Neighborhood Stabilization Program Public Comment of the Affordable Housing Task Force Miami Dade County has Proposed to HUD a "Substantial Amendment"
on how it plans to use its NSP funds
The Affordable Housing Task Force is comprised of attorneys from Legal
Services of Greater Miami, Inc., Florida Legal Services, Inc., and
community organizers from the Miami Workers Center. This group is
committed to the cause of creating and preserving affordable rental
housing for extremely low, low, and moderate income individuals.
federal government's 2008 Neighborhood Stabilization Grant ("NSP") Fund
allocation to Miami Dade County (the "Grantee") is an opportunity to
protect tenants and stabilize communities affected by the mortgage
crisis. Often overlooked are communities comprised of residents
who make less than 50% of area median income ("AMI") and who live in
multi-family unsubsidized private rental complexes. These residents
have often been displaced, or forced to live in deplorable conditions
due to the foreclosure or abandonment of their rental complex. We
are currently working with tenants in several buildings which are
either owned by the lender (post foreclosure) or are in a state of
limbo with the lender refusing to finalize the sale and take possession
of the property. Our comments and observations are listed below.
Comments on the Proposed Substantial Amendment to the 2008 Action Plan
least 50% of the funds should be used to assist in the purchase and
rehabilitation of multifamily rental buildings, affordable to renters
making less than 50% of AMI. Although the County has allocated almost
45% of the total NSP Funds for the acquisition and rehabilitation of
foreclosed upon multi-family properties for use as affordable housing,
only 25% of this total amount is to benefit renters making less than
50% of AMI. Additionally, it is unclear why the County has
allocated the exact amount of $26,571,480.00 for the acquisition and
rehabilitation of foreclosed upon multi-family properties for use as
affordable housing, and how the County plans to use this money. A
more detailed explanation should be provided.
the County has decided to purchase and operate these properties, they
should provide tenants with the same rights as those living in public
housing, and the County should operate these properties by following
the Miami Dade Housing Agency's Admissions and Continued Occupancy
Policy ("ACOP"). The County should commit to rehabilitating
properties located in an area of greatest need, and in an area where
the rehabilitation efforts will have a positive widespread
impact. The funds are specifically provided for neighborhood
stabilization, not the stabilization of one building, or the
stabilization of random scattered sites.
County should make funds available to outside developers.
However, they should only consider those developers which are: 1)
familiar with the community in which they want to purchase and operate
a property; 2) non profit agencies committed to neighborhood
redevelopment and community participation; 3) experienced in operating
affordable rental complexes targeted to those making less than 50% of
AMI; 4) able to leverage additional funds and proceed in a expeditious
manner. The highest consideration should be given to tenant
groups and their chosen nonprofit partners who wish to purchase and
rehabilitate properties. We would also recommend that any
nonprofit/tenant partnerships, with an eventual goal of some form of
tenant ownership, or other model of tenant control be given highest
priority. Neighborhood stabilization can truly only be achieved
if the tenants are afforded an opportunity to participate in their
The Housing and Economic
Recovery Act encourages the use of NSP funds not only to stabilize
neighborhoods in the short-term, but to incorporate modern, green
building and energy efficiency improvements in all NSP
activities. Multi-family rental complexes can serve a larger
population and therefore can provide additional environmental benefits
for a community. The acquisition and rehabilitation of rental
structures in areas such as Liberty City is an excellent way of
achieving the goals of the Neighborhood Stabilization Grant.
Some portion of the funds should be set aside for mobile home park preservation.
have been working intensively with tenants in foreclosed buildings for
the past year. They are the unrecognized victims of this economic
meltdown. These funds not only provide an opportunity to
assist these families but it also provides an opportunity to acquire
and rehabilitate much needed housing in the poorest neighborhoods of
Areas of the County such as Liberty City have
deteriorated significantly over the past two years due to the
foreclosure of multi-family properties and ultimate displacement of its
Most of these residents wish to remain in their communities and continue to pay affordable rents.
Many multi-family rental complexes in these areas have been purchased by slumlords during the past several years.
Many of these complexes are now either in foreclosure or already have been foreclosed.
The complexes are often in terrible condition due to the inattention of the owner.
Consequently, these communities, lacking a safe and decent rental environment, have been destabilized.
Many residents that were homeowners are now unable to purchase another home due to poor credit.
need a safe, habitable, affordable environment in which to rent that is
close to their schools, work, and community centers.
Most residents of communities such as Liberty City make much less than 50% of AMI.
Most residents are unable to qualify for either Section 8 housing or a tax credit rental apartment.
their only choice has been small to mid sized multi-family rental
complexes, which are traditionally in poor condition, and are now even
more neglected due to the current foreclosure crisis.
Safe, habitable rental housing can serve as an anchor in a community.
factors such as loss of rental units to conversions, rising costs,
aging rental stock, and the foreclosure crisis, using NSP funds to
provide safe and habitable multi-family rental housing is an
appropriate response considering our current market needs in Miami-Dade
The acquisition of multi-family rental
properties at an extremely low cost is an integral part of stabilizing
and rehabilitating the current rental stock in communities most
affected by the foreclosure crisis.
The work of the Affordable
Housing Task Force is funded through a grant from the Florida Bar
Foundation. Our mission is the preservation and creation of
affordable multi-family rental developments for extremely low, low, and
moderate income individuals. Our task force consists of public
interest housing and community development attorneys and community
organizers that are working on a daily basis in our communities, which
the County has identified as areas most affected by the foreclosure
crisis. Throughout the past year, we have noticed a substantial
increase in the loss of affordable rental housing due to
foreclosures. We hope that you will take our comments and
observations into consideration. We are here to assist our local
governmental entities with this new challenge of creating and
implementing policies and procedures in utilizing the NSP funds to
increase access to affordable housing. Thank you for your time