Caribbean L 26 ife, July 12–18, 2019
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HUD Immigrant Family rule
subsidy under the present regulatory
structure received by so-called
“mixed” families — those comprised
of eligible and ineligible members —
amounts to $1,900 per person per year.
This number appears to have been
calculated by taking the total amount
of housing assistance payments issued
and dividing by the total number of
persons in the receiving households —
eligible and ineligible alike. However,
per existing HUD regulation, and as
demonstrated in the Department’s own
analysis, HUD prorates the amount of
assistance received by these households
and only disburses monies based on the
number of eligible recipients.
Yet, the Department’s analysis
argues that by terminating benefits
to households with ineligible
members, this $1,900 yearly benefit
will be redirected to families where
all members are eligible to receive
benefits, in a total amount of $60
million annually. This literally
does not add up. HUD already does
not distribute benefits to ineligible
persons — the assistance disbursed
would be the same whether or not
the ineligible household member or
members were present. To terminate
benefits to “mixed” households
in favor of households made of
all eligible persons would result
in no monies saved, but monies
shuffled around from other eligible
recipients.
Indeed, not only would the rule as
proposed not save money, it would
result in substantial additional
costs, specifically to New York City.
Following the consent decree that
settled Callahan v. Casey in 1981,
New York City has recognized that
a legal right to shelter is mandated
by Article XVII of the New York
State Constitution, requiring the
provision of shelter to homeless
individuals. The text of HUD’s own
summary and economic analysis
acknowledges that the rule would
exacerbate homelessness.
This proposed rule would impact
approximately 2,800 households in
New York City alone, encompassing
11,400 persons, nearly half of them
children. When the Department’s
own financial analysis considers
costs associated with homelessness
range from $20,000 to $50,000 per
person, this rule would impose
new costs on New York City of
$228 million at minimum and
possibly as much as $570 million.
These are the projected costs for
displacement of 2,800 households
in one city, albeit the largest one;
HUD analysis indicates this rule
could impact up to 25,000 families
nationwide.
I would return to something
I raised at the beginning of this
comment. The authorizing statute
creating the Department of Housing
and Urban Development explicitly
states that the Department should
operate with consideration of the
needs and interests of the nation’s
communities and the people in
them. How this proposed rule could
possibly operate in harmony with
that principle escapes even the most
forgiving imagination.
At no point in the Department’s
own analysis does it clarify why it
is in the interests of the nation’s
communities to adopt a rule that
would promote homelessness. At
no point in the Department’s own
analysis does it clarify why it is in the
interests of the nation’s communities
to adopt a rule that incentivizes
families to splinter and separate in
order to keep a roof over some of their
heads, or to choose homelessness as
a consequence of staying together.
In fact, the Department openly
acknowledges the harm of these
choices in presenting them as valid
options:
“Although the option of paying
the full rent is possible, it may
not be affordable. ... Temporary
homelessness could arise for a
household, if they are unable to find
alternative housing, for example
in tight housing markets. Another
compliance option, but a ruthless
one, would be for the household
to remain and continue to receive
assistance but to ask the ineligible
member(s) to leave. ...a potential
impact of this outcome would be
homelessness of the unsupported
family member.” (emphasis added)
In October of 2018, Adam Serwer
of “The Atlantic” published the
essay “The Cruelty Is the Point.”
The central argument of the essay
is that the policies of the Trump
Administration are not motivated
by principles of administrations
past, of budget hawks or the virtues
of limited government; rather, that
there is a segment of society who feel
entitled to the beneficial treatment
and resources of America and the
more a person identifies with a
group scorned by that segment —
immigrants, people of more color,
women, LGBTQ+, or any who would
dissent from this presumptive
ruling class — the more that person
deserves to be cast aside, deserves
to be left in the street, deserves
cruelty. After nearly a year since
that essay and three years into
the Trump Administration, policies
and proposals such as this have
done nothing to rebut Serwer’s
argument.
I reiterate my strong opposition
and objection to this proposed rule,
and urge its withdrawal in favor of a
housing policy that actually serves
and benefits the people of New York
City and America.
Sincerely,
Jumaane D. Williams
Public Advocate for the City of
New York
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