8/9/2019 Ph Css Test Nycha Plan 610 (3)

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Testimony of Victor Bach,Senior Housing Policy Analyst

Community Service Society (CSS)

Public Hearing on the Draft Annual Plan for FY 2011

New York City Housing Authority (NYCHA)

June 30th, 2010

The Community Service Society (CSS) is a 160 year-old organization dedicated to

promoting the economic security of low-income New Yorkers. For 15 years CSS has worked

closely with NYCHA resident leaders on a range of policy issueslocal, state and federalthatimpact our public housing communities. CSS fully supports the attached position paper put

forward by the NYC Alliance to Preserve Public Housing, a collaboration of resident leaders,advocates, and concerned officials.

I want to focus this testimony on the question of what constitutes a significant

amendment to a NYCHA plan. Last October, after the June public hearing, NYCHA proposedto demolish hundreds of units at Prospect Plaza as a last-minute amendment to its 2010 Plan,

without adequate time for RAB review, without the 45-day notice or public hearing that would

be required if it was considered a significant amendment. We hold that any proposal to

demolish public housing in New York City is a significant proposal.

Federal law requires annual plans, notice, and a public hearing for good reasonthey are

due process to assure greater transparency and public accountability. NYCHA casual attitudeabout demolition sets a very bad precedent for the future. Similarly, a change in pet policy was

recently incorporated without adequate notice and may result in evictions. A change in

admissions policy, barring some claimants for five years, was also considered insignificant bythe authority.

In this years plan (page 118) NYCHA finally defines what it considers a significantamendment. A plan amendment is considered significant 1) if it results from a change in the

federal law, or 2) if NYCHA considers it a significant amendment. That is not acceptable.

NYCHA, like any public, governmental body, has no right to that kind of institutional arrogance.

NYCHA must set standards, stricter standards for significance, or these hearings are

meaningless. Any change can be slipped in between now and October if NYCHA deems it

insignificant.

We propose that NYCHA consider a plan amendment significant if it will result in 1)

the demolition of public housing, or 2) the disposition of NYCHA property, or 3) increasedevictions, or 4) a change in admission policy. CSS urges NYCHA to adopt these standards for

significance and include them in the Annual Plan it submits to HUD this coming October.

Thank you.

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