Public comments for: Proposed Amendments to Rules Governing City-Aided Limited-Profit Housing Companies

Comments

Comment:
I desperately request that our voices be heard in this plight against this proposal. How can you reduce 365 days to only 30 days. How will your minority survive in this already suffering economy? many of us are already facing economic straints and to allow this amendment that's proposed is so unjust. I sincerely hope and pray that this will not be granted as our minority community are the ones who stand to suffer while the management benefits.
Supporting Document:
Agency: HPD
Comment:
As a tenant residing in a Mitchell Lama development (Atlantic Plaza Towers), I write to add my voice to those who ask that the proposed amendment to the rules governing city-aided limited profit housing companies re: Article XI not be approved. The proposal should not go through because a 30-day notice of any changes would create a hardship to many tenants who rely on the rules that are currently in place to keep us in our homes in a city where affordable housing is becoming more difficult to find. In a city with the cost of living rising prices are making it more difficult for middle income families to survive, if the current rule stands (365 day notice), it would allow the tenants to make any necessary adjustments to lives and not put them in jeopardy of becoming homeless. Many of the tenants in Mitchell Lama developments are on fixed incomes and cannot readily adjust to a rule change that would make it essentially impossible for them to face rising rent increases as early as January 2014. Even those currently working cannot afford a drastic change in rent. These rules have been put in place to ensure that the middle income population would be able to afford a safe living environment and this rule should not be amended to threaten that outcome.
Agency: HPD
Comment:
I oppose all of the proposed changes in Article XI. One in particular is in Section 9 paragraph (2) where the intention is to change the owner’s notification of intent to dissolve from 365 days to 30 days. It is clear this change benefits the owners only. It is to my understanding that HPD’s role in this city is to preserve the city’s stock of affordable housing. Mitchell Lama buildings are Limited Profit Housing Companies/Corporations, which entitles owners to earn a profit while providing affordable housing for the many residents that occupy their buildings. HPD and our government should be standing behind the thousands of families that live in these developments and working to keep them in place. Most of the people that live in Mitchell Lama Housing work hard to keep this city functioning. Police officer’s, EMT, transit employees, nurses, school teachers, white and blue workers or retirees from such lines of work that have dedicated their best years to keeping this city running. Like the owners of these developments we want the best education, opportunities and futures for our children and work hard to provide a safe, comfortable quality of life for our families. Salaries are not increasing in the city at the same rate as the RGB rent stabilization rates or the rate that the cost of food and living expenses in general are rising. Unlike the owners with millions of dollars to invest in these huge developments many of us can’t afford private schooling for our children or extensive family vacations and find it difficult to even save enough to invest in our own small piece of real estate. Converting Mitchell Lama to Rent Stabilization leaves residents open to the possibility of being forced into homelessness or depending on other government programs to subsidize their rent in 10-20 years as their rents increase. The city already has an abundance of these situations (families in shelters, on Section 8, etc.) and there is yet to be a solution that works to truly help the people in these types of situations get out of it. Why rush the increase of profits for an individual owner or small group of owner’s that have millions of dollars to invest for the sake of millions of people working in NYC that, through their tax dollars, will then be forced to pay for programs that more New Yorkers will have to depend on as affordable housing stock is continuously reduced. The city isn’t creating any more Mitchell Lama Housing so what is in place should be preserved for those that can truly use it. There is plenty of housing stock in NYC that offer rents at market or above market where investors can also or otherwise invest in to see their profits rise with no limits. I ask HPD and all Government officials that take the time to read these comments, to preserve Mitchell Lama Housing and consider the state of New York City’s economy and safety in the next 10-20years if you make these changes today.
Agency: HPD
Comment:
Please don't change the 365 day rule of notification to 30 days. Have you thought about the impact this change could have? "The total number of homeless people in municipal shelters is 52,351." (www.coalitionforthehomeless.com) It would be great if rent could stay the same but in this ever increasing society and pay staying the same I know that would be impossible so having 365 days would give tenants living in a Mitchell Lama program more of a fighting chance to get educated and prepare personally than changing the rule to 30 days.
Agency: HPD
Comment:
I opposed section 9 paragraph 2 and section 5, subdivision (p) of the Mitchell Lama Rules and Regulation changes of 365 days submission/application deadline for owners to 30 days. Due to the fact, It is not sufficient time to inform the tenants of any changes. It simply not fair and too drastic of a change. It does not give ample time to educted the tenants of the difference encounter in the program. Plus the tenants as whole will not have enough time to make any personal adjustments. It may incrreae the homelessness in the five boroughs. It will give a complete advantage to the owners and very little to the tenant as whole. It is bare smack in the face of the tenants who always pay their rent on time, due to the economic time. Reminder Most tenant, especially cityworkers and private industrial have not had any pay raises since our previous Mayor in office. Plus the overall business world have been layoff and composite with decrease in their normal salary. This Mitchella-Lamma Rule and Regulation change is like the coming of the hurrican Sandy to New York.
Agency: HPD
Comment:
Adding to my previous comment, when a tenant of record no longer lives in an apartment, remaining tenants should not automatically be forced to leave their homes and "downsize" to smaller apartments - HPD should maintain discretion in these situations. Under the new rules, a proposed successor would be REQUIRED to downsize if they no longer meet occupancy standards. However, HPD would now be allowed to waive those same occupancy standards "in order to fill vacancies." So, in other words, as a surviving tenant I would be "required" to move from my home, but then HPD can "bend the rules" for someone else to be placed IN THAT VERY SAME APARTMENT (offering my home to someone else who ALSO doesn't meet the occupancy standards)...This is unconscionable to say the least. Instead of creating new rules that remove tenants from their homes for the sake of shortening a list, HPD should instead address some of the more problematic results of "downsizing." There have been many instances where tenants have been coerced into downsizing so that owners could "cherry-pick" new occupants for those apartments, serving their own interests (this happens all too often, and it amazes me that this practice goes unnoticed or perhaps is ignored). Furthermore, by giving HPD the broad authority to "waive occupancy standards to fill vacancies" only makes it easier for building owners to do this, with HPD's "blessing." Placing new and unfounded restrictions on tenants who can easily be misled by building owners with ulterior motives undermines the purpose of the Mitchell-Lama program. The proposed rules will obscure reasonable and concise guidelines that are already in place, while granting vague and broad authority to HPD and building owners/managers. I respectfully urge HPD to seriously consider the real impact of these proposed rules. Again, thank you for your consideration.
Agency: HPD
Comment:
I think HPD should not change the 365 day app. rule deadline for owners to 30 days because there is not enough time for the information to be given to tenants and educate us about what is about to take place. This is not fair to tenants because late information equals no action in a timely fashion. There are many tenants who have lived in Atlantic Plaza Towers for more than 20 years, some not retired, some on disability, and this would leave these people without anywhere to go if rents are going up yearly. This program was put into place to render affordable housing, now with the proposed rule changing, and the owners trying to rush us out of the present agreement, that leaves many with no where to go. Please do not allow this to happen, there is too much homelessness in NYC as is. As a 37 year employee of the New York City Police Dept. and Atlantic Towers Plaza has been my home since 1997, I thank God for affordable housing, please help keep my home affordable. Respectfully yours, Janice Lyons
Agency: HPD
Comment:
I oppose section 9 paragragh 2 the change of the 365 day submission/application deadline; for owners to 30 days. This does not allow sufficent time; to inform the tenants of the changes/differences in the progam. The voices of the tenants need to be heard; 30 days only allows the landlord to be heard or benefit
Agency: HPD
Comment:
I disagree with what is going to happen if this propose is put in to order why because I am a stay at home mother of 4 girls and my legal blind husband who is our way of income and he doesn't have riches to be able to pay a high rent or work with all these changes trying to come our way. We live in low incoming housing and it is hard already with the rent being high why would we want to have any changes made to the Mitchell-Lama Program. In the proposal there are many holes like increases the rent the way you want to with us and it is going to put the poorer people who live in this type of housing like myself and my family to wonder why and make it harder for us. The proposal sucks a lot I feel like you are just about money why do it to those who live on a fit income from month to month and trying to put us further in the poor house. I was looking at the proposal with open eyes and this is what a saw in it Eliminates succession rights for nephews, nieces, aunts and uncles, and will only authorize succession where the tenant/cooperator of record has either died or been relocated to a long term care facility. Applications for succession will not be considered unless the family member files an application within ninety days of the tenant/cooperator's death or relocation to a long term care facility. Any proposed successor other than a surviving spouse is required to move to the next available appropriately sized apartment. Under the proposed rule, only family members approved for succession would be allowed to become owners of shares in a mutual housing company development and signatories on the occupancy agreement. Occupancy rights of family members. The rights of family members of a tenant/cooperator who have requested to remain as the lawful tenant/cooperator are governed by policies and procedures set forth in this subdivision, except in those instances where this subdivision is preempted by the rules or regulations of other federal, state or city programs engaging in family activities by jointly attending family functions, holidays and celebrations, social and recreational activities, etc.; formalizing of legal obligations, intentions, and responsibilities Notice of Intent for Rental Companies. A rental housing company intending to dissolve and/or reconstitute pursuant to §35, shall submit to HPD no later than 365 days prior to the' anticipated date of dissolution and/or reconstitution, a notice of such intention ("Notice of Intent") which shall contain the following information and supporting documents: (i) Name and address of the housing development; Name and business address of the beneficial and legal owner(s) other than limited partners and stockholders; Name and address of proposed transferee, if property is being sold or transferred and the proposed date of any such transfer; A current rent roll reflecting rents last ordered by HPD and/or by HUD including surcharges, subsidy and other special charge data;
Agency: HPD
Comment:
I oppose the changes to Section 5, Subdivision (p) of the Mitchell-Lama Rules and Regulation, 365-day submission/application deadline for owners to 30 days; Due to the fact this in not enough time to communicate and inculcate to the tenants of what these changes means and how it would affect us. What happen to the tenants’ rights? This is not fair to the tenants in 249 Thomas S. Boyland Street.
Agency: HPD

Pages