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Other Office Locations:

Ron Olson Justice Center, 1550 W. 8th Street, Los Angeles, CA 90017 East Los Angeles, 5301 Whittier Blvd., 4th Floor, Los Angeles, CA 90022 Long Beach, 601 Pacific Ave., Long Beach, CA 90802
South Los Angeles, 7000 S. Broadway, Los Angeles, CA 90003 Legal Aid Foundation of Los Angeles
1640 5th St., Suite 124
Santa Monica, CA 90401

SUBMITTED VIA EMAIL
City of Santa Monica
Housing Office
1685 Main Street, Mail Stop #19
Santa Monica, CA 90401
[email protected]
March 20, 2023
Re: Comments to FY2023-2024 Administrative Plan
To Whom it May Concern:

Legal Aid Foundation of Los Angeles (“LAFLA”) appreciates this opportunity to comment the Santa Monica Housing Authority’s (“SMHA”) draft FY2023-2024 Administrative Plan (“Administrative Plan”). LAFLA is the largest provider of free legal services to low-income residents of Santa Monica. Our comments are based on our experiences representing countless participants in the SMHA’s Section 8 Housing Choice Voucher program. We welcome any questions you may have about the issues outlined in this letter.

I. Annual Rent Increases Initiated by the SMHA
It is currently SMHA policy for the SMHA to approve an increase in the contract rent for an HCV-assisted unit as a part of a tenant’s annual recertification. See Admin. Plan § 8-III.B. This policy is unchanged in the draft Administrative Plan. Specifically, at each Section 8 participant’s annual recertification, the SMHA initiates and approves an increase of the contract rent equal to the maximum “general adjustment” allowed under the Santa Monica Rent Control Charter Amendment (“SMRCCA”). Though not explicitly stated in the Administrative Plan, we understand from experience that the SMHA automatically initiates and approves these increases even when landlords do not request or provide any notice of rent increase to their tenants or the SMHA. This policy is inconsistent with Section 8 regulations, portions of the SMHA Administrative Plan, state law, and Santa Monica Rent Control Board regulations.

Under Section 8 regulations and the Administrative Plan, a landlord and tenant must agree to new rent amount before the SMHA can determine whether the new rent amount is “reasonable,” and if so, approve the rent. See 24 CFR § 982.506 (“The owner and the family negotiate the rent to owner.”); 24 § 982.507 (rent reasonableness regulation); see also Admin. Plan § 8-III.B. The SMHA must help the owner and tenant negotiate a new rent only if the tenant requests this assistance. 24 CFR § 982.506. The Administrative Plan requires such annual “rent increase 2 requests shall be timed with a tenant’s annual re-examination.” Admin. Plan § 8-III.B (emphasis added). However, the current draft of the Administrative Plan does not explain how a landlord should go about making such a request.

In practice, many landlords and tenants in California do not formally re-negotiate the rent when an initial lease term expires because this is not required under state law. Instead, most landlords simply serve a notice of change in terms of tenancy to the tenant with a notice of the increased rent amount, and if the tenant chooses to stay and pay the new rent, this is construed as an agreement to the increased rent. See Civ. Code § 827(b), (c). Thus, in order to increase the rent for any tenant in California, a landlord must, at a minimum, serve a notice of change in terms of tenancy to the tenant at least 30-days in advance of the proposed rent increase. Id.

For tenancies subject to the SMRCCA, Santa Monica Rent Control Board Regulation 3035(c) reiterates that a landlord is prohibited from collecting a “general adjustment” (an annual rent increase) “unless the landlord has provided the affected tenant with written notice as required by California Civil Code Section 827.” The notice to rent controlled tenants must further include a certification signed by the landlord that the unit “is not subject to any uncorrected citation of notices of violation of any state or local housing, health, or safety laws issued by any government official or agency.” Id. Critically, “[i]f the landlord fails to comply with this subsection, the tenant may refuse to pay the improperly-noticed rent increase, and may raise the landlord’s noncompliance as an affirmative defense in any resulting unlawful detainer action.” Id.

Current SMHA practice effectively nullifies these requirements of federal, state, and local law.

Specifically, the SMHA automatically increases the contract rent to the owner at the tenant’s annual recertification, without the landlord making a “request” for such rent increase as required by Administrative Plan § 8-III.B, and without the landlord and tenant ever having “negotiated” this rent increase as required by 24 CFR § 982.506. Under state law, the “negotiation” between landlord and tenant must, at a minimum, involve the landlord serving a 30-day notice of change in terms of tenancy stating the new rent amount. Civ. Code § 827(b). And under Santa Monica Rent Control Board Regulation 3035(c), the notice of change in terms in tenancy must additionally include a certification, signed by the landlord, that the unit is not subject to any violations of housing, health, or safety laws. Under SMHA practice, the landlord gets the rent increase even when they never served any notice at all.

Indeed, in dozens of cases, our clients have received HAP Contract Amendment Notices from the SMHA after their annual recertification which state that the contract rent for the unit is being increased, but the tenant was never served with any notice of rent increase from their landlord.

The HAP Contract Amendment Notices themselves do not satisfy the requirements of Civil Code § 827 because that law requires that the landlord give the written notice of rent increase. Civ.

Code § 827(b). The HAP Contract Amendment Notices also do not comply with Rent Control Regulation 3035(c) because they do not include the required certification from the landlord.

The law is clear that tenants are not obligated to pay any rent increase for which they have not received a proper, compliant notice from the landlord. However, tenants are placed in a very difficult position when they receive a HAP Contract Amendment Notice from the SMHA which purports to notify them of a rent increase but is not a valid notice under state or local law. If they 3 refuse to pay the rent increase the landlord is expecting, they subject themselves to an unlawful detainer case and, very possibly, loss of housing and their voucher. Most, if not all, will feel forced to pay the unlawful rent increase to avoid this risk, even if this means foregoing paying for other basic necessities.

In some cases, the increase in the contract rent will not directly or immediately impact the tenant because the contract rent will still be below the payment standard for the tenant’s voucher.

However, more and more often, as rents rise and the payment standards remain stagnant, we are seeing tenants whose contract rents do exceed their payment standards. These tenants must pay 30% of their income toward the rent, plus every dollar of rent that exceeds the payment standard.

In just a few years, this can result in a tenant paying well over 40% or 50% of their income toward rent and becoming severely rent burdened, a problem the voucher program was created, in part, to prevent. In many of these cases, the contract rents might have stayed below the payment standard, or at least not exceeded the payment standard by such a large degree, if the SMHA had not annually increased the contract rent on its own initiative.

In summary, because it has been SMHA practice to automatically increase the contract rent for a while, shifting from this practice may be confusing for both landlords and tenants. We believe these impacts can be mitigated with a few different strategies.

First, we also suggest that the SMHA provide ample written notice to both landlords and tenants that the SMHA will not increase contract rents at tenants’ annual certification unless a landlord affirmatively requests a rent increase.

Second, we recommend that the SMHA develop a form for landlords to serve to tenants which informs the tenants: (a) of the requested new contract rent; (b) that this new amount is a request which the SMHA still has to approve or deny; (c) that the tenant will not be responsible for the entire amount of the requested new rent; and (d) that the SMHA will notify the tenant of her share of rent at least 30 days prior to any increase taking effect. We are concerned that if a landlord simply serves a notice to a tenant of the requested new contract rent with no further explanation, the tenant will be alarmed and think she is responsible for the entire amount. The SMHA may also want to include the certification language required by Rent Control Regulation 3035(c) on this form.

Third, we recommend that the SMHA require that landlords provide tenants and the SMHA the above written notice at least 60 days before the tenant’s annual recertification or lease renewal would take place. This is so the SMHA will have enough time to perform the rent reasonableness analysis on the new proposed rent, and to notify the landlord and tenant of the tenant’s share of the new rent well in advance of the rent increase.

Fourth, we recommend that the SMHA describe these changes to policy and practice clearly in the Administrative Plan, Section 8-III.B.

We understand that re-aligning this SMHA practice with the Section 8 regulations, Administrative Plan, and state and local law will take some work. We nevertheless believe this 4 change is necessary, and remain available to assist SMHA participants in understanding and navigating these changes.

Thank you for your time and consideration of these comments. Please feel free to contact me at [email protected] if you have any questions.

Sincerely,
Romy C. Ganschow
Attorney
RAB Recommendations for SMHA 2023-24 Administrative and Annual Plans Submitted electronically on March 20, 2023 by Theresa Marasco on behalf of Courtney Lauretano, RAB representative unanimously elected by RAB members at a March 19, 2023 meeting, on behalf of the following SMHA clients:

Courtney Lauretano
Hajar Muqtasid St Claire
Stephanie S.

Danielle Charney
Sheila Finley
Olga Zurawska
Theresa Marasco
Michelle Gray
Anonymous

1. SMHA Board refuse to approve the Administrative and Annual Plans unless and until all RAB members can meet, review discretionary documents sections, discuss, and submit collective feedback to SMHA.

2. SMHA immediately schedule the six-month-overdue meeting of the RAB/CAB that was ordered to be scheduled “with haste” by a unanimous City Council/SMHA Board vote on September 13, 2022, with parameters and support as outlined in the Housing Commission CAB recommendations presented on the same date.

3. That the SMHA adopt the recommendations of the Housing Commission regarding the RAB/CAB that were presented and submitted to the Santa Monica Housing Authority Board on September 13, 2022, by Housing Commission Chair Michelle Gray.

4. The SMHA supports the annual election of two RAB/CAB representatives to the SMHA Board by the members of the RAB/CAB.

5. SMHA must immediately convert the payment standard basis to Small Area FMR and raise payment standards according to the recent Housing Commission recommendations to City Council/SMHA Board.

6. The SMHA revive the Family Self Sufficiency Program (FSS), and seek out other Self Sufficiency Programs available through HUD, such as the “Move to Work” (MTW) demonstration program, and other federal and state programs, that lead to pathways to self-sufficiency and greater economic equality. That the SMHA actively seeks and applies for the Notice of Funding Applications to ensure that the self-sufficiency programs are provided maximum financial support. That information about the self-sufficiency programs be widely disseminated on a regular basis to program participants, encouraging program participants to participate in the various programs such as the FSS, MTW, and Earned Income Disallowance (EID) program, providing clear information about eligibility and how to access the programs. The information about the self-sufficiency programs should be posted on the SMHA website, on the walls at the SMHA office, flyers made for clients to take Note that SMHA ended the FSS program in 2019 stating that there were not enough program participants interested in the program because most of the Housing Authority program participants were either “disabled or elderly”, thereby discriminating against elderly and disabled program participants. Furthermore, there have been more HCV clients added to the program since 2019, so there are a greater number of program participants now than there were in 2019, and ALL eligible program participants could benefit from the FSS program. Finally, the SMHA never advertised the FSS program so the majority of the clients/program participants never even knew the program existed or how to utilize the program to accrue escrow funds.

7. Santa Monica Housing Authority (SMHA) create and actively seek funding to support the Housing Choice Voucher (HCV) homeownership program which is supported by HUD to create a pathway for HCV clients to purchase a home and utilize vouchers to make monthly mortgage payments. Note that any homeownership program created for SMHA HCV participants can be used to purchase homes outside of the City of Santa Monica.

8. SMHA administratively facilitate yearly or biannual surveys created and conducted by the RAB/CAB by a) both emailing and mailing surveys and instructions to all SMHA clients in English and Spanish with instructions to request translations into other languages written in all known client languages, and b) for the results of the surveys to be compiled and provided to the RAB/CAB for further use.

9. The SMHA offer or partner with other agencies to offer financial literacy programs to all SMHA clients.

10. The SMHA allow HCV clients to cohabitate using their vouchers such as renting a room in a house or having roommates who are or are not HCV clients to share living space. Note that the City of Los Angeles and other jurisdictions permit this.

11. The SMHA create and fill the invaluable position of Landlord Liasion/Housing Navigator, successfully utilized in jurisdictions nationwide, to help advocate for clients with prospective and current landlords and help prospective and current landlords navigate SMHA bureaucracy in a smooth and timely fashion. This position is necessary to facilitate voucher utilization and prevent source of income discrimination that while illegal, is rampant in Santa Monica.

12. Create or advocate for a public relations campaign to destigmatize SMHA clients and housing voucher holders as a whole and raise awareness of the benefits of HUD programs to tenants, landlords, and larger communities.

13. Ensure the Annual and Administrative Plans include language that states program participants are to be treated with respect and dignity by staff and landlords at all times and details recourse for clients when that policy is violated.

14. Offer or partner with other agencies to offer supportive services to all SMHA program participants who need them.

15. The SMHA seek the participation and input of the RAB/CAB when hiring a new Landlord Liasion/Housing Navigator, dedicated ADA/Section 504 Coordinator/Disability Liaison, and Veteran Liaison.

16. SMHA work with the city of Santa Monica to ensure Housing Commission meetings are live streamed and made subsequently available on YouTube, with hybrid participation, as SMHA explicitly relies on Housing Commission meetings to offer opportunities for clients to provide SMHA related feedback.

17. SMHA needs to designate or hire a Veteran Liaison to assist clients who have served in the military.

18. SMHA must create and fill a dedicated position of ADA/Section 504 Coordinator as strongly recommended by the 2020 Assessment of Fair Housing report with the City of Santa Monica Housing and Economic Development Department and the Lawyers’ Committee for Civil Rights Under Law and published on April 1, 2020 and approved by City Council on April 28, 2020
(https://www.santamonica.gov/housing-policy-and-reports).

19. SMHA must overhaul and create transparent, measurable, and regularly tested parameters for Below Market Housing list notices and SMHA digital and physical correspondence with clients to ensure all clients receive equal BMH opportunities and all SMHA communications. Note there are current complaints of unequal BMH listing notices to seniors and regular and ongoing omission of numerous clients from important SMHA correspondence.

20. SMHA ensure or partner with other agencies that are in no way financially affiliated with the City of Santa Monica to ensure program participants have automatic access to legal representation if they are facing eviction actions or Ellis Act eviction. Program participants have unfettered access to legal representation and resources for housing concerns with access to mediation to resolve landlord/tenant disputes. The new tenant protection laws automatically provide legal representation for tenants facing eviction but are only available to rent-controlled tenants. The City needs to create legal access for SMHA program participants outside LAFLA, the Santa Monica branch of which is funded by the City of Santa Monica, whose infrastructure SMHA is inextricable from.

21. SMHA arrange for and publicize the name and contact information of a representative from Public and Indian Housing to provide technical support to the RAB/CAB.

22. SMHA add to the Administrative Plan and website a flow chart with names, titles, contact information, and salary funding source (federal or city) of every single SMHA employee and manager, including city employees charged with SMHA interaction and/or oversight. This must include each employee’s direct report and names and contact information for recourse when clients encounter problems with SMHA at any level.

23. SMHA must furnish every client with the complete data and calculations used to determine their share of rent at every re/evaluation. This must include the HUD form used to calculate these rent shares.

24. SMHA must educate clients about the existence, role, and details of medical deductions in determining income and subsequently share of rent, including specific information about what counts as medical deductions and information on how and when to submit deductions. SMHA must also furnish all clients who submit medical deductions with itemized results of those claims including approval or denial and the reason for any denial.

25. SMHA must address ongoing habitability issues that program participants face, including mold, cockroaches, and bed bugs. SMHA must ensure SMHA inspectors have sufficient resources to properly address habitability issues with landlords who violate such requirements, including issuing warning letters to landlords and facilitating abatements of rent when landlords fail to cure violations within a specified time frame.

SMHA must ensure clients are knowledgeable about habitability information from sources including California Health and Safety Code and Code Enforcement, by widely disseminating this information in the SMHA office, orientation packets, yearly recertification packets, on the SMHA website, and posted on the information boards at City Hall and/or in the SMHA office with copies available for program participants to take.

26. SMHA must overhaul voucher waitlists to create transparency for applicants, including access to information about their position in the selection process and notification when they are approved for any voucher program.

27. SMHA must stop penalizing clients for theoretical back rent when Housing Specialists are behind in processing recertifications or income changes, resulting in delays of landlord notifications to tenants of rent changes, which must precede actual rent changes by at least 30 days. Note that under California law, such notices must come from landlords; SMHA notices of rent changes do not constitute legal notification by landlords.

Theresa Marasco, SMHA RAB Member
[email protected]
March 20, 2023
Santa Monica Housing Authority
Patrick Komesu, Sr. Administrative Analyst-Housing Authority City of Santa Monica
Housing Office
1685 Main St., Mail Stop #19
Santa Monica, CA 90401
Sent via email to: [email protected]; [email protected] Dear Patrick Komesu and Santa Monica Housing Authority Staff:

The following are my public comments and recommendations for discretionary changes to be made to the 2023-24 SMHA Annual and Administrative Plans:

1. That the Santa Monica Housing Authority Board does not approve the Annual and Administrative Plans until the first RAB/CAB meeting is held as directed by the Santa Monica Housing Authority Board on September 13, 2022.

2. SMHA immediately schedule the six-month-overdue meeting of the RAB/CAB that was ordered to be scheduled “with haste” by a unanimous City Council/SMHA Board vote on September 13, 2022, with parameters and support as outlined in the Housing Commission CAB recommendations presented on the same date.

3. That the SMHA adopt the recommendations of the Housing Commission regarding the RAB/CAB that were presented and submitted to the Santa Monica Housing Authority Board on September 13, 2022, by Housing Commission Chair Michelle Gray.

4. The SMHA supports the annual election of two RAB/CAB representatives to the SMHA Board by the members of the RAB/CAB.

5. SMHA must immediately convert the payment standard basis to Small Area FMR and raise payment standards according to the recent Housing Commission recommendations to City Council/SMHA Board.

6. The Santa Monica Housing Authority (SMHA) create a Homeownership Program for all eligible voucher programs and seek all funding sources to support the program.

7. Revitalize and seek funding for the family Self-Sufficiency Program, as well as other self-sufficiency programs, and amend the annual plan to reflect this. Any and all information for self-sufficiency or other programs should be made available in the office, via flyers, and emailed/mailed to participants, and widely disseminated through orientation and recertification packets as well as posted on the SMHA website.

8. That the SMHA Apply for the Moving to Work (MTW) demonstration, which would grant the housing authority more flexibility in the execution of its programs and funding.

9. Hire an ADA coordinator for the SMHA per the recommendations stated in the Fair Assessment of Fair Housing completed in April 2020.

10. Add the informal review officer to the administrative plan and include their contact information. Add the informal review process/rules to the website and the ability to obtain a form and or submit a form to request an informal review. Also, add the information for a state hearing process.

11. Adopt a tenant/owner portal that accommodates the needs and disabilities of voucher participants. The portal should be user-friendly and allow tenants/owners to submit all documents electronically and time stamp them with a confirmation email after submission. The portal should also serve as a way to communicate with Housing Specialists and be capable of preserving client emails for up to 10 years.

12. Rent increases should only be initiated by the landlord and policy should reflect it.

13. Due to a total lack of transparency in AFF/Subsidized housing; etc. (preferential treatment who gets housing.) The SMHA needs to make available a comprehensive list of all shelters, project based housing, deed-restricted/tax credit, and/or affordable housing units in the city. The City and County of San Diego publish such a list for public access. Santa Monica can easily publish a list like San Diego (see link to San Diego Housing List: https://www.sdhc.org/housing-opportunities/affordable-rentals/).   


     



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General Comment:

Hi Patrick,
Donna Brown is not a rep.

She has never once participated in any SMHAB meeting. It is I fair towards HCV voucher holders to pretend that Donna is a rep.

Neither Donna nor Elizabeth respond to emails sent to their city addresses.

Therefore they are not really reps.

Elizabeth has stated on the dais that she has no idea what she is supposed to do as a rep.

Neither Elizabeth nor Donna have been appointed with any input from the program participants.

It’s all a charade.

Additionally, CoC voucher holders do not have ANY representation on the legislative body which is SMHAB, which is in violation of the federal law. The City never has made an effort to appoint a CoC representative to the SMHAB but instead, inexplicably, asked HUD for a waiver of the requirement.

As a CoC voucher holder I have been deprived of the representation I’m supposed to have on SMHAB.

Please rectify this ASAP!
Thank you.

Olga
From: OZ
To: David White; SmHousing Mailbox; Patrick Komesu
Cc: Lana Negrete; Phil Brock; Christine Parra; Oscar de la Torre; Paolo Velasco Subject: OBJECT to consideration and approval of Admin Plan by SMHA Board in its current composition (public input to SMHA Admin Plan)
Date: Monday, March 20, 2023 11:55:33 PM

EXTERNAL
-->There is currently no Resident Advisory Board in Santa Monica, therefore there has not been a RAB process as required by federal law for the Admin Plan to be approved by SMHA Board. Additionally, there is no unhoused or formerly unhoused tenant representative on SMHAB as is required by federal law. The current composition of SMHAB is unlawful, therefore the Board has no authority to discuss or approve the Admin Plan.<--
To date SMHA Board has not established the mandatory Resident Advisory Board or specified the form of the RAB, nor has it directed the Executive Director of SMHA to establish a RAB on behalf of SMHAB or to determine the form of the Santa Monica RAB as he wishes.

There has been no public process pertaining to the establishment of a RAB in any particular form, not has there been any public process pertaining to the establishment of any seats for SMHA program participants on SMHAB, or the process of electing or appointing to such seats.

The City Attorney for the City of Santa Monica, who reportedly also represents and advises the SMHAB, has not been involved in the establishment of a RAB or in the establishment of a process that would lead to the appointments of RAB reps to the SMHAB for any specific length or number of terms.

There is no mention of any RAB, or RAB representatives participating on SMAHAB in any ordinance, resolution, motion with direction for staff to establish a RAB in any particular form, and there is no mention in the SMHAB bylaws of the RAB or RAB reps to serve on SMHAB.

If there exists any SMHAB resolution or ordinance establishing a Santa Monica RAB, or if there exists any mention of a RAB or RAB reps in the SMHAB bylaws, please provide them to me prior to the discussion of the Admin Plan in April 2023 by SMHAB.

Claims by City of Santa Monica Housing Program Manager James Kemper that a RAB exists in Santa Monica because he established a RAB through his unilateral action (while having no direction from SMHAB, or authority to do so, and while bypassing the public process), are meritless, and very concerning.

As concerning are James Kemper's statements that he as a City of Santa Monica staffer took the liberty to decide how the RAB reps would be applying for the seats on SMHAB, how they would be appointed and by whom, for what length of terms, and what the term limits there were for them, if any. It is with good reason.

There is no other seat within the City, whether appointed or elected, that is established by a City staffer who also unilaterally decides on the application and appointment or election process for that seat, and who unilaterally decides on the length of the term of service or the term limits for that seat, if any.

The fact that both the SMHAB and the public (including the voucher holders), were excluded from Mr. Kemper's unilateral decisions are extremely concerning in that they appear to arise from patriarchal, undemocratic attitudes towards voucher holders as contrasted with other Santa Monica residents. There is no place for such attitudes in a progressive city like Santa Monica.

James Kemper has been instrumental in preventing the voucher holders from being able to meet and deliberate regarding their input to the Administrative Plan. James Kemper claims that the fact that (according to him) each voucher holder received a notice of the opportunity to individually submit comments to SMHA regarding the Administrative Plan is equivalent to the voucher holders being able to meet and collectively deliberate and come up with input. This is an idea as absurd as one where Council Members do not need to meet but rather they can individually, without any deliberation or even contact with one another, submit their individual thoughts to the City Hall where staffers can post those individual opinions for the public to read in lieu of the the Council holding public meetings and deliberating together… Why does the Santa Monica City Council meet instead of its members individually submitting their individual thoughts on agenda items to the City Hall? Why does the SMHA Board meet? Why does the School Board meet? Why do nonprofit boards meet? Why does any city board, commission, task force or committee meet? Why does the State Assembly meet? Why does the US Congress meet? Why are there HOA board meetings? Why are there neighborhood group board meetings?...

If there is no RAB in Santa Monica, and the RAB is prevented from holding meetings, then it is not possible to have the Admin Plan go through the federally mandated RAB process.

If there is no RAB then there also cannot be RAB representatives on the SMHAB who could discuss and vote on the proposed amendments to the Admin Plan with the rest of the SMHA governing body.

Per the federal regulations, the governing body of the PHA (here it is the SMHA Board) "must" include at least one RAB representative. Therefore the SMHAB in its current composition is not a legitimate governing body of SMHA for the purpose of discussing and approving the Administrative Plan.

It is quite shocking that the city of Santa Monica has managed to evade the federal regulations pertaining to the RAB and the requirements for RAB reps on the governing body for DECADES, and is continuing to try to disenfranchise voucher holders while posturing as a progressive, diverse and inclusive city.

Additionally, SMHAB is, and has been for decades in violation of the federal requirement to include at least one representative of the Continuum of Care program (a currently or formerly formerly unhoused participant in the CoC program). 24 CFR 578.75(g)(1).
(g) Participation of homeless individuals.
(1) Each recipient and subrecipient must provide for the participation of not less than one homeless individual or formerly homeless individual on the board of directors or other equivalent policymaking entity of the recipient or subrecipient, to the extent that such entity considers and makes policies and decisions regarding any project, supportive services, or assistance provided under this part. This requirement is waived if a recipient or subrecipient is unable to meet such requirement and obtains HUD approval for a plan to otherwise consult with homeless or formerly homeless persons when considering and making policies and decisions.

James Kemper failed to make any attempt to survey CoC program participants and ask if they were willing to serve on SMHA Board. Instead, without engaging in any public process or receiving direction from SMHAB, James Kemper unilaterally made the decision to ask HUD behind everyone's back for a waiver of the requirement to have an unhoused or formerly unhoused individual participate on the policymaking body of SMHA, i.e. SMHA Board. This took place amid CoC program participants’ enquiries with James Kemper about the opportunity to serve on SMHAB or have a representative on SMHAB as is required by the federal law.

Inexplicably, James Kemper obtained a waiver from HUD even though the federal regulation states that it can only be applied for when a PHA is "unable" to fulfill this requirement. Here SMHA is perfectly able to fulfill this requirement, but it is unwilling to fulfill it. What is preventing SMHA from being able to fulfill the requirement? SMHA has never asked currently or formerly unhoused voucher holders if any of them were interested in serving on SMHAB. Instead, SMHA is fighting hard to prevent unhoused or formerly unhoused program participants from having a voice on the governing body of SMHA. Meanwhile, the SMHA Board is so undereducated that they are not even aware that there is a requirement that a CoC representative sits with them on the dais...

Despite eventually acknowledging that the RAB must have at least one rep on SMHAB, James Kemper still claims that in the case of CoC representatives, it is "better" for them not to participate on the policymaking body of SMHA (as is required by the federal regulation) but sit on the Housing Commission (merely an advisory body) instead...

Again, to be very clear: the Housing Commission is an advisory body, not the board of directors or policymaking body of SMHA. Serving on the Housing Commission is not comparable to serving on SMHA Board (governing body) just as being on an advisory city commission or board is not comparable to serving on the City Council (another governing body).

It appears that James Kemper is adamant about not allowing currently or formerly unhoused tenant representatives to have a vote on the policymaking body, but only on an advisory body instead... Such an attitude by James Kemper appears to be discriminatory specifically towards unhoused or formerly unhoused program participants and aimed at disenfranchising them. James Kemper does not have a problem seeing other program participants serve on the SMHAB, even though they also already have representation on the Housing Commission. James Kemper's apparent mission to disenfranchise unhoused or formerly unhoused program participants is unacceptable in a city that claims it values equity, diversity and inclusion, and particularly in a city that recently declared a state of emergency in regard to homelessness.

Does SMHAB condone such attitude and actions by James Kemper? Did SMHAB ever direct James Kemper to apply for a waiver that prevents unhoused or formerly unhoused program participants from having a voice on the policymaking body of SMHA???
Why is the progressive City of Santa Monica not willing to follow the federal law and have an unhoused or formerly unhoused SMHA program participant sit on the governing body of SMHA Board???
The progressive City of Santa Monica claims to care about homelessness but goes to great lengths to take away the lawful right of unhoused or formerly unhoused tenants to have a voice on the SMHA Board, while it admits it wouldn't mind having other tenants represented on SMHAB???
This warrants an investigation by the City's Equity and Inclusion Manager, Paolo Velasco, and likely an HR complaint against Mr. Kemper and his loose approach to the law, and usurping the powers an authority that he does not posses as a City of Santa Monica staffer.

The SMHAB may not approve the Admin plan before:
1) it properly establishes a RAB or a Client Advisory Board (CAB) through a public process and a resolution or ordinance and an amendment to the SMHAB bylaws and, 2) it properly codifies through a public process the manner of selection, appointment and terms of service for the tenant representatives (HCV and CoC) that must participate on the SMHAB and,
3) a RAB or CAB has been able to meet to discuss and submit their input to the Administrative Plan and,
4) tenant representatives have been appointed or elected to SMHAB in accordance with the federal law and through a transparent public process.

Regards,
Olga Zurawska
-------------------
Pertinent regulations that I am aware of at this time:
24 CFR § 903.13 What is a Resident Advisory Board and what is its role in development of the Annual Plan?
(a) A Resident Advisory Board refers to a board or boards, as provided in paragraph (b) of this section, whose membership consists of individuals who adequately reflect and represent the residents assisted by the PHA.
(1) The role of the Resident Advisory Board (or Resident Advisory Boards) is to assist and make recommendations regarding the development of the PHA plan, and any significant amendment or modification to the PHA plan.
(2) The PHA shall allocate reasonable resources to assure the effective functioning of Resident Advisory Boards. Reasonable resources for the Resident Advisory Boards must provide reasonable means for them to become informed on programs covered by the PHA Plan, to communicate in writing and by telephone with assisted families and hold meetings with those families, and to access information regarding covered programs on the internet, taking into account the size and resources of the PHA. (b) Each PHA must establish one or more Resident Advisory Boards, as provided in paragraph (b) of this section.
(1) If a jurisdiction-wide resident council exists that complies with the tenant participation regulations in part 964 of this title, the PHA shall appoint the jurisdiction-wide resident council or the council's representatives as the Resident Advisory Board. If the PHA makes such appointment, the members of the jurisdiction-wide resident council or the council's representatives shall be added or another Resident Advisory Board formed to provide for reasonable representation of families receiving tenant-based assistance where such representation is required under paragraph (b)(2) of this section. (2) If a jurisdiction-wide resident council does not exist but resident councils exist that comply with the tenant participation regulations, the PHA shall appoint such resident councils or their representatives to serve on one or more Resident Advisory Boards. If the PHA makes such appointment, the PHA may require that the resident councils choose a limited number of representatives.
(3) Where the PHA has a tenant-based assistance program of significant size (where tenant-based assistance is 20% or more of assisted households), the PHA shall assure that the Resident Advisory Board (or Boards) has reasonable representation of families receiving tenant-based assistance and that a reasonable process is undertaken to choose this representation.
(4) Where or to the extent that resident councils that comply with the tenant participation regulations do not exist, the PHA shall appoint Resident Advisory Boards or Board members as needed to adequately reflect and represent the interests of residents of such developments; provided that the PHA shall provide reasonable notice to such residents and urge that they form resident councils with the tenant participation regulations. (c) The PHA must consider the recommendations of the Resident Advisory Board or Boards in preparing the final Annual Plan, and any significant amendment or modification to the Annual Plan, as provided in § 903.21 of this title. (1) In submitting the final plan to HUD for approval, or any significant amendment or modification to the plan to HUD for approval, the PHA must include a copy of the recommendations made by the Resident Advisory Board or Boards and a description of the manner in which the PHA addressed these recommendations. (2) Notwithstanding the 75-day limitation on HUD review, in response to a written request from a Resident Advisory Board claiming that the PHA failed to provide adequate notice and opportunity for comment, HUD may make a finding of good cause during the required time period and require the PHA to remedy the failure before final approval of the plan. 24 CFR § 964.410 Additional definitions.

The following additional definitions apply to this subpart only:

Directly assisted. Directly assisted means a public housing resident or a recipient of housing assistance in the tenant-based section 8 program. Direct assistance does not include any State financed housing assistance or Section 8 project-based assistance.

Eligible resident. An eligible resident is a person:
(1) Who is directly assisted by a public housing agency; (2) Whose name appears on the lease; and
(3) Is eighteen years of age or older.

Governing board. Governing board means the board of directors or similar governing body of a public housing agency.

Resident board member. A resident board member is a member of the governing board who is directly assisted by that public housing agency. 24 CFR § 964.415 Resident board members.
(a) General. Except as provided in §§ 964.405(b) and 964.425, the membership of the governing board of each public housing agency must contain not less than one eligible resident board member.
(b) Resident board member no longer directly assisted.
(1) A resident board member who ceases to be directly assisted by the public housing agency is no longer an “eligible resident” as defined in § 964.410. (2) Such a board member may be removed from the PHA board for that cause, where such action is permitted under State or local law. (3) Alternatively, the board member may be allowed to complete his/her current term as a member of the governing board. However, the board member may not be re-appointed (or re-elected) to the governing board for purposes of serving as the statutorily required resident board member.
(c) Minimum qualifications for board membership. Any generally applicable qualifications for board membership also apply to residents, unless the application of the requirements would result in the governing board not containing at least one eligible resident as a member. Further, PHAs and localities may not establish eligibility requirements for board membership that are solely applicable to residents. 24 CFR § 964.425 Small public housing agencies.
(a) General. The requirements of this subpart do not apply to any public housing agency that:
(1) Has less than 300 public housing units (or has no public housing units):
(2) Has provided reasonable notice to the resident advisory board of the opportunity for residents to serve on the governing board;
(3) Has not been notified of the intention of any resident to participate on the governing board within a reasonable time (which shall not be less than 30 days) of the resident advisory board receiving the notice described in paragraph (a)(3) of this section; and
(4) Repeats the requirements of paragraphs (a)(2) and (a)(3) of this section at least once every year.
(b) Public housing agencies that only administer Section 8 assistance. A public housing agency that has no public housing units, but administers Section 8 tenant-based assistance, is eligible for the exception described in paragraph (a) of this section, regardless of the number of Section 8 vouchers it administers. (c) Failure to meet requirements for exception. A public housing agency that is otherwise eligible for the exception described in paragraphs (a) and (b) of this section, but does not meet the three conditions described in paragraphs (a)(2) through (a)(4) of this section, must comply with the requirements of this subpart. ————————————
  


     



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General Comment:

Thank you, Patrick.

Please let me know what CoC program participants like myself need to do to secure representation in the SMHA Board as is required by the law.

There never was an effort by SMHA to create the required representation on the governing body of SMHA.

This is not only in violation of the HUD regulation but also discriminatory when HCV participants have a path to get their representatives on the governing body of SMHA but CoC program participants don’t.

At a time here the city has declared a state of emergency regarding homelessness, how can the City justify going to great lengths to prevent CoC representation on the governing body of SMHA? Thank you for your assistance.

Regards,
Olga Zurawska
  


     



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Comment from RAB Member
Hello,
My name is Mia and I am providing my comments for the Section 8 Administrative Plan in writing should I be unable to be present on the actual day via video:
1) They have to make the Payment Standards automatically correlate with the FMRs posted to HUDs Website Annually and proactively instead of waiting for the HCV program to be unhelpful to hopefully clients or an emergency to address this concern about clients finding a home in the Housing Authority given price range or aka payment standards. A person has to be able to use a common website such as craigslist.org or Westsiderentals.com etc. For example, to be able to find housing quickly and in the time frame for the vouchers expiration date. Let's avoid looking at it in terms of undeserved "luxury" or whatever or that people somehow need to live in squalor so that poverty has a specific image to judge and instead focus solely on getting people housed using the HCV program to utilize the housing that is already available in the market so that people don't have to be homeless for decades waiting on specific genre of buildings to be build or converted for " low income" aka poor and poverty stricken. By adding language for automatic and proactive changes in rental payment standards, you would take the guesswork out and less work on your end because HUD would be posting rents for you:) 2) Let's change the "Bedroom Standards". Or HCV bedroom allotment for families. Change it to 1 person= 1bedroom and at the 1 bedroom payment standards for HCV approval. If there is 1 parent and one child = 2 bedrooms, 2 adults = 2 bedrooms unless they are married. 1 adult and two children can have 2 bedrooms if the children are close in age and same gender. If the children are opposite identifying children then they can change an adult with 2 children (1 boy and 1 girl) as granted 3 bedrooms and 3bedroom payment standards. 1 Married couples can have one bedroom because they would likely be sleeping in the same room together. Stop considering studios or efficiency as a "1 bedroom" under the rent payment standards. Stop treating the living room as a bedroom. If an appraiser for a property that is for sail, only considers it a bedroom if it has its own door and closet for clothing storage then that is what it should be for everyone. Studios and efficiency has to be treated as immediate and temporary housing similar to tiny homes, never intended for long term residency.

Adjusting the bedroom standard makes it easier to find housing. Also, I am even a fan of just giving people a budget based on household and say go find housing in this price range whatever you can find and be approved for. Rather than saying if you find a 2 bedroom with a den that you are prohibited from using your 3 bedroom voucher because it's not technically a bedroom. It's could save the housing authority money for a family to choose that unit to rent, so let them exercise choice. If a 1 bedroom person would rather have a studio because it's the only place available near their job and within their price range, let them choose it while maintaining their 1 bedroom payment standards because it gets them housed quickly and that is the primary purpose. Maybe they have mobility issues or they want to pay less utilities every month. Trust them to make a decision for themselves by taking away so much restrictive language and obstacles that could affect efficient use of the program.

We are not punishing people for being poor or for circumstances that put them in poverty. We are helping people and we want them to be happy about it. Once everyone has the HCV there will be little to no envy. Squeezing 6 people into a 2 bedroom for example is ridiculous and not practical. It might even be contributing to mental health issues.

In Santa Monica, if you address these three issues, the program will be more efficient and useful.

California is unique in that it has higher rents. This is a way to house people, give them an actual choice in housing like the program implies, and gives them breathing room and will make them confident to address housing issues like maintenance when they're not trapped by rare cheap price of rent, they could simply move to a better landlord avoiding pests, crime or plumbing issues for example.

California never has to penny pinch, they have plenty in surplus budgets. The poor will likely behave better and look better instead of being a blite on the community when they have a reason to care and stuff to care about and take care of. It's been a jungle because they were treated like animals with no way out or a safety net to life circumstances that would allow for a law abiding life in peace of mind. So let's give them this pathway to resume contributing to society and peace to mind recover and move on from traumatizing poverty and homelessness. And include military Veterans for eligibility. VASH and HCV are essentially the same, only the rent payment standards are different. This will give non program participating neighbors peace of mind and desire to stay when the neighborhood remains clean and safe and they actually get to know who's living with next to them is human just like them.

Last, can you add some language that will say that if a person is a victim of crime or custody matter or abduction/kidnapping that they will be treated as if the child is still in home if they can show the agency a nexus between the missing household member and criminal activity such as domestic violence. And without housing decisions for allotment being related to any court orders. Some people who have had to escape domestic violence or whatever have been separated from their children or other family members and they should have enough space to provide for them should they return. If a walkthrough was conducted on a one bedroom and a parent is trying to get 4 children back for example, it might be seen as a negative to be living in a one bedroom compared to a husband who has a house for example.

We avoid punishing victims and the poor for the life circumstances. Rather we look for ways to help and improve their lives and circumstances long term.

Cantor Oreen Zeitlin
March 15, 2023
City of Santa Monica Housing
1685 Main Street Stop #19
Santa Monica, CA 90401
Dear Representative:

My experience with Section 8 Housing has been, unfortunately, less than ideal. While I understand that you are understaffed and overloaded right now since the pandemic, it has been since December 1, 2022 that I have not received a call or email in return of some very valid issues. That is a large gap in communication. Further to this, my Social Worker at Wise and Healthy Aging also said she never gets her communications returned. That does not bode well for the agency.

I am currently living on Social Security and SSI. I am handicapped since July, 2021. To begin with, I had a monthly increase of my share of the rent from $314 per month to $376 in one month with the total being paid by Section 8 remaining the same. The letter I received said I paid $366 per month last year which I did not. The Management Company also did not receive an increase last year from $314 per month. I called the Administrator of Section 8 after months of trying to reach my contact at the agency and have received no reply after several weeks, even though he stated that there was a discrepancy.

Further to this, the increase in rent was dependent on an increase in Social Security. Section 8 made the calculations before November, 2022 and before the large increase in costs for gas. My heating bill in January alone was $262, Further, the Social Security increase did not even cover the increased cost of food, which has left me to choose between food and heat. The calculations used were definitely well below the increases in cost of living in Santa Monica. DPPS just informed me today that they are cutting back on the food allotment which does not cover the inflation as it is and prices for food are still going up. When prompted, I was number 61 in the cue and I hung up. There is no way to reach them directly and since the social worker is changed constantly, I do not even know whom to ask for.

The next issue has to deal with Senior Housing. I went to the building on 14th Street with a great view of the cemetery. This was at the height of the pandemic before there were vaccines. The manager of the facility was a young woman who bragged about being anti vaccine. And she was in charge of Senior Housing. She showed me an apartment on the second floor. It was smaller than a dormitory room and had composite cabinets full of formaldehyde and plastics with phalates everywhere. Phalates and formaldehyde cause cancer. Who knows what other chemical laden materials were used! There was no way out of the building in case of fire or earthquake. There was one elevator which would not be working in either situation, and there were over 30 steep stairs from the second floor to the first floor, which I could not climb down if I had to. The entire building is a fire trap for Senior Citizens.

The next issue is toxic mold. While sequestered during the pandemic, I became more and more ill until one day in July, 2021, I woke up barely able to walk. My Physician, Dr. Gabriel Niles, took tests and told me I had Mycotoxin Poisoning which is a mold poisoning, and told me I had to move to another place immediately. My landlord and Management Company refused to do any remediation of the moldy walls. Three apartments that are similar in the courtyard building have mold. There are only four apartments so that is 3 out of four. In the four apartments in my building, my next door neighbor had mushrooms growing out of her walls. The next apartment over, with two small children, had black mold all over the apartment that was not remediated.

The Board of Health did not order mold remediation. The inspector of Section 8 Housing said “I have seen worse.” regarding bubbling paint in my apartment from mold, and they passed inspection despite many infractions. Code Enforcement let them pass inspection. Nobody in any agency would care about systemic problems in the buildings, only in each apartment which they passed despite unhealthy conditions.

Further to this, I called Rent Control and spoke to Amelia who mentioned to me that there was a big problem with mold in older buildings in Santa Monica. If that is the case, why are they allowing people to live in mold infested housing, especially children and vulnerable Senior Citizens? Obviously mold is an issue they know about but do not enforce.

My solutions are the following:

Change the codes to set a minimum standard for mold, visible and invisible.

Require that there be testing for levels of mycotoxins, other molds and cancer causing toxins before people move in to any building and before any building is bought or sold. If mold exists above a certain level, require remediation.

Agencies must look for systemic problems in buildings and not just by each apartment.

Section 8 cannot just let people pass inspection with obvious issues.

You can speak to or visit the website ISEAI.org which deals with environmental toxins or you can call Dr Kelly McCann in Costa Mesa, CA who deals with patients with mold illness or Dr.

Gabriel Niles of St. Johns Physicians Partners who also deals with mold issues and has a questionnaire for people to fill out regarding known toxins when they come for an initial visit. In addition, Mr. Michael Schrantz of Toronto, Canada is an expert on environmental issues who can be reached to speak to you about toxin contamination.

By the way, the area around Santa Monica Airport has a cancer cluster. I suggest you make such maps more readily available to consumers. I found out only after I moved to the area.

Before July, 2021, I never considered mold or any issue of this type and did not even know about Mycotoxins. Now I have become handicapped as a result of building conditions that are not mitigated and am as a result, dying. Before the sequestration, I was fine. My previous internists said that I was totally asymptomatic. After sequestration, I I became very ill. Now I am sensitive to environmental toxins and poisons, where before the sequestration, I felt and showed no symptoms outwardly.

I am hoping that this letter will be taken into consideration as the cost to the health system will be millions of dollars in Santa Monica alone. I am hoping that just because someone is poor, they will get healthy housing situations instead of having to choose between mold and cancer causing chemicals in their environment.

Please change the codes and make owners responsible. Nobody made them buy sick buildings.

Sincerely,
Cantor Oreen Zeitlin
Hi Pat,
Thank you again for talking with me last week. I'm encouraged by our conversation and your support for SMHA clients and the CAB.

I just learned that I was mistaken about the current status of the RAB representatives to the SMHA Board. Despite any local rules saying otherwise, SMHA is legally required by HUD policy to ask the RAB at least once a year if anyone is interested in being one of those two designated RAB representatives. As Ann Cochran and Donna Brown have been designated RAB representatives for almost two years now, and the RAB was never asked after the first year if any other members wanted to serve, that must be remedied and happen now.

Tonight I attended a five hour RAB meeting of approximately ten current RAB members. The RAB members present voted unanimously for two new RAB representatives to serve on the SMHA Board until the CAB can meet and choose CAB representatives. Those two new RAB chosen RAB representatives are Courtney Lauretano and Hajar Muqtasid St Claire.

I ask that you please arrange for these two people to be named as replacement RAB representatives to the SMHA Board in time to attend the April 11th SMHA Board meeting as board members.

As staff chose the initial two representatives, their rightful one year tenure has long since ended, and SMHA did not ask the RAB if anyone else was interested in the last year as required by HUD policy, staff designating two new RAB representatives chosen by the existing RAB should pose no problem.

I've copied SMHA Board members Phil Brock, Christine Parra, and Oscar de la Torre and encourage you to confer with them if you have any concerns about honoring my request.

Thank you again for your support of our self representation, Pat. Please let me know if you have any questions.

Very best wishes,
Michele
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