Testimony: Housing Our Neighbors

Thank you to the New York City Council’s Committee on Housing and Buildings for holding an oversight hearing on the newly released Mayor’s housing plan, Housing Our Neighbors: A Blueprint for Housing and Homelessness.

My name is Oksana Mironova and I am a housing policy analyst at the Community Service Society of New York (CSS). We are a leading nonprofit that promotes economic opportunity for New Yorkers. We use research, advocacy, and direct services to champion a more equitable city and state.

We have been closely tracking New York’s housing landscape for decades. According to our analysis of the initial findings of the 2021 Housing Vacancy Survey:

• Asking rents increased by 34 percent above inflation between 2017 and 2021.
   
• Since 2014, income necessary to afford the median asking rent has gone up by 74 percent, up to $110,000. Wages increased by only 16 percent during that time.
• Vacancy rates in low-rent apartments were 0.9 percent; they were 12.6 percent in high-rent apartments.
   
• Rent regulation is effective at preventing rent gouging and displacement: The 2019 Housing Stability and Tenant Protection Act (HSTPA) saved 15,670 apartments from deregulation and kept rent in 37,040 apartments roughly $300 lower than they would have been otherwise.
   
• Housing conditions are worsening, even as rents are rising. One example: rodent infestations were reported in almost a quarter of NYC buildings.
   
• While conditions are generally worse in lower-rent apartments than higher-rent housing, conditions in public housing are particularly dire, with a plurality of public housing residents experiencing three or more maintenance problems.
   
• 26 percent of families with kids are living in overcrowded conditions, with immigrant households facing higher levels of overcrowding than U.S.-born households.

With data showing how dire the situation is for low-income tenants across the city, we offer the following comments on Mayor Adams’ housing plan.

An Integrated Housing Plan

We commend Housing Our Neighbors for bringing together affordable housing, homelessness, and public housing in one plan, and encouraging collaboration between the myriad of agencies that work on housing issues in New York City. We have long called for the integration of homeless services, affordable housing development, and the preservation of New York’s largest source of permanent and deeply affordable housing (NYCHA). This plan is a step in the right direction.

Resources, Not Rhetoric

While the plan rightfully acknowledges a problematic hyperfocus on quantifying development in previous administrations’ housing plans, it does not offer any accountability measures or transparency into how the outlined goals will be achieved. Judging the plan’s success by its ability to move people from homelessness and precarity into affordable housing and stability is, indeed, the right goal – but the administration can put forward metrics to assess their success or failure in that goal without falling into the pitfall of arbitrary unit counts.

The city’s latest budget has already hamstrung the promises made in Housing Our Neighbors. It implemented drastic cuts to a range of social service programs, and failed to substantially increase housing capital spending beyond inflation, breaking a promise made by the Mayor when he was on the campaign trail.

Our housing crisis will not be solved with only administrative changes and roundtables exploring affordability challenges. We need a substantial commitment of political will and public money to address the root causes of housing instability.

Eviction

As the city begins implementing Housing Our Neighbors, New York City’s housing courts are buckling under a backlog of eviction filings. In the Bronx, judges used to hear one case every 30 minutes in their Right to Counsel intake part; now they hear two cases every 15 minutes. This is an impossible position for both tenants and legal services organizations.

Housing Our Neighbors includes a few notable programs that will help curb unjust evictions, including proactive inspections of buildings where harassment may be occurring, increased capacity to bring harassment cases against bad landlords, and an expansion of HPD’s Partners in Preservation program. However, it does not mention one of the most effective tools in the city’s toolbox for lowering eviction rates: Right to Counsel. New York was the first city in the country to implement a Right to Counsel (RTC) law.

Following the implementation of RTC, we worked closely with the Right to Counsel Coalition to advocate for Local Law 53, which requires the City to work with tenant organizers to educate tenants about RTC. It was supposed to go into effect in November 2021, but Local Law 53 was not implemented. The city is now out of compliance and the law needs to be implemented immediately. Right to Counsel is extremely effective at keeping people housed, but it does not work if tenants do not know to take advantage of it. Trusted, neighborhood-based groups are the key to getting information to tenants facing eviction.

Homelessness and rental assistance

We were glad to see a commitment in Housing Our Neighbors to help New Yorkers in shelter move into permanent housing faster, ease income verification procedures for affordable housing applicants, and address source of income discrimination.

The city’s own rental assistance program, CityFHEPS, has the potential to effectively address housing instability and homelessness, but there are a number of administrative and enforcement obstacles preventing the program from functioning at full capacity. As part of administrative reforms to the program, the city must:

• Expand eligibility to more households, such as to families where everyone is undocumented, who often have the longest shelter stays.
   
• Reform bureaucratic processes to make sure that the City and shelter staff quickly process applications and that minor errors no longer result in month-long delays or outright denials.
   
• Eliminate unnecessary rules, such as the utility allowance and rent reasonableness rules.
   
• Combat discrimination by rebuilding the City’s source of income discrimination unit and making sure that it actually enforces the rights of CityFHEPS households.
   
• Improve code enforcement by ensuring that oversight agencies regularly conduct thorough inspections, and that they have the capacity and expertise needed to enforce necessary repairs.

Preservation, development, and social housing

We were glad to see a commitment to social housing development and conversions in Housing Our Neighbors. This includes continued HPD support for nascent community land trusts (CLTs), leveraging CLTs to stabilize private owners in financial distress, and expanding the Zombie homes pilot.

For CLTs and limited-equity cooperatives to be effective, city agencies have to move beyond pilot studies and commit to social housing conversions and development on a bigger scale. The city can achieve this by:

• Abolishing the tax lien sale, and replacing it with an alternative tax collection system that stabilizes rental buildings facing tax foreclosure by turning them into social housing.
   
• Passing the Community Opportunity to Purchase Act (COPA), with a priority for social housing development.
   
• Targeting public land for social housing development.
   
• Expanding city funding for social housing models.
   
• Incorporating measures of permanent affordability and resident control into HPD’s term sheets.

Thank you for the opportunity to testify. If you have any questions about my testimony or CSS’s research, please contact me at omironova@cssny.org.

Issues Covered

Affordable Housing