Lower rents to HCV landlords through demonstrating non-compliance with "rent reasonableness"

The first approach to reform responds to the documented observation that market rents in Woodlawn are, on average, lower than the rent received by Housing Choice Voucher landlords. The over-payment of subsidy creates an advantage for accepting vouchers in low-rent neighborhoods like Woodlawn over other neighborhoods. By reducing the rent that a landlord would receive, it would also reduce the profits of landlords providing lower-quality management in Woodlawn and assist more households. As discussed in Chapter 5, HUD has a requirement of Òrent reasonablenessÓ that is intended to prevent a landlord from charging a Housing Choice Voucher recipient more than they charge for un-assisted units in the same building (assuming they have unassisted units) and what identical unassisted units would receive on average in the market place.

Because of anecdotal evidence that tenant and CHA payments are more for units located in the same building, statistical evidence that assistance payments are higher than the market rate and the presence of clear regulations that forbid this, the natural solution would be better enforcement. This could include conducting a detailed study/inventory of current apartments rented by HCV residents along with non-assisted apartments that would provide clear evidence of unreasonable rents. It could be argued that this approach reduces the rent that ÒgoodÓ landlords receive in Woodlawn, which would have a depressing effect on housing options. However, these landlords provide a better service and have a credible case for charging more to Housing Choice Voucher recipients. Indeed, helping the market to better distinguish landlords on the basis of management quality would certainly be a positive side effect.

Support public safety efforts, including landlords of two- to four-unit buildings

One recommendation, not specific to two- to four-unit buildings, involves continuing broad-based neighborhood efforts around improving public safety. These include the use of Interrupters to prevent escalation of interpersonal conflict into violence, prayer vigils to encourage neighborhood healing and discourage retaliatory violence, and training landlords about their role in preventing crime with the support of law enforcement. Improvements in public safety are critically important for improving the neighborhoodÕs perception issues.

Merge East and West Woodlawn TIF districts

In order to align the financing mechanisms with community interests in connecting the areas west and east of Cottage Grove, the two Tax Increment Districts should be merged into one. Continued (or past) gentrification of East Woodlawn would generate a source of funds for both financing affordable housing in the stronger eastern part and also for stabilizing investments West of Cottage Grove.

Promote 3-1-1 for requesting public services

The first recommendation involves continuing education for residents on ChicagoÕs existing 3-1-1 infrastructures teaching how to make a host of non-emergency requests, namely filing a police report after a crime has occurred and the offender has gone, i.e. property theft, noise disturbances, and property/automobile damage (Chicago CAPS, 2013).

Institute rental licensing for two- to four-unit buildings

Another means for improving the entire rental market, including two- to four-unit buildings, is the adoption of a rental-licensing program. The program would require annual inspection and payment of $40-$140 per rental unit per year. It would convert the complaint-driven process typical of code enforcement to a compliance-driven process that has wider coverage.

Pressure public agencies to improve culture of customer service

The final part of improving public services concerns itself with cultural and behavioral concerns, which are generally beyond the scope of service requests and analyzing standard performance metrics. These concerns are often best highlighted by anecdotes that highlight cultural practices that need to be changed and other examples of the ideal behavior (Behn, 2006). As such, identifying formal and informal channels for documenting Òcustomer serviceÓ-oriented complaints and bringing them to the attention of decision makers capable of taking action (either disciplining employees or pursuing other efforts of redress) are extremely important. Each documented issue creates more momentum for change. Neighborhood actors who were more willing to pursue these alternative avenues were more successful in making their concerns held.

Informal and Formal Channels for ÒCustomer ServiceÓ Complaints (Table)

Institute "one unit for market" requirement

The third approach to effecting change in the Housing Choice Voucher program disallows the business strategy of targeting voucher holders through administrative rules. It targets only the landlord that exclusively leases to voucher holder and by forcing the landlord to market at least one unit in a building to a non-subsidized tenant (or sustain the vacancy), it would reduce the profits associated with the business strategy. The rule could be added to the Housing Quality Standards enforced at the time of application through inclusion in the Request for Tenancy Approval form that each landlord must complete before a HCV contract is created (CHA, 2013d). The addition of a question about the number of units in a building would allow a queries of data to show the number of active housing assistance payment contracts at a particular address alongside the number of inhabitable units. Verifying the housing units in a two- to four-unit property could be an easily added inspection item.

The requirement could be narrowly tailored to address the particular problem-causing landlords. Landlords who develop and implement a supportive services plan could receive a waiver, releasing them from the marketing requirement since they should have already developed such a plan to qualify for CHA project-based housing vouchers. A unit that is owner-occupied would satisfy the one-unit minimum, further limiting the policy to investor-owned two- to four-unit buildings. Still, the policy would likely require changes in federal rules and regulations for the Housing Choice Voucher.

Woo NHS of Chicago to establish a greater presence

This recommendation also calls for the invitation and support of Neighborhood Housing Services of Chicago to develop a field presence in Woodlawn. As was discussed in Chapter 5, much of the missing home-ownership infrastructure stems from the fact that (in the void created by Shore BankÕs demise) NHS only has a field presence in a subset of Chicago neighborhoods that does not include Woodlawn. Whether it is home-ownership counseling, marketing of home purchase and acquisition & rehabilitation loans, technical assistance for home renovation or housing preservation, NHS has a successful track record of providing these services for two- to four-unit buildings in other neighborhoods. The Small Building Initiative could enter a partnership with NHS whereby a NHS employee is subsidized by the Small Building Fund and spends 50% of their time working out of Woodlawn in space provided by POAH and eventually the Woodlawn Resource Center.

Monitor and support Sub-Area FMR Demonstration

The second approach revolves around the Small Area Fair Market Rent demonstration discussed in Chapter 4. If adopted, this program would reduce the maximum rent any landlord could charge a Housing Choice Voucher recipient in Woodlawn. It would also increase the rent a landlord could charge in a higher-rent area within the region, creating more rental opportunities for assisted households. If successful, this program would work towards the same objective as the first approach, Unlike the first approach, however, it would not as effectively allow apartment and management quality to be a source of differences in rent, since the maximum rent will be reduced for all landlords regardless of quality. Less discretion would give way to a more uniform approach to reducing the incentives for targeting voucher holders.

Shift dominant strategy from demolition/new construction to rehabilitation

The last recommendation calls for a clear shift in the redevelopment strategy of demolition and new construction (embodied by the both of the Columbia Point phases) to renovating vacant buildings. With the removal of tax delinquencies and municipal liens, not only would it be environmentally more sustainable to renovate, but it would also be less expensive and keep housing costs lower and minimize displacement through the continued provision of modest housing.