GALVESTON HOUSING AUTHORITY

Report
CITY OF GALVESTON
A Bold New Approach For Subsidized
Housing
By
The Galveston Open Government Project
Movement of the Population & Economic Center of Galveston County 1940 to 2008
(Map from Texas Windstorm, Risk Designation Areas for Galveston County)
Texas City Housing Authority
Galveston Housing Authority
La Marque Housing Authority
Migration path of economic/demographic center of county from
1940 to 2008.
Demographic Facts Since GHA Founding in 1940
1940 City Of Galveston % of County Population – 75%
2008 City Of Galveston % of County Population – 19.8%
1940 Economic/Population Center of County – City of Galveston
2008 Economic/Population Center of County – Dickinson Area
All 3 of Galveston County’s Housing Authorities are in the far south of the county: Galveston, Texas City, La Marque
HUD Has Not Kept Up With the Economic & Population Shift!!
Result – Subsidized Housing Roll-Up
Housing Authorities
Sorted by Population
Galveston County
League City city (pt.)
Galveston city
Texas City city (pt.)
Friendswood city (pt.)
Dickinson city
La Marque city
Santa Fe city
Houston HUD
2008 Census % of County Public
Public
Estimate
Population
Housing
Section 8 Housing
288,239
100.0%
1100
1996
70,471
24.4%
57,086
19.8%
970
1516
44,488
15.4%
130
422
25,025
8.7%
17,886
6.2%
14,236
4.9%
0
58
10,479
3.6%
0
0
TDHCA
Public
Section 8 Housing
192
Total
Public
Section 8 Housing Section 8
1100
1996
0
0
970
1708
130
422
0
0
0
0
0
58
0
0
*Census Data from U.S. Census Website www.census.gov/popest/cities
*Public Housing and Section 8 Data from Housing Authority Profiles HUD website.
*Section 8 – Funded vouchers, 697 on island, 516 on the mainland.
*PH numbers from HUD HA profiles, GHA redevelopment plan said pre-Ike number was 979 https://pic.hud.gov/pic/haprofiles/haprofiledetails.asp
*TDHCA operates Section 8 vouchers in county. They have not responded to our inquiries
on numbers or distribution of vouchers.
HUD Has Not Kept Up With the Economic & Population Shift!!
Result – Concentration of Subsidized Housing
Total
Sorted by Population
Galveston County
League City city (pt.)
Galveston city
Texas City city (pt.)
Friendswood city (pt.)
Dickinson city
La Marque city
Santa Fe city
% of
Public
2008 Census % of County Public
County
% of
Housing Section 8
Estimate
Population
Housing Section 8
PH
Section 8 Burden
Burden
288,239
100.0%
1100
1996
70,471
24.4%
0
0
0.0%
0.0%
0.0
0.0
57,086
19.8%
970
1708
88.2%
85.6%
4.5
4.3
44,488
15.4%
130
422
11.8%
21.1%
0.8
1.4
25,025
8.7%
0
0
0.0%
0.0%
0.0
0.0
17,886
6.2%
0
0
0.0%
0.0%
0.0
0.0
14,236
4.9%
0
58
0.0%
2.9%
0.0
0.6
10,479
3.6%
0
0
0.0%
0.0%
0.0
0.0
*Census Data from U.S. Census Website www.census.gov/popest/cities
*Public Housing and Section 8 Data from Housing Authority Profiles HUD website. https://pic.hud.gov/pic/haprofiles/haprofiledetails.asp
*Section 8 – Funded vouchers, 697 on island, 516 on the mainland.
*PH numbers from HUD HA profiles, GHA redevelopment plan said pre-Ike number was 979
HUD Has Not Kept Up With the Economic & Population Shift!!
Result – Concentration of Minority Population
Sorted by % Minority
Population
Galveston County
La Marque city
Galveston city
Texas City city (pt.)
Dickinson city
League City city (pt.)
Friendswood city (pt.)
Santa Fe city
2008 Census % of County
Estimate
Population
288,239
100.0%
14,236
4.9%
57,086
19.8%
44,488
15.4%
17,886
6.2%
70,471
24.4%
25,025
8.7%
10,479
3.6%
2008
Minority
Population
(Census
Minority %
X Census
Population)
55,676
6,549
24,147
17,484
5,741
11,275
2,477
671
2008
Census
Estimate
Minority %
of
Population
19.3%
46.0%
42.3%
39.3%
32.1%
16.0%
9.9%
6.4%
County Minority Population within Housing Authority Cities
48,180
County Minority Population
55,676
% Of County Minority Population located in Cities with Housing Authorities
86.5%
% of Public Housing Units located in Cities with Housing Authorities
100%
*Census Data from 2008 Estimate U.S. Census Website www.census.gov/popest/cities
HUD Has Not Kept Up With the Economic & Population Shift!!
Result – School Districts of the 3 HA Cities Have The Highest Concentration of African-American Students
Student
Population
African
Americ
an
%
African
Americ
an
HA
%
White
La Marque
3625
2527
69.7%
Yes
10.8%
Galveston ISD
Galveston
7903
2395
30.3%
Yes
23.9%
Texas City ISD
Texas City
5899
1150
19.5%
Yes
41.8%
Dickinson ISD
Dickinson
8228
1251
15.2%
No
39.8%
Clear Creek ISD
League City
36314
3232
8.9%
No
61.1%
Friendswood ISD
Friendswood
5865
129
2.2%
No
82.5%
Santa Fe ISD
Santa Fe
4517
32
0.7%
No
85.8%
School Districts by
% African American
Students
City
La Marque ISD
* All school data from ISD websites.
HUD Has Not Kept Up With the Economic & Population Shift!!
Result – School Districts of the 3 HA Cities Have The Highest Concentration of African-American Students
HUD Has Not Kept Up With the Economic & Population Shift!!
Results – The 3 HA Cities Have the Lowest Income per Capita in the County
N to S
2008
Inc.
(1999
$'s)
1940
1950
1960
1970
1980
1990
2000
2008
81,173
113,066
140,364
169,812
195,940
217,399
250,158
288,239
Friendswood
0
0
0
5,675
10,719
22,814
29,037
25,025
28,615
League City
0
1,341
2,622
10,818
16,578
30,159
45,444
70,471
27,170
Dickinson
0
2,704
4,715
10,776
7,505
11,692
17,093
17,886
19,785
La Marque
0
7,359
13,969
16,131
15,372
14,120
13,682
14,236
17,518
Santa Fe
0
0
0
0
5,413
8,429
9,548
10,479
20,396
Texas City
5,748
16,620
32,065
38,908
41,403
40,822
41,521
44,488
17,057
Galveston
60862
66568
67175
61809
61902
59067
57247
57,086
18,275
Galveston
County
* The solid line represents the northern migration of the population center of the county.
*Census Data from U.S. Census Website www.census.gov/popest/cities
HUD Has Not Kept Up With the Economic & Population Shift!!
Results – The 3 HA Cities Have the Lowest Income per Capita in the County
The Proposal
We propose that the county’s three housing authorities merge, and
immediately petition the County Government for recognition as the
“Galveston County Housing Authority”.
The overriding principle should be that subsidized housing should be deconcentrated out of the City of Galveston. Housing, educational and
employment opportunities need to be addressed from a regional
perspective. HUD through it’s local Public Housing Authority, the Galveston
Housing Authority (GHA), has a statutory obligation to affirmatively further
fair housing by ensuring that the GHA’s plan has a regional perspective, and
furthermore, that GHA’s regional plan is in alignment with the regional plans
of Houston HUD and surrounding Housing Authorities.
Legal Basis – Thompson v. HUD, U.S. District Court for the District of Maryland, MJG-95-309
Academic Basis – Geography of Opportunity, Communities of Opportunity (Suggested links on last
slide)
The Proposal
Thompson v. HUD – Summary from NAACP Legal Defense Fund Website
“The ACLU of Maryland filed the lawsuit in 1995 on behalf of a class of approximately 14,000
African American tenants, former tenants, and prospective tenants of Baltimore City public
housing developments. Plaintiffs alleged that HUD denied Baltimore's African American public
housing residents opportunities to locate throughout the region and instead concentrated them in
predominantly minority areas within the city limits in violation of the Fair Housing Act.
In January 2005, the District Court found HUD liable for failing to take affirmative steps to
implement an effective regional strategy for desegregation and poverty de-concentration in
Baltimore. The court found that HUD's programs "failed to achieve significant desegregation in
Baltimore City." As Judge Marvin J. Garbis explained, "Baltimore City should not be viewed as
an island reservation for use as a container for all of the poor of a contiguous region."
The Proposal
Thompson v. HUD – Decision Memorandum
“In light of HUD’s statutory duties and the fact that its jurisdiction and ability to exert practical
leverage extend throughout the Baltimore Region, it was, and continues to be unreasonable for the
agency not to consider housing programs that include the placement of a more than insubstantial
portion of the Plaintiff class in non-impacted areas outside of Baltimore City limits.”
“In sum, the Court finds that HUD failed to consider regionally-oriented desegregation and
integration policies, despite the fact that Baltimore is contiguous to, and linked by public
transportation and roads to, Baltimore and Anne Arundel Counties and in close proximity to other
counties in the Baltimore Region.”
“It is high time that HUD live up to its statutory mandate to consider the effect of its policies on the
racial and socio-economic composition of the surrounding area and thus consider regional
approaches to promoting fair housing opportunities…”
The Proposal
Thompson v. HUD – The Map that Got the Baltimore Housing Authority in Trouble
Maryland 1990 Census – 24.9% African-American Population
The Proposal
Galveston County’s Map
Galveston County 2000 Census – 25.5% African-American Population
The Proposal
Benefits to the Stakeholders
Subsidized Housing Residents
Choice of location that matches up with current job skills.
Choice of location for educational opportunities for new skills.
Choice of location for parents to choose schools.
Choice of location based on risk tolerance of storm damage.
Opportunity for residents to tie in to the employment and
educational opportunities of Houston via the Houston Metro Park &
Ride located right across the county line in Webster.
The Proposal
Benefits to the Stakeholders
Housing Authorities
Combined operation would be more cost efficient.
Larger HA would carry greater weight with HUD.
Site selection opportunities would increase exponentially.
Maximize client’s opportunities to graduate out of system.
Would have the expanded resources of a region to
address housing issues, and the issues of the clients.
The Proposal
Benefits to the Stakeholders
Current HA Cities
Reduced total number of Public Housing units would increase the
amount of property on City tax rolls.
City residents and business would no longer have to make up lost taxes
due to exempt properties.
Restored tax equity would put these cities on better footing for
rebuilding viable middle class populations.
Socio-economic burdens would be carried by all County residents
equitably.
Planning Department Checkpoints
Any plan submitted to this committee should pass three checkpoints before a recommendation for
approval is given to city council.
Check Point 1 – Agree on the number of units. (Thompson v. HUD, de-concentration)
The number of proposed subsidized housing units (public housing + Section 8), as a percentage of households
within the City of Galveston, shall not exceed the percentage of subsidized housing units within Galveston County.
Check Point 2 – Agree on the location of units.
Check Point 3 – Agreement on the type and mix of units in the agreed locations.
Verification
*U.S. Census Bureau Population Estimate data.
*Texas Department of Housing and Community Affairs (State agency responsible for disbursing subsidized housing
funds, and tracking the number of units.)
Summary
•
The Housing Authorities of Galveston, Texas City, and La Marque should merge and become
the “Galveston County Housing Authority”. A regional approach should be used.
•
The expansion of the service area for the new County Housing Authority would benefit all
stakeholders.
•
HUD/GHA has not lived up to it’s statutory responsibility to expand regionally, when the
demographic data shows that the current working model results in concentration of public
housing units and minorities within a contiguous area.
•
GHA’s current plan does not live up to the location criteria of the signed Consent Decree
•
The city has the guidance of judicial rulings upon which to base it’s decisions, and to minimize
the risk of law suits to the city or delay in redevelopment.
•
A checkpoint system, using the judicial rulings and verifiable government data, can be used to
responsibly move the proposed redevelopment plan through the system.
1)
Agree to the number of units.
2)
Agree to the locations.
3)
Agree to the type and mix.
Research
The concept of taking a regional approach to housing issues is not new, but renewed focus has
come out of the Thompson v. HUD decision.
The following links connect to further reading on the Regional approach in regards to housing
issues:
Future of Fair Housing – National Commission on Fair Housing and Equal Opportunity
Geography and Opportunity – Kirwan Institue for the Study of Race and Ethnicity (The Ohio State
University), Director John Powell – Expert Witness Thompson v. HUD
Inclusive Communities Project
ACLU-MD's Fair Housing Department releases a report entitled "New Homes, New
Neighborhoods, New Schools: A Progress Report on the Baltimore Housing Mobility Program"
NAACP Legal Defense Fund – Thompson v. HUD Information
Legal Issues
Thompson v. HUD – HUD obligated to address housing on a regional basis. Outline of
Opinion. Analysis.
The Inclusive Communities Project, Inc. v. Texas Department of Housing and Community
Affairs – Current complaint that the way the TDHCA administers the Low Income Housing
Tax Credit program perpetuates racial segregation. GHA’s proposal relies heavily on the
LIHTC program.
Texas Appleseed Administrative Complaint to HUD – CDBG funds to Texas put on hold
because of non-compliance with Federal Regulations. TAA’s complaint includes that subrecipient City of Galveston cannot certify that they are affirmatively furthering fair housing
because the required AI is inadequate (pg 22)
Residency of Public Housing Clients – The issue of where Galveston’s Public Housing
Clients originated is a non-issue. Federal Regulations and GHA’s “Admissions and
Continuing Occupation” policy have no residency requirements (pg 9). As a federal
program, anyone from anywhere is allowed to apply to any HUD Housing Authority in the
country.
Galveston County, and all of the county municipalities listed as sub-recipients of the
County CDBG, as a recipient of that CDBG, have an obligation to affirmatively further fair
housing. Legal basis – USA v. Westchester County, NY.
General Questions About Current GHA Proposal 1 of 3
HUD Regulations
4010.1 Definitions, Policy Statements and General Rules
Chapter 4 Policy Statements Concerning Avoidance of Surplus Housing
Conditions, Processing Priorities and Reviews
(?) Have you received, or asked for, a determination letter from the
local HUD office in regards to HUD-FHA obligations under sections
4-2, in regards to your proposed development plan? (4.2
Responsibility of Field Offices to Avoid Conditions of Surplus
Housing)
Chapter 7 Mandatory Flood Insurance Requirement in Special Flood Hazard Areas
(?) Do you have commitments for obtaining flood insurance? (7-1)
(?) Do you have a signed waiver, or opinion document, in regards to 7-9
(HPMC Flood Hazard Exposure Standards)? Specifically subsection c
which reads, “Properties should be rejected if they are subject to
frequently recurring flooding, or if there is any potential hazard to life or
safety, or if escape from them to high ground would be infeasible during
severe flooding.
General Questions About Current GHA Proposal 2 of 3
HUD Regulations
1390.2 Chapter 3 – Compliance Factors
Compliance Factor #3 Flood Plain Management
(?) Are in you in compliance with all of the requirements of CF3.2
Legislative and Regulatory Requirements, Use of Federal funds for
development in Floodplains parts a thru e?
Please provide a copy of the Initial Flood Hazard Screening, as required
by CF3.3?
General Questions About Current GHA Proposal 3 of 3
Current GHA plans do not seem to be compliant with this Federal Regulation. Please provide letter from HUD
certifying your plans comply with this Federal Regulation?
Title 24 – Housing and Urban Development
Part 941 – Public Housing Development
CFR 941.202 Site and Neighborhood Standards (Does the plan have approval from the field office that it is compliant with this section, as required by this section?)
Proposed sites for public housing projects to be newly constructed or rehabilitated must be approved by the field office as meeting the following standards:
(a) The site must be adequate in size, exposure and contour to accommodate the number and type of units proposed, and adequate utilities (e.g., water, sewer, gas and
electricity) and streets must be available to service the site.
(b) The site and neighborhood must be suitable from the standpoint of facilitating and furthering full compliance with the applicable provisions of Title VI of the Civil Rights
Act of 1964, Title VIII of the Civil Rights Act of 1968, E.O. 11063, and HUD regulations issued pursuant thereto.
(c)
(1)The site for new construction projects must not be located in:
(i) An area of minority concentration unless
(A) sufficient, comparable opportunities exist for housing for minority families, in the income range to be served by the proposed project, outside areas of minority
concentration, or
(B) the project is necessary to meet overriding housing needs which cannot otherwise feasibly be met in that housing market area. An ‘‘overriding need’’ may not serve as
the basis for determining that a site is acceptable if the only reason the need cannot otherwise feasibly be met is that discrimination on the basis of race, color,
religion, creed, sex, or national origin renders sites outside areas of minority concentration unavailable; or
(ii) A racially mixed area if the project will cause a significant increase in the proportion of minority to non-minority residents in the area.
(2) Notwithstanding any other provision of this paragraph (c), public housing units constructed after demolition of public housing units may be built on the
original public housing site, or in the same neighborhood, if one of the following criteria is satisfied:
The number of public housing units being constructed is no more than 50 percent of the number of units in the original project;
In the case of replacement of a currently occupied project, the number of public housing units being constructed is the minimum number needed to house current
residents who want to remain at the site; or
(iii) The public housing units being constructed constitute no more than twenty-five units.
(d) The site must promote greater choice of housing opportunities and avoid undue concentration of
assisted persons in areas containing a high proportion of low-income persons.
(e) The site must be free from adverse environmental conditions, natural or manmade, such as instability, flooding, septic tank back-ups, sewage hazards or mudslides;
harmful air pollution, smoke or dust; excessive noise vibration, vehicular traffic, rodent or vermin infestation; or fire hazards. The neighborhood must not be one
which is seriously detrimental to family life or in which substandard dwellings or other undesirable elements predominate, unless there is actively in
progress a concerted program to remedy the undesirable conditions.
(f) The site must comply with any applicable conditions in the local plan approved by HUD.
(g) The housing must be accessible to social, recreational, educational, commercial, and health facilities and services, and other municipal facilities and services that are at
least equivalent to those typically found in neighborhoods consisting largely of similar unassisted standard housing.
(h) Travel time and cost via public transportation or private automobile, from the neighborhood to places of employment providing a range of jobs for low-income workers,
must not be excessive. (While it is important that elderly housing not be totally isolated from employment opportunities, this requirement need not be adhered to
rigidly for such projects.)
(i) The project may not be built on a site that has occupants unless the relocation requirements referred to in § 941.207 are met.
(j) The project may not be built in an area that has been identified by HUD as having special flood hazards and in which the sale of flood insurance has been
made available under the National Flood Insurance Act of 1968, unless the project is covered by flood insurance as required by the Flood Disaster
Protection Act of 1973, and it meets any relevant HUD standards and local requirements.
[45 FR 60838, Sept. 12, 1980. Redesignated at 49 FR 6714, Feb. 23, 1984, as amended at 61 FR 38017, July 22, 1996]
CITY OF GALVESTON
A Bold New Approach For Subsidized
Housing
By
The Galveston Open Government Project
END

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