In the coming months, the D.C. Housing Authority will likely be finalizing new local regulations that govern all aspects the Housing Choice Voucher Program (HCVP). Legal Aid, together with housing advocates at Washington Legal Clinic for the Homeless, Bread for the City, and Legal Counsel for the Elderly, have worked intensively over the last year to ensure that these new regulations will best serve HCVP applicants and participants and members of our client community.
The HCVP, which assists nearly 11,000 low-income individuals and families in the District, helps participants secure affordable housing by providing subsidies that they can use to lower the cost of housing on the private market.
The D.C. Housing Authority administers the program for D.C. residents. The Housing Authority also sets the policies and rules that govern the program locally. For example, the Housing Authority creates the local rules for admission to the program, obtaining a rental unit, housing quality inspections, and transfers from one assisted unit to another.
Although the Housing Authority has promulgated regulations over the years to cover targeted subject areas, the rules have not had a comprehensive overhaul in well more than a decade. That process finally began in February 2011, when the Housing Authority sent Legal Aid and other advocates a draft version of the proposed new HCVP regulations. The Housing Authority requested comments and thoughts on the new policies and rules before publishing them officially for public comment.
While the intent behind the proposed regulations was good, the content had several major problems. In March 2011, Legal Aid and advocates responded to the Housing Authority with a 58-page single-spaced letter. Among the problems identified were disjointed organization, duplicative provisions, failure to define terms, inconsistent use of terms, internally inconsistent policies, policies inconsistent with federal law, and policies that were inequitable or simply unworkable for HCVP applicants and participants.
For the past year, Legal Aid and other housing advocates have met more than a dozen times with Housing Authority staff to discuss the new regulations and our suggestions for revision. Advocates persuaded the Housing Authority to modify many of its proposed policies and procedures so that the program will run more smoothly for HCVP applicants, participants, landlords, and staff. The regulations were re-organized to flow with the natural course of applying for and using a housing voucher. Duplicative provisions were removed. Terms were defined and uniformly applied throughout the regulations. Steps were taken to ensure consistency throughout the regulations. Policies were modified to conform with federal and local laws.
In February 2012, exactly one year from the prior draft, the Housing Authority published for comment the new proposed regulations. While the revised proposed regulations reflect the fact that advocates significantly influenced the HCVP policies and procedures on many subjects, opinions continue to differ on some subjects, and the Housing Authority did not adopt all of the advocates’ suggestions. Last month, Legal Aid and our partners again submitted comments to the Housing Authority on the revised proposed regulations. In any event, HCVP applicants and participants will certainly be better served by the revised policies and procedures. And Legal Aid and advocates continue to push for these policy changes in other contexts.
In the near future, we expect that the Housing Authority will finalize the regulations, and we hope it will take into account our remaining comments. Ultimately, we look forward to having a comprehensive, well-vetted set of regulations to govern the program on which so many of our clients rely for safe, decent and affordable housing.