SI LTDRO Public Comment on CBDG-DR plan A

Staten Island Community and Interfaith Long Term
Disaster Recovery Organization

Immediately after Superstorm Sandy devastated Staten Island, many non-profit organizations, faith communities, and volunteer crews stepped up to help the community recover from the disaster. These service providers started meeting together every week beginning in November to collaborate and share resources to foster an effective long term recovery on Staten Island and to provide a vehicle for disaster preparedness and future emergency responses. These groups have formalized their relationships and become the Staten Island Community and Interfaith Long Term Disaster Recovery Organization (the Staten Island LTRO). 

The LTRO continues to meet on a weekly basis with membership from over forty disaster recovery organizations. Our LTRO has twelve committees, each representing the perspectives of Sandy impacted residents, social service providers, community leaders, elected officials and local and federal agencies. 

The Staten Island LTRO commends the efforts of the City to provide a structure to the process that attempts to address the needs of Sandy victims in a fair and equitable manner. The organization writes now to raise the questions and concerns of highest priority to our member organizations and their resident constituencies with respect to the Partial Plan A for the first Community Development Block Grant, specifically focusing on NYC Houses Program, which will directly impact the majority of our members. These concerns fall into categories that trace a hypothetical affected homeowner’s path through the program in chronological order. 

Program Staffing
The Plan as written is vague regarding the operations and staffing of the NYC Houses Program.  It is unclear which agency will be the managing agency for the program and if that agency will be supervising the Housing Recovery Specialists. In addition, the LTRO urges that the revised plan provide clarity about how Housing Recovery Specialists will be recruited and trained and what the qualifications for those positions will be.

The NYC Houses program excludes assistance for undocumented homeowners.  Staten Island is already one of the least diverse of the five boroughs.  The LTRO is extremely concerned that the legacy of Sandy will be one that lessens that diversity further. If the NYC Houses Program is not amended to include support for undocumented homeowners, we urge that alternative sources of assistance be provided regardless of federal immigration status. 

Outreach
The Plan as written does not seem to contemplate funding door-to-door outreach. All the outreach channels enumerated are broadcast-based, not affirmative outreach methods for finding those who are displaced.  We have found, based upon our contact with the affected communities, that these outreach methods have not been very effective in the past. For example, most people we have spoken to were completely unaware that the City had a mold program. Additionally, the plan is not clear about the time frame for intake. Please advise how long homeowners will have to apply and how deadlines will be communicated.

Assessment of Damage
Concerns have also been raised regarding assessments. Our understanding is that the prioritization will be based upon the amount of damage sustained rather than the amount of unmet need.  We are hopeful that the priorities will instead be based upon unmet need as a percentage of the total pre-storm value of the home. This will ensure that lower income areas are not prioritized last simply because the home values are not as high. 

We believe the plan should include more detail or the city should provide more information about the hiring and training process for assessors.  In particular, which city agency will manage and supervise the assessors? What qualifications must someone in that position possess and what training will be provided?

Housing Needs During Home Reconstruction and Rehabilitation
LTRO members are concerned that the plan does not articulate any rental assistance in connection with the assessment process. We would like the plan to include more details about what the requirements for eligibility for rental assistance and what the limits of such assistance will be. Have any locations on Staten Island been identified for short term housing that would fit the monetary criteria that will be set? Finally, the LTRO feels strongly that undocumented immigrants should be eligible for the rental subsidy program, as the program would fall under the category of “short-term, no-cash, in-kind disaster assistance.” 

Appealing the Assessment
The Plan does not articulate any process for a homeowner to appeal a damage assessment. A homeowner may realistically disagree about which “path” is available for them under the NYC Houses program. In particular, many residents have disagreed with determinations made by FEMA and/or insurance companies with respect to the amount of damage or amount of awards offered to them. The plan must  advise how the assessment process will address inconsistencies and disputed amounts. 

Limiting post-Sandy Options for the Most Affected
Under the Plan as written, in order to get assistance through the NYC Houses program, a homeowner must commit to five years of future ownership. Many residents have been hit hard emotionally as well as financially and do not wish to return to their homes. They do however desire to restore these homes so that they may be sold. While we recognize and applaud the City’s efforts to ensure that neighborhoods remain intact, the determination of whether to sell or stay should be left to a homeowner without disincentive. The unintended result could be homes left unrepaired and unsold in the midst of neighborhoods that are recovering. 

Reconstruction and Rehabilitation: Who Does the Work?
The plan does not explain how the contractors who are eligible to be paid by the restricted grants for rehabilitation and rebuilding work on individual properties will be selected. The LTRO’s members have expressed concerns and voiced the concerns of their constituent Staten Island residents that, unless the Plan specifically articulates a preference for using local contractors and a clear pathway for those contractors to become approved for receiving funding through the CDBG restricted grants program, there will be a repeat of the inefficiencies of the Rapid Repairs program and a foreclosing of economic opportunities for contractors and others in the construction trades who themselves have been affected by Sandy.

When the rapid repairs program was implemented, many of the contractors used were from out of town. Local residents prefer to utilize local contractors for a variety of reasons. First, keeping the money spent in the community, especially when many are still struggling from the economic impact of Sandy and a less than strong economy is a goal the residents support. Second, residents feel that contractors who are not local do not have to protect their reputations in the community the same way someone who has done business here for years and plans on continuing to do so does. If there are any problems with a local contractor, residents are more confident in their ability to find the contractor and resolve the issue. The Staten Island LTRO and its constituent members urge that there be a preference given for local licensed contractors and a clear pathway for those community institutions to participate in rebuilding their neighborhoods.

Reconstruction and Rehabilitation: Financial Supports for Sandy Victims Who Are Partially Recovered
At the urging of government, many homeowners incurred substantial debt or depleted their savings to make immediate repairs to their homes. The repairs made by these residents are excluded from the Plan for recovery. While the LTRO understands the need to limit spending and the difficulty in oversight that occurs with a reimbursement plan, we hope that the City will recognize that the financial impact of Sandy on residents who made repairs at their own cost will have a long term effect on neighborhoods and the local economy. The LTRO suggests that the City consider implementing a grant program based upon economic need for those that are suffering economically as a result of the storm.

Reconstruction and Rehabilitation: Prioritizing Support for Mitigation in the Face of Potential Future Flooding and Present Financial Insecurity
Based upon the information provided at the Community meeting at St. Charles Church on April 1st, it is the Staten Island LTRO’s understanding that homeowners whose property was not “substantially damaged” as that term is defined will not be eligible for aid to raise their homes to the elevations required under the new flood maps. In our opinion, not including funding for raising homes that were damaged disproportionately affects those in the lower income brackets who will be unable to afford to make the choice between raising the home at their own expense or paying exorbitant increases in flood insurance. These residents will also be unable to sell their homes because a buyer’s mortgage company will require the flood insurance or the elevation.  For a bungalow, the cost of either choice will likely  be a much greater percentage of the total value of the home than for other types of homes. These residents will be left with little choice other than acquisition.

Pushing many homeowners at once into the acquisition pathway is guaranteed to change the character of the neighborhoods most affected by Sandy. There is no guarantee that post-acquisition construction will create affordable housing options; with no new affordable housing options, the character of neighborhoods that were economically and racially diverse will homogenize post-acquisition. Protecting the uniqueness of Staten Island’s lower middle class neighborhoods is a priority for us as an Organization and we urge that it be incorporated as a priority into the plan for our neighborhoods’ recovery by supporting those who want to stay in homes that are now in the floodplain.

Sincerely,
The Staten Island Community and Interfaith Long Term Disaster Recovery Organization

Member Organizations:
Beacon of Hope NY
Calvary Presbyterian Church
Castleton Hill Moravian Church
Cedar Grove Community Hub
Christ Church
Church at the Gateway
Community Health Action of Staten Island
Effective Trauma Therapy
Episcopal Diocese NYC
Habitat for Humanity
Jewish Board of Family and Children’s Services
Lutheran Family Health Centers
Lutheran Social Services of NY
Make the Road NY
Mennonite Disaster Service
Metropolitan NY Synod ELCA
Midland Ave Neighborhood Relief
Midland Beach Alliance
New York State Nurses Association
NHS of SI Inc.
Northfield LDC
Occupy Sandy
Olivet Presbyterian Church
Port Richmond CERT
Presbyterian Church of Chatham Township
Project Hospitality
The Salvation Army
Sandy Yellow Team
Sarapis Foundation
Star America
Staten Island Episcopal Church Long Term Recovery Group
Staten Island Help. Inc.
Staten Island Hunger Task Force
Staten Island JCC
Staten Island Legal Services
Staten Island Tool Library
Staten Island University Hospital
Tunnels to Towers Foundation
Unitarian Church of SI
Urban Outreach
Where to Turn
World Cares Center
World Hindu Council

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