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Better oversight and consulting on BPDA units

Hello Ms. Dillon,

My company represents over a dozen properties in the City of Boston that together have over 200 affordable BPDA units. We’ve worked closely with the BPDA and BFHC over the years on many lotteries, and I continue to work with BFHC on the new process and procedures they are implementing for lotteries going forward. I have many thoughts about the lottery process and the delays everyone is experiencing, and would be happy to discuss those at a later date, but that is not the reason I’m writing you today. I’m writing to discuss how there are likely thousands of over-income tenants in income-restricted units in Boston and how the City can do the equivalent of adding thousands of much need affordable units to the City’s housing supply without a single new unit being constructed.

It’s come to my attention from over the years working with the BPDA program that there is hardly any oversight of the ongoing eligibility of tenants in income-restricted units. I’ve talked to Mary Mendonca at the BPDA about this and I believe she will confirm my claims made below. The City obviously goes to great lengths to ensure that tenants are eligible for the unit prior to initial move-in, but the BPDA will tell you themselves that they have no way of knowing if the property owns are doing any income or asset checks after initial move-in. Owners simply must submit a report to Mary Mendonca at the BPDA, and Mary simply does not have the time or resources to follow-up on the reports to see if there is documentation supporting the claims made in these reports. And I can tell you from my experience that most properties do not do any of the required recertification work.

I have worked in this field for over 14 years and in affordable housing programs where there are no audits, the majority of management company simply stop doing certifications. Additionally, I know people who live in BPDA units who have never submitted a piece of income or asset or tax documentation after their initial move-in. And we’ve been brought on to help new owners of a building in City to ensure their tenants’ are income eligible, only to be told by the tenants that they haven’t had to complete any certification since they moved in years ago.

This is problematic for a myriad of reasons. And based on my work on 40B and units built under special permits, typically about 3-5% of households are found to be over-income for an affordable unit each year of certification. So if certifications are not done for 2-5 years (or ever), it is reasonable to think that 10-20% of the households living in income-restricted units are not qualified. If the City of Boston has 30,000 privately owned affordable rental housing units (that number is from Mayor Walsh’s Housing A Changing City: Boston 2030), then I would estimate that approximately 3,000 to 6,000 people living in income-restricted units are over-qualified.

Think about that. You could create another 3,000 to 6,000 units for people who need them just by having better oversight of the current program. That’s 3,000 to 6,000 more units for Boston Residents without a single new building being built!

I have ideas on how to make it possible, and the burden can be put mostly on the owners and management companies, but some of the burden needs to be shared by the City. I would like the opportunity to talk to you more about this in the near future. As an advocate of affordable housing, and as agent that helps enforce the much needed regulations in place to ensure that the proper households are being served, I think it is critical that the City doesn’t ignore the endgame to all the work that is put into getting income-restricted units built. This really is an opportunity to improve the program and increase opportunities for those that need them.

I look forward to hearing from you.