.
We propose that the area be expanded to include the area
below
Re: Item 3
While the two-year lease is appropriate for those signing new leases, they may not be available for the low-, moderate-, and middle-income tenants now in place. This is particularly true, if, as the New York Times reported on March 12th, the housing market begins to intensify.
Therefore, we suggest that any lease renewals not be dependent on the owner 's willingness to enter into a two-year lease. Similarly, tenants must be able to qualify if the owners demand an increase in non- regulated apartments since they are, in essence, dependent on the property owner 's decisions. Therefore, our recommendations are three-fold:
(1) The benefits must be pro-rated for the period that the tenant remains in place, up to two years; and
(2) the two-year lease restriction be eliminated; and
(3) the requirement that rents may not exceed pre-9/11/01 rents, except in regulated apartments, be eliminated.
In relation to the recommendation that tenants must be fully paid up or have money deposited in a legal escrow account, we propose that a hardship category be established for those who may have lost their jobs or have had reduced incomes as a direct, or indirect result of September 11th . A waiver of this requirement should also be allowed in those cases. Furthermore, if tenants are facing evictions because of economic hardships resulting from September 11th, they should be eligible for additional financial and legal assistance.
Re: Item 4.
Regarding the recommendation that owner occupants must show that mortgage payments, maintenance, and tax payments are current or have money deposited in a legal escrow account, I recommend that a hardship category for those who may have lost their jobs or have had reduced incomes as a direct or indirect result of September 11th be established so that they are not adversely affected by this requirement. A waiver of this requirement should also be allowed in those cases. Furthermore, if owners are facing foreclosure and eviction because of economic hardships resulting from September 11th, they should be eligible for additional financial and legal assistance.
Additional Suggestions
Lower Manhattan
CDBG funds are traditionally targeted to meet the needs of
low- and moderate-income families. The funds being allocated in this case, for
obvious reasons, are intended to reach a larger sector of the population, to
which we have no objection. However, when it comes to encouraging new families
to move into the area, the obvious result will be that only upper-income
families will benefit from these proposed subsidies and low- and
moderate-income families will be excluded. The need and the desire by many to
expand the supply of affordable housing in lower
Therefore, we recommend that the City, using CDBG funds, acquire and provide for up to 45 % of all the available units to be set aside for low-, moderate-, and middle-income families to rent and/or to purchase. Of the 45%, one-third should be allocated for families earning up to 80% of the median income of New York City residents; another third should be set aside for those earning up to 100% of the median income; and the final third should be for those earning up to 120% of the median income for all New York City residents. Another alternative is to provide Section 8 subsidies for low- and moderate-income families, enabling them to access vacant units in Battery Park City.
In addition, the city should preserve the existing supply of
affordable housing using these CDBG funds to buy out all of the buildings
facing expiring subsides. This is essential in order to avoid the displacement
of up to 4,779 residents in 22 existing buildings serving moderate- and
middle-income residents in Community Boards 1, 2, and 3 in
Other Areas of the City Impacted by September 11,
2001
Conspicuously missing from the plan are any program
initiatives to assist those whose incomes were severely impacted by the events
of September 11th and who as a result are in jeopardy of either
being evicted from their apartments and/or are facing foreclosure on their
mortgages. This is particularly important since 60% of the more than 100,000
people who lost their jobs were in industries where they earned less than
$23,000 per year and, 80% of those who lost jobs live in boroughs other than
1. Direct housing assistance payments to those lower Manhattan workers unemployed after 9/11 equal to 30% of rent for the unemployment period and/or 24 months; which ever is less, and reimbursement for any legal costs incurred due to eviction or foreclosure actions. An alternative would also be to issue emergency Section 8 vouchers for people in these circumstances.
2.
Two million dollars should be set aside for
community-based development organizations and legal service organizations
located in, or serving low- and moderate-income communities where there are
concentrations of families that were unemployed or underemployed as a result of
September 11th. These funds are to be used for tenant counseling,
anti-eviction proceedings, mortgage counseling and representation in
foreclosure actions.
Comments on Proposals for Worker Training
This
program is clearly designed to
benefit workers left unemployed or underemployed by the events of
September 11th, but in the
proposed plan workers have no control of their own training needs
� control is given to the businesses that may or may not provide them with this
service. The LMDC should rework this program in
its entirety and develop recommendations that builds on and enhances the city 's
already existing workforce development network and system which enables
unemployed and underemployed workers, including those on public assistance, to
participate in an array of job training and educational services.
Specific options
should include:
1.
Work
with community-based economic development groups, work force development
specialists, and community economic development economists to identify where
jobs exist and can be created, as well as the skills needed to perform and
retain these jobs.
2.
Fund
specialized skills training, GED and ESL courses, job readiness workshops,
union apprenticeships, higher education, and other programs that will promote
job growth and retention.
3.
Encourage
the development of career ladders that a) enable existing industry employees to
access better jobs and thus also b) create entry-level jobs for other to fill.
4.
Diversify
the economy, protect manufacturing jobs and undertake a concerted effort to
identify sectoral interventions and other investment policies that will spur
community enterprise development e.g., sustainable building requirements and
investment will lead to demand for photovoltaic and other related products
which in turn can be manufactured in New York.
5.
Create
buy New York Incentives in all program areas similar to HUD local procurement
requirements.
Finally, we are
concerned that LMDC has chosen a seemingly low and arbitrary number of workers
to serve. Funding should be made
available for every worker who was directly or indirectly impacted by the
events of September 11th.
Summary and
Conclusion
The
We are also concerned about maintaining and enhancing the area 's vitality and its attractiveness to artists, working artisans and low and moderate-income populations as part of a viable, healthy mixed use, mixed income community. To that end, we have made a number of specific recommendations geared towards retaining and enhancing the area 's mixed income population.
We also are cognizant of the potential displacement due to either gentrification and/or the expiration of existing subsidies and we urge action to address these issues.
We are concerned about the housing needs of those formerly employed in the area who lost their jobs, and others who either directly or indirectly lost their jobs due to the events of September 11th and are now are facing either eviction and/or foreclosure. We recommend that LMDC, the State, HUD and others move quickly to address these omissions in the plan.
We believe that the job-training component of the plan is
very weak and needs to be restructured and a new plan developed for comment as
quickly as possible. We also urge that LMDC meet immediately with community
economic development advocates and workforce development specialists to craft a
more responsive and workable plan.
We stand ready to meet with the LMDC to clarify and expand upon any of these recommendations and to respond to any questions regarding the aforementioned suggestions.
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