Attachment G
1 Summary of Comments and Responses
Public Comment, General Public, Voucher Participants, & SMHA Staff Response Written Comment:
Regarding the letter from the SMHA for the Administrative Plan workshop dated March 6, 2023, the meeting does not exist.
Response:
The opportunity to provide input and the meeting for the Administrative Plan workshop was held Monday, March 13, 2023, at 1:00 PM in accordance with that notice.
The following comments were submitted in writing by a single voucher holder via direct correspondence with the SMHA and at the March 2, 2023, Housing Commission meeting.
Comments:
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.
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.
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.
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 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?...
Attachment G
2 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.
CoC voucher holders do not have any representation on the Housing Authority Board (HAB).
Elizabeth Cochran and Donna Brown have been not appointed with any input from the program participants and are not representatives.
If HCV participants have their reps on HAB, why don't CoC participants have one as well? we have a state of emergency declared based on homelessness, but we don't want to hear from unhoused people? What kind of government acts like this?
The Housing Commission is NOT a policymaking body but merely an advisory body to SMHA Board (i.e. City Council). The participation of a formerly homeless person on the Housing Commission is not equivalent to what is required by federal regulation.
The Housing Authority Board 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 unhoused participant in the CoC program).
There are no HCV reps on SMHA Board and yet SMHA sends out misleading correspondence to program participants claiming that such reps exist.
Response:
The main role of the Resident Advisory Board (RAB) is to make recommendations in the development of the Public Housing Authority (PHA) Plan. The current RAB consists of the entire Housing Choice Voucher (HCV) program and solicits direct input from all voucher participants. The SMHA is currently compliant with the federal requirements for the Housing Authority Board (HAB) and the RAB.
Elizabeth Cochran and Donna Brown are both active tenants in the SMHA’s voucher program and qualify to be tenant representatives. Additionally, the SMHA is compliant with 24 CFR 964.425 (b), with regard to representation which was confirmed by HUD on May 29, 2020.
The SMHA has actively sought input from all voucher program participants during the public comment period with various opportunities. On February 3, 2023, staff posted the start of the public review period on the Housing Office website. Notices were published in the Santa Monica Daily Press on February 4, 2023, and February 25, 2023. On February 6, 2023, staff directly notified members of the Resident Advisory Board and all other voucher participants via direct mail or email correspondence of the opportunity to provide input on the SMHA Plans. Additionally, staff invited all voucher participants and members of the public to the Housing Commission meeting on March 2, 2023, to provide comments and input on the SMHA Plans. Staff also held a workshop on March 6, 2023, which served as another opportunity to discuss and provide input during the public review period.
Attachment G
3 To create a more inclusive and representative Housing Authority Board (HAB) and RAB, the SMHA is proposing the creation of a Client Advisory Board (CAB) which would create opportunities for all the SMHA’s voucher participants to serve on the CAB as well as the HAB. The two tenant representatives on the HAB would be selected from the newly proposed CAB, which will be presented for Council and HAB consideration on April 11, 2023.
Comment:
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.
There is no functioning RAB, and SMHA has been aggressively obstructing the creation of one despite a dire need and a strong interest from program participants.
Response:
HUD guidance provides Housing Authorities with great discretion in the creation or a RAB. The current RAB for the SMHA consists of the entire Housing Choice Voucher (HCV) participant population and complies with federal regulations. Regarding the Housing Authority Board, HUD determined in 2015 that the SMHA is in compliance with the Continuum of Care (CoC) program requirement regarding participation of a homeless person or formerly homeless person, as such representation is achieved through the Housing Commission and its bylaws requirement that at least one Commissioner be a homeless person of formerly homeless person.
Comment:
A proper assessment of the feasibility of administering HUD's HCV Homeownership Program should be a goal of SMHA as part of its efforts to affirmatively further fair housing (AFFH).
Response:
Adding a Homeownership program would involve evaluating the associated regulations, assessing the feasibility of such a program given the gap between maximum voucher payment standards and real estate prices in Santa Monica, and determining the staffing and other resources needed to support the program. Currently, the SMHA is focused on completing its core responsibilities according to HUD’s requirements and does not have resources that can be allocated to assessing the feasibility of new programs such as a homeownership program.
Attachment G
4 Summary of Resident Advisory Board Member Comments, Other Voucher Participant Comments & SMHA Staff Response
Resident Advisory Board (RAB)/Client Advisory Board (CAB) (Submitted by Email/at the Housing Commission meeting and Administrative Plan Workshop):
Comments:
The SMHA Board should refuse to approve the Administrative and Annual Plans until all RAB members can meet, review discretionary documents, discuss, and submit collective feedback to the SMHA.
Delay requesting/providing Housing Authority Board approval of any Administrative Plan changes until RAB members are meaningfully informed about the document and their rights, provided a genuine and accessible opportunity to meet as a RAB and discuss the Administrative Plan, and given adequate time and means to provide feedback as a RAB.
The SMHA should immediately schedule the six-month-overdue meeting of the RAB/CAB that was ordered to be organized “with haste” by a unanimous City Council/SMHA Board vote on September 13, 2022.
As a RAB member, I am guaranteed by federal HUD policy administrative support by the SMHA to meet with my fellow RAB members to discuss RAB business. It is not sufficient to call all client’s RAB members but only allow direct individual feedback to staff on the Administrative Plan. SMHA must set a RAB meeting for RAB members only ASAP. City Council voted to direct staff to do just that for RAB (and would-be CAB) members "with haste" last year and it has yet to be done. SMHA clients are being denied participation in a functioning RAB for yet another Administrative Plan cycle in violation of federal policy.
The last-minute workshop does not fulfill SMHA’s obligation to inform clients about the Administrative Plan and provide an opportunity for us to confer as a RAB and submit feedback as a RAB. We’re receiving less than two weeks notice (for mail recipients it will be closer to a week), it’s scheduled for 1pm on a workday, and there’s no opportunity for the RAB to confer before providing input.
I would like to affirm the requests of several participants who have requested a general meeting prior to approval of the HUD plan. My suggestion is a meeting facilitated by a professional eg. Dr.
Karen Gunn who has extensive expertise in working with client groups. Since the plan is so large another suggestion would be breakout groups that could synthesize the material and present feedback to the group.
The SMHA adopts the recommendations of the Housing Commission regarding the RAB/CAB, including supporting annual RAB/Cab Elections to the SMHA Board.
The SMHA should facilitate annual 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 Attachment G
5 b) for the results of the surveys to be compiled and provided to the RAB/CAB for further use.
Response:
On February 3, 2023, staff posted the start of the public review period on the Housing Office website. Notices were published in the Santa Monica Daily Press on February 4, 2023, and February 25, 2023. On February 6, 2023, staff directly notified members of the Resident Advisory Board and all other voucher participants via direct mail or email correspondence of the opportunity to provide input on the SMHA Plans. Additionally, staff invited all voucher participants and members of the public to the Housing Commission meeting on March 2, 2023, to provide comments and input on the SMHA Plans. Staff also held a workshop on March 6, 2023, which served as another opportunity to discuss and provide input during the public review period.
Finally, nine voucher holders met independently of SMHA staff to discuss and provide input on the SMHA plans.
The SMHA is proposing the creation of a Client Advisory Board (CAB) which took considerations from the HAB, the Housing Commission, an independent consultant, and is modeled after other boards in the City of Santa Monica.
Programs and Opportunities
Family Self-Sufficiency (FSS) Program
Comment:
The SMHA should revive the FSS Program and actively seeks out funding through the Notice of Funding Opportunities (NOFOs) applications to ensure the FSS Program has the maximum funding available.
Response:
The SMHA is currently sunsetting the FSS program and most of the operational aspects have been or will be shut down. Although the SMHA can seek out funding for the FSS program, it would not be sufficient to revitalize the FSS program. Additionally, the SMHA is focused on completing its core responsibilities as a Housing Authority and does not have resources that can be allocated to revitalize the FSS program.
Move to Work (MTW) Demonstration
Comment:
The SMHA apply for the MTW demonstration, which would grant the housing authority more flexibility in the execution of its programs and funding.
Response:
The MTW is a demonstration program for public housing authorities (PHAs) like the SMHA that provides an opportunity to design and test innovative, locally designed strategies that use Federal Attachment G
6 dollars more efficiently, help residents find employment and become self-sufficient, and increase housing choices for low-income families. Applying for the MTW will require extensive consideration, review of the demonstration parameters, discussions with HUD for feasibility and applicability to the SMHA, and approval from the HAB. The SMHA will explore the MTW option.
Homeownership
Comments:
The SMHA should create a Homeownership Program for HCV program participants as a way to assist those of low or extremely low income in purchasing a condo or house. Note: that any homeownership program created for SMHA HCV participants can be used to purchase homes outside of the City of Santa Monica.
Response:
The SMHA does not offer an HCV Homeownership program. Adding such a program would involve evaluating the associated regulations, assessing the feasibility of such a program given the gap between maximum voucher payment standards and real estate prices in Santa Monica, and determining the staffing and other resources needed to support the program. The SMHA is focused on completing its core responsibilities for Santa Monica residents according to HUD’s requirements and does not have resources that can be allocated to assessing the feasibility of a homeownership program.
Payment Standards
Comments:
The SMHA convert the payment standard to Small Area FMR and raise payment standards according to the recent Housing Commission recommendations to the City Council/SMHA Board.
The Payment Standard is insufficient.
Response:
The SMHA is currently reviewing the feasibility of using the Small Area Fair Market Rents (SAFMRs) to establish Payment Standards, rather than the metropolitan area Fair Market Rents.
Comment:
Make the Payment Standards automatically correlate with the Fair Market Rent (FMR) posted to HUD’s website.
Response:
The SMHA is required to review the Payment Standards at least once a year and make sure they are within HUD’s designated range of 90 percent to 110 percent of the current published FMR. Based on a previously requested and approved exception to the HUD limit of 110 percent, the SMHA’s Payment Standards currently exceed 110 percent of the current FMR for 1-, 2-, and 3-bedroom units, and for Efficiency units is at 99 percent of the 2023 published FMR. The following table shows the current SMHA and metropolitan area FMRs (Payment Standards).
Attachment G
7 Policy
Comment:
The SMHA received comments from participants, RAB members, and a letter from the Legal Aid Foundation of Los Angeles about the SMHA’s current Rent Increase policy, practices, and procedures.
Response:
The SMHA agrees with the comments that were submitted about landlords affirmatively requesting rent Increases and notifying tenants and has added clarifying language in the proposed Administrative Plan, Chapter 8 Section 8-III.B., Page 8-23.
Comment:
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 share living space. Note that the City of Los Angeles and other jurisdictions permit this.
Response:
The SMHA agrees with your input that voucher holders should be able to use the voucher in a shared housing situation and is proposing to amend the Administrative Plan to allow for Shared Housing. The proposed amendment can be found in The Administrative Plan Chapter 15, Page 15-1.
Comment:
Change the "Bedroom Standards". Or HCV bedroom allotment for families. Change it to 1 person= 1 bedroom 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 Attachment G
8 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.
Response:
The SMHA is required to adhere to HUD’s federal regulations in the facilitating and application of vouchers. The SMHA is required to size the voucher to the smallest number of bedrooms needed to house a family without overcrowding (defined as 2 persons per bedroom + 1).
The federal regulation that governs both is 24CFR § 982.402 which states the following:
(b) Determining family unit size. The following requirements apply when the PHA determines family unit size under the PHA subsidy standards:
(1) The subsidy standards must provide for the smallest number of bedrooms needed to house a family without overcrowding.
Additionally, the same regulation further states:
(c) Effect of family unit size-maximum subsidy in voucher program. The family unit size as determined for a family under the PHA subsidy standard is used to determine the maximum rent subsidy for a family assisted in the voucher program. For a voucher tenancy, the PHA establishes payment standards by number of bedrooms. The payment standard for a family shall be the lower of:
(1) The payment standard amount for the family unit size; or (2) The payment standard amount for the unit size of the unit rented by the family. (3) Voucher program. For a voucher tenancy, the PHA establishes payment standards by number of bedrooms. The payment standards for the family must be the lower of:
(i) The payment standards for the family unit size; or
(ii) The payment standard for the unit size rented by the family.
Comment:
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 at 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 their life Attachment G
9 circumstances. Rather we look for ways to help and improve their lives and circumstances long term.
Response:
The SMHA does have language in the Administrative Plan that establish exceptions to subsidy standard (i.e., bedroom size) on page 5-15, section 5-II.C. which states the following:
In determining family unit size for a particular family, the PHA may grant an exception to its established subsidy standards if the PHA determines that the exception is justified by the age, sex, health, handicap, or relationship of family members or other personal circumstances [24 CFR 982.402(b)(8)]. Reasons may include, but are not limited to:
• A need for an additional bedroom for medical equipment • A need for a separate bedroom for reasons related to a family member’s disability, medical or health condition
For a single person who is not elderly, disabled, or a remaining family member, an exception cannot override the regulatory limit of a zero or one bedroom [24 CFR 982.402(b)(8)].
PHA Policy
The PHA will consider granting an exception for any of the reasons specified in the regulation: the age, sex, health, handicap, or relationship of family members or other personal circumstances.
The family must request any exception to the subsidy standards in writing. The request must explain the need or justification for a larger family unit size, and must include PHA required documentation. Requests based on health-related reasons must be verified by a knowledgeable professional source (e.g., doctor or health professional), unless the disability and the disability– related request for accommodation is readily apparent or otherwise known. The family’s continued need for an additional bedroom due to special medical equipment must be re-verified at annual reexamination.
After a request for an exception is presented, the PHA will respond in writing, acknowledging receipt of the request, within 10 business days.
Based on the verified need for the exception or the absence thereof, the PHA will render its decision within a reasonable period of time. If a participant family’s request is denied, the notice will inform the family of their right to request an informal review.
Comment:
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.
Attachment G
10 Response:
A core requirement of job duties for all SMHA staff is to provide effective customer service, which includes treating program participants with respect. Additionally, the Administrative Plan includes a policy regarding discrimination complaints – see pages 2-4 to 2-5.
The Administrative Plan is specifically meant to describe the SMHA’s policies for the administration of the voucher programs, implementing and complying with federal regulations, rather than establishing customer service standards for staff. However, the SMHA is receptive to feedback about improving customer service and addressing complaints.
A landlord’s obligations to the voucher program participant are dictated by the terms of the lease and should be negotiated during the lease process. The landlord’s obligation to the SMHA is dictated by the Housing Assistance Payment (HAP) contract, which is a HUD-authored document that must be used by Housing Authorities. If the landlord violates the HAP contract, the SMHA enforces the contract in accordance with the specific violation and the policies and procedures outlined in the Administrative Plan.
New Staff Positions
Comment:
The SMHA should create and hire 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).
Response:
The SMHA is funded to complete its core responsibilities according to HUD’s requirements and does not have the resources or capacity to hire a designated ADA/Section 504 Coordinator at this time.
The City of Santa Monica has a designated ADA/Section 504 Coordinator that also works with the SMHA. The name and contact information for the ADA Coordinator is:
Mirna Medina, ADA/Section 504 Coordinator
PO Box 4050
Santa Monica CA 90411
310-434-2605 TTY: 310-458-8696
[email protected]
Comment:
The SMHA needs to designate or hire a Veteran Liaison to assist clients who have served in the military.
Response:
The SMHA is funded to complete its core responsibilities according to HUD’s requirements and does not have the resources to hire a designated Veteran Liaison. Additionally, the HUD-Veterans Affairs Attachment G
11 Supportive Housing (HUD-VASH) program, one of the voucher programs administered by the SMHA, combines HUD’s Housing Choice Voucher (HCV) rental assistance for homeless veterans with case management and clinical services provided by the Department of Veterans Affairs (VA). The VA provides these services for participating veterans at VA medical centers (VAMCs), community-based outreach clinics (CBOCs), through VA contractors, or through other VA-designated entities.
Comment:
The SMHA hire a Landlord Liaison/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 the source of income discrimination that while illegal, is rampant in Santa Monica.
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.
Response:
The SMHA is funded to complete its core responsibilities according to HUD’s requirements and does not have the resources to hire a designated Landlord Liaison/Housing Navigator or a Public Relations Officer. Additionally, the City of Santa Monica funds several local social service agencies that provide housing navigation to clients participating in their programs. Further, the City of Santa Monica has outlawed source of income discrimination in housing, and anyone experiencing such discrimination may file a complaint with the Consumer Protection Division of the City Attorney’s Office, which can be reached at 310-458-8336.
Comment:
The SMHA should seek the participation and input of the RAB/CAB when hiring a new Landlord Liaison/Housing Navigator, dedicated ADA/Section 504 Coordinator/Disability Liaison, and Veteran Liaison
Response:
The SMHA is part of the City of Santa Monica and must follow the same policies and procedures when hiring staff.
Customer Service
Comment:
The 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 Attachment G
12 include each employee’s direct report and names and contact information for recourse when clients encounter problems with SMHA at any level.
Response:
The SMHA is part of the City of Santa Monica and follows the same information protocols and transparency requirements as other City departments. Additionally, the SMHA provides direct contact information to program participants at the initial voucher briefing, every annual recertification, and as requested by program participants.
The SMHA as an agency reports to and is overseen HUD. Here is the website link to the contact information for the HUD Los Angeles Office: https://www.hud.gov/states/california/offices Los Angeles Field Office
United States Department of Housing & Urban Development (HUD) Los Angeles Field Office
300 North Los Angeles Street, Suite 4054
Los Angeles, CA 90012
Phone: (213) 894-8000
Email: Customer Service
Fax: (213) 894-8107
TTY: (213) 894-8133 or Dial 7-1-1 (Not available in all areas.) The SMHA’s governing body is the Housing Authority Board. Here is the website:
https://www.santamonica.gov/housing-hab
Here is the website link to the Salary Schedules of Santa Monica Employees:
https://www.santamonica.gov/media/Document%20Library/Detail/Memorandum%20of%20Unders tandings/MOU/2022_04_21_salary-sched.pdf
Here a link for employee salaries:
https://transparentcalifornia.com/salaries/santa-monica/ Here a link for tenant rights:
https://www.santamonica.gov/tenants-rights
Comment:
The SMHA does not have a point of contact for Reasonable Accommodations.
Response:
Every SMHA staff acts as a point of contact for reasonable accommodation requests. HUD requires that if an applicant or participant indicates that an exception, change, or adjustment to a rule, policy, practice, or service is needed based upon a disability, the SMHA must treat the information Attachment G
13 as a request for a reasonable accommodation. This rule requires that every staff member acts as a point of contact to initiate the reasonable accommodation process.
Comment:
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.
Response:
Chapter 16 of the Administrative Plan establishes the informal review process and rules. The Administrative Plan is available year-round at https://www.santamonica.gov/housing-policy-andreports. A specific form is not required to request an informal review, the applicant simply needs to make the request in writing and submit the request to the SMHA. The SMHA determines the appropriate staff member among the SMHA team to conduct the informal review, as long as the person is other than the one who made or approved the decision under review, or a subordinate of that person.
Comment:
The 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.
Response:
When the family payment (tenant portion of rent) is incorrectly set too low, the SMHA is providing more subsidy than allowed under the federal program. In cases where the error or omission is the fault of the PHA, the family and owner are not responsible for repayment of any previously paid excess amount. Going forward, the PHA must give the family and owner reasonable notice of the increase in the family payment and corresponding decrease in housing assistance payment.
In cases which the error or omission is the fault of the family, the family must repay the PHA within a reasonable period of time. If the amount owed is not repaid, the PHA may terminate the family’s assistance. The PHA must process the change immediately and inform the landlord and family of the effective date of the change. Increases in the amount of family payment resulting from a family error or omission become effective retroactively to the time of the reporting error or omission.
Comments:
Offer or partner with other agencies to offer supportive services to all SMHA program participants who need them.
The SMHA should offer or partner with other agencies to offer financial literacy programs to all SMHA clients.
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14 Response:
The SMHA does maintain partnerships with supportive service organizations and continually looks for other opportunities to support the voucher population. Here is current list of supportive services, information, and resources available within Santa Monica:
https://www.santamonica.gov/housing-resources
https://www.santamonica.gov/housing-at-risk
https://www.santamonica.gov/housing-seniors
The People Concern
(310) 450-4050
Disability Community Resource Center (DCRC)
(310) 390-3611
Step Up on Second
(310) 394-6889 (310) 576-1308
WISE Senior Services
(310) 394-9871
St. Joseph Center
(310) 396-6468
Legal Aid Foundation of Los Angeles (LAFLA)
Phone: (310) 899-6200
Website: lafla.org
City of Los Angeles Housing Resource Center
http://www.housing.lacity.org/
Affordable Housing in Los Angeles County
https://www.affordablehousing.com/los-angeles-ca/
If you need a place to stay in the case of an emergency:
211
Call 2-1-1 or visit 211LA.org. Operators will help you home in on resources based on your specific needs and situation.
Comment:
The 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 Attachment G
15 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.
Response:
The SMHA is funded to complete its core responsibilities according to HUD’s requirements and does not have the resources to independently fund legal services for tenants beyond those funded with City of Santa Monica resources.
Comment:
The 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.
Response:
Here is the website link to the contact information for the HUD Los Angeles Office:
https://www.hud.gov/states/california/offices
Los Angeles Field Office
United States Department of Housing & Urban Development (HUD) Los Angeles Field Office
300 North Los Angeles Street, Suite 4054
Los Angeles, CA 90012
Phone: (213) 894-8000
Email: Customer Service
Fax: (213) 894-8107
TTY: (213) 894-8133 or Dial 7-1-1 (Not available in all areas.) Comments:
The SMHA 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.
The SMHA must educate clients about the existence, role, and details of medical deductions in determining income and subsequently share of the rent, including specific information about what counts as medical deductions and information on how and when to submit deductions. The SMHA should also furnish all clients who submit medical deductions with itemized results of those claims including approval or denial and the reason for any denial.
Response:
The SMHA agrees and will ensure transparency for the participants in rent calculations, expenses, allowances, deductions, and the tenant’s share of the rent.
Attachment G
16 Comments:
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.
The SMHA 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.
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/affordablerentals/).
Make the program more accessible for persons with disabilities.
Response:
The SMHA continuously seeks to improve communications with, and information to, program participants. The SMHA will review the current format of the website to explore options to improve accessibility, communication, transparency, and customer service delivery.
Comment:
There needs to be a survey of all voucher holders to assess the experience of the end user of the program, which is the tenant.
Response:
The SMHA will explore options to access the voucher holders’ experience to improve accessibility, communication, transparency, and customer service delivery.
Comment:
Would like plans written in layman’s terms.
Response:
The Annual Plan is presented on a form required by HUD. SMHA will strive to publish a summary sheet of the changes in easier-to-understand terms.
Other
Comment:
The SMHA should work with the city of Santa Monica to ensure Housing Commission meetings are live-streamed and made subsequently available on YouTube, with hybrid participation.
Attachment G
17 Response:
The Santa Monica Housing Commission is a City advisory body created by the Santa Monica City Council and must adhere to the rules and procedures for advisory bodies adopted by Council.
Comment:
The SMHA must overhaul and create transparent, measurable, and regularly tested parameters for Below Market Housing (BMH) list notices and digital and physical correspondence with clients to ensure all clients receive equal BMH opportunities and all SMHA communications.
Response:
The BMH waitlist is a City program which matches waitlist applicants to affordable housing opportunities throughout the City and is not administered by the SMHA, which administers rental housing voucher programs. Waitlist applicants are contacted as opportunities arise which match the income and household size requirements of the housing opportunity, and the system is based upon diligent and timely responses to opportunity notifications.
Comment:
The SMHA must address ongoing habitability issues that program participants face, including mold, cockroaches, and bed bugs. The 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.
Response:
HUD requires that the SMHA enforce the federally-established Housing Quality Standards (HQS), which all housing must meet in conjunction with voucher assistance. All housing must pass an HQS inspection prior to the initial occupancy and then annually or biennially. Additionally, Chapter 8 of the Administrative Plan is dedicated to HQS – see pages 8-1 to 8-26, providing details on the physical standards that housing must meet, the inspection process, obligations of owners and tenants, and the SMHA’s policies for program enforcement.