MASSACHUSETTS UNION Comments on amendments to proposed state public regulations

Just last week,Jack Cooper, Exutive Director of MUPHT, in an email to Ian Meyer, Dept. of Housing and Community Development respectfully submited these comments to the Massachusetts Department of Housing and Community Development (DHCD) in response to proposed changes to regulations that impact public housing residents.

Our comments are on DHCD’s proposed amendments to Sections 4.00, 6.00, 11.00, and 63.00 of 760 CMR. MUPHT Board members met over the course of three days with Massachusetts Law Reform Institute to review the proposed regulations and discuss their affect public housing residents and public housing. Mass Union also reviewed comments that MLRI with Greater Boston Legal Services submitted on these proposed regulations (referred to as MLRI Comment). See attached. We support all of their comments with the certain emphasis, additions or exceptions. (Mass Union tracks our comments to MLRI Comment numbers.)

1. MLRI Comment 1 - LHA Website
In addition to requiring LHAs to post the documents listed in Comment 1, Mass Union urges DHCD to require LHAs post the rent hardship form online. While many residents do not have computers, more and more do, some Local Tenant Organizations have computers, and community organizations that help residents generally have computers. The website is a very efficient way to get out information to a community and in the long-run save staff time tracking down documents. Many LHAs have excellent websites and many still need to evolve.

2. MLRI Comment 9 - Annual Plan List of Waivers
We agree with Comment 9 that DHCD should require that LHAs list all waivers in the LHAs Annual Plan that DHCD has approved. This will make more transparent what waivers a LHA is operating under. In addition, Mass Union feels that waivers should not be forever. The Annual Plan offers an important opportunity to review waivers and Mass Union urges that regulations require that waivers be reviewed annually during the Annual Planning process. 760 CMR 4.17(b)
3. MLRI Comment 12 - Resident Participation Before Release of Annual Plan We agree with Comment 12. Just as DHCD asked for our feedback and feedback from housing authorities before releasing these regulations, we feel that the best time for housing authorities to get input from residents and community advocates on the annual plan is before the release of the draft annual plan. Mass Union urges that DHCD require that housing authorities meet with Resident Advisory Boards (RAB), residents, and advocates during the development of a plan at least twice before it is put out for comment. In the long run this will be more efficient and our participation can be more meaningful. ...

To read the entire 5-page document you can either click here... ,view the pdf version..., or to view MUPHT and otherorganizations' 2016 comments on proposed state public housing regulations click:
http://www.masslegalservices.org/content/comments-proposed-state-public-housing-regulations. Feel free to copy this link and share with others.