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CORRESPONDENCE - WS-1 OPPOSITION
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CORRESPONDENCE - WS-1 OPPOSITION
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WS-1
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2/6/2018
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36 <br />community at large, forced displacements entail direct public costs <br />in the form of fees for court services, social services, and use of <br />homeless shelters and emergency foster care. <br />The recent focus on forced relocations has led several cities to <br />review their eviction procedures. In 2017, New York City became <br />the first city in the country to guarantee legal representation to <br />low-income residents facing eviction, other cities have taken steps <br />to limit the set of causes for which landlords can pursue eviction. <br />Expanding support for emergency rental assistance and rapid re- <br />housing programs would also help to protect households most at <br />risk of homelessness. <br />GROWING INCOME SEGREGATION <br />Residential segregation by income has increased steadily in recent <br />years, especially among households with the highest and lowest <br />incomes. This trend adds to the challenges posed by entrenched <br />residential segregation by race and ethnicity in many cities. It also <br />raises concerns that low-income renters have increasingly limited <br />access to a full range of neighborhoods. <br />In 2015, the average renter household earning under $20,000 lived <br />in a neighborhood where 28 percent of residents had comparably <br />low incomes and only 15 percent had incomes above $100,000 <br />(Figure37). In comparison, the average US household lived in a neigh - <br />Rental Property Owners Are Slower than Homeowners <br />to Rebuild Following Disasters <br />Condition of Horricano-0am2ged Properties in Louisiana and Mississippi After Five Years <br />(Percent) <br />90 <br />go <br />70 <br />60 <br />50 <br />40 <br />30 <br />20 <br />10 <br />0 <br />Small Renal Properties Homeowner Propar0es <br />â– Remin[l P'p Cleared Lot In Need of Suhsticaral Repairs <br />Nates: Sample is representative of residential properties that experienced major or severe hurricane de mage <br />and were located on significantly affected blocks. Rebuilt structures are resldeneas that do net show <br />substantial repair needs, Cleared lots contain an empty lot ore foundation with no slanding structure, <br />Source: Spade[ 2915. <br />borhood where 18 percent of residents had incomes below $20,000 <br />and 24 percent had incomes above $100,000. <br />A recent JCHS working paper provides evidence of the detrimental <br />effects of residential segregation on the educational attainment, <br />employment, socioeconomic mobility, and health of low-income <br />renters. Households living in areas of concentrated poverty are <br />particularly vulnerable. Such segregation not only limits economic <br />potential for individuals and society as a whole, but also reduces <br />social cohesion and intergroup trust, increases prejudice, and erodes <br />democratic participation. <br />Reversing this trend is difficult and would require changes in both <br />private markets and the location of assisted units. A key step would <br />be to increase the supply of low-cost rental units in neighborhoods <br />of all types, including construction of assisted units in a broader <br />range of neighborhoods. Many states have in fact begun to incentiv- <br />ize LIHTC applicants to propose projects that do just that. In addi- <br />tion, the recently finalized Affirmatively Furthering Fair Housing <br />(AFFH) rule establishes a planning process for local HUD grantees to <br />assess current residential patterns and to take meaningful actions <br />that foster inclusion. <br />Reforms to the housing choice voucher program would also help to <br />increase the options available to low-income households, outreach <br />to landlords, protections against source -of -income discrimination, <br />and mobility counseling would all serve to expand the range of prop- <br />erties and neighborhoods available to voucher holders. For example, <br />the results of Baltimore's Special Mobility Housing Choice Voucher <br />program demonstrate that mobility counseling can help to increase <br />neighborhood choice among voucher holders. HUD's Small Area Fair <br />Market Rent demonstration is also testing whether adopting neigh- <br />borhood -level fair market rents (FMRs) would induce moves into a <br />broader set of neighborhoods. HUD currently sets a single fair mar- <br />ket rent for each metropolitan area, often forcing voucher holders <br />to choose from units clustered in a few neighborhoods where rents <br />fall below the FMR. While the interim report on the demonstration <br />found evidence that neighborhood -level FMRs broadened the loca- <br />tion choices of voucher recipients in some areas, the results were <br />less encouraging in other areas, and HUD has suspended expansion <br />of the demonstration to additional metros. <br />REBUILDING AFTER DISASTERS <br />The damage wrought by natural disasters in 2017 will pose substan- <br />tial rebuilding challenges for years to come. Much of the housing <br />stock lost in the recent hurricanes, for example, was renter -occu- <br />pied. Indeed, the latest American Community Survey indicates that <br />rental units accounted for 41 percent of all housing in the Houston <br />metro area, 36 percent in Florida, and 32 percent in Puerto Rico. <br />
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