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Robin Hammeal-Urban
Publication Date: June 1999
NOTE: This paper urges advocates to comment on proposed housing regulations. However, since this paper was written, those regulations have become final.
Special thanks to The Ford Foundation for its support of the National Resource Center on Domestic Violence and Building Comprehensive Solutions to Domestic Violence, the initiative under which these materials were produced. We also wish to acknowledge the U.S. Department of Health and Human Services for their ongoing funding of the NRC.
The ideas expressed herein are those of the author and do not necessarily represent the official position or policies of The Ford Foundation or other funders of the National Resource Center on Domestic Violence.
Published by the National Resource Center on Domestic Violence, a project of the Pennsylvania Coalition Against Domestic Violence, June 1999.
These materials may be reprinted or adapted with proper acknowledgment.
The author wishes to thank Amy Correia, Anne Menard, and Susan Schechter for their valuable assistance in reading and commenting on drafts of this paper, and Kara Walsh-Hart for her assistance in proofreading this paper.
Thanks also to Jill Davies, who offered encouragement and valuable assistance in refining ideas, reviewing drafts, and offering guidance on the writing of this paper.
A special thanks to Richard Tenenbaum for his continuous and thorough review of HUD regulations, and insightful comments on this paper.
Robin Hammeal-Urban is the Outreach and Policy Attorney for the New England Network on Domestic Violence and Poverty. Her previous experience includes 13 years of advocating for the rights of people living in poverty, through litigation and policy advocacy, while a staff attorney at Greater Hartford Legal Assistance, Inc., in Connecticut.
The New England Network on Domestic Violence and Poverty is a new initiative of Building Comprehensive Solutions to Domestic Violence, a multi-year project of the National Resource Center on Domestic Violence. The Network will explore a variety of approaches to multi-disciplinary policy development and advocacy for battered women and their families, especially those who are living in poverty. Coordinated by Greater Hartford Legal Assistance, Inc., the Network will be a catalyst to develop comprehensive policy strategies to address domestic violence and poverty. Material and lessons learned from the Network will be shared with domestic violence coalitions and anti-poverty advocates around the country.
The federal agency responsible for designing and overseeing the operation of federal housing programs, the Department of Housing and Urban Development (HUD), recently issued two sets of proposed regulations that are of particular interest to battered women 1 and their advocates 2 . The proposed regulations will govern the way two federal housing programs operate -- "public housing" 3 and the "Section 8 voucher program." 4 . Among other things, the proposed regulations set out ways in which people could be chosen to benefit from these programs. According to the proposed regulations, victims of domestic violence should get into housing programs before other people who are applying.
There are two purposes for this paper. The first is to encourage domestic violence advocates, housing advocates, and legal services staff to collaborate in an effort to support proposed federal housing regulations that begin to address some of the housing needs of battered women. These collaborations will be essential as each public housing authority designs its own plan to implement these regulations and others in the federal housing programs they administer 5 . Important decisions that may affect battered women will be made in the next few months. Now is the time to start building collaborations. The second purpose of this paper is to urge domestic violence advocates to submit comments to the Department of Housing and Urban Development (HUD) to support those sections of the proposed regulations that could give battered women faster access to housing.
The proposed regulations are just that, proposed regulations. They are not yet final. Before HUD finalizes the regulations, HUD will accept comments from the public. There are two sets of proposed regulations. Comments on one set of proposed regulations are due at HUD by June 29, 1999. Comments on the other set are due at HUD by July 13, 1999.
There are two sets of proposed regulations that include HUD's directive to public housing authorities to "consider preferences for individuals who are victims of domestic violence." You should send a separate letter to comment on each set of these proposed regulations. The content of the two letters can be identical. Remember, each letter should refer to just one set of proposed regulations by title and docket number.
SET 1: "Changes to the Admission and Occupancy Requirements in Public Housing and Section 8 Assistance"
Docket No. FR-4485-P-01
Comments due by June 29, 1999.
SET 2: "Section 8 Tenant Based Assistance; Statutory Merger of Section 8 Certificate and Voucher Programs; Interim Rule"
Docket No. FR-4428-I-01
Comments due by July 13, 1999.
Both letters should be sent to:
Regulations Division/ Rules Docket Clerk
Office of General Counsel
Room 10276
Department of Housing and Urban Development
451 Seventh Street, SW
Washington, DC 20410-0500
The next step is to advocate with your local public housing authority in collaboration with your allies in housing advocacy, anti-poverty organizations, and legal services. Public housing authorities will have to develop annual and five-year plans that will specify how the public housing authority will administer its public housing program as well as the Section 8 voucher program. Among other things, these plans will specify how the public housing authority will choose people from its waitlist, including whether it will give a preference to victims of domestic violence. It is important to be involved with your local public housing authority as it creates its annual and five-year plans that must be submitted to HUD. If the federal regulations direct public housing authorities to consider preferences for victims of domestic violence, but these preferences are not included in the plans of public housing authorities, then battered women will not have gained anything meaningful.
You can find out when your public housing authority will be working on the annual and five-year plans by calling your local housing authority (the phone number of your public housing authority can be found by looking in the government listing section of your phone book), or by asking local housing advocates or legal services staff. Some public housing authorities will be working on their plans as soon as Fall 1999.
Public housing authorities must hold a public hearing on the plans before they are submitted to HUD for approval. Forty-five days before the public hearing, the public housing authority must make the plan available to the public for review. This gives you and your allies time to review the plans and to prepare comments about the plans. You can prepare written comments to submit to the housing authority at the public hearing, and/or you can read your comments out loud at the public hearing. Your comments should tell the public housing authority about the housing needs of domestic violence victims. When your public housing authority submits its plan to HUD, it must tell HUD about the public comments it received and whether it made any changes to its plan as a result of those comments.
It is up to you to make the voices of battered women heard by public housing authorities while they are designing their plans. It is these plans that will ultimately affect whether battered women get access to subsidized housing.
(This is merely a sample letter, with suggested wording and content for your assistance. Remember to put this letter into your own words, and print it out on your organization's letterhead.)
Date
Regulations Division
Office of General Counsel
Room 10276
Department of Housing and Urban Development
451 Seventh Street, SW
Washington, DC 20410-0500
Re: Docket No. FR-4485-P-01; Changes to Admission and Occupancy Requirements in the Public Housing and Section 8 Housing Assistance Programs [Comments due at HUD by June 29, 1999.]
Or
RE: Docket No. FR-4428-I-01; Section 8 Tenant-Based Assistance; Statutory Merger of Section 8 Certificate and Voucher Programs [Comments due at HUD by July 13, 1999.]
Dear Regulations Division/Rules Docket Clerk,
I am writing on behalf of victims of domestic violence to support the portions of these proposed regulations that direct public housing authorities to consider adopting admissions preferences for victims of domestic violence. [Explain who your organization serves--the geographic region, number of clients, and the types of services your organization provides. State whether you are a state wide coalition against domestic violence, a domestic violence shelter program, or provider of other needed services to victims of domestic violence.]
Although each victim's circumstances, including risks and resources, are unique, many victims of domestic violence desperately need the benefits of federal housing programs. For some victims, the financial assistance provided by a federal housing program is the resource needed to be able to leave an abuser. Federal housing assistance may free a victim from having to move frequently due to the inability to pay market rent and poor housing conditions. Such housing stability may enable a victim to pursue job training and employment, which could ultimately increase her economic self-sufficiency and resources.
In our work, we see many victims of domestic violence who are in desperate need of federal housing programs. [Give examples of clients (without any information that could disclose their identity) who had a great need for a federal housing program. You could include examples of victims who experienced violence over a prolonged period of time while waiting to get into a housing program, or victims whose abuser sabotaged the victim's efforts to be employed while living in the same household. You could also include stories of victims who have benefited from getting into a federal housing program.]
In addition to victims of domestic violence, there are other groups of people who are in equally desperate need of housing. In light of the great demand and need for quality affordable housing, HUD should require, through regulation, that all admission preferences used by public housing authorities be based solely on the need for housing.
We applaud HUD's efforts to begin to acknowledge and address the needs of victims of domestic violence.
Very truly yours,
Name
Title
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