On Friday, July 2nd, the Legal Aid Justice Center (LAJC) and the Virginia Poverty Law Center (VPLC) submitted joint public comment on the Richmond Redevelopment Housing Authority (RRHA) Annual Agency Plan opposing significant aspects of the plan.
Our key concern is that the plan will decrease the amount of deeply subsidized housing units in Richmond, disproportionately impacting people of color. RRHA currently plans to redevelop all of its public housing communities, converting 100% low-income developments such as Creighton Court into mixed-income communities. Without one-for-one replacement, this will greatly lessen the number of units affordable to the lowest-income bracket of renters. RRHA’s own agency plan states that there are over 11,000 families on its public housing waiting list, 82.4% of whom are extremely low-income and 88% of families on the wait list are Black.
LAJC and VPLC are requesting that RRHA adopt one-for-one replacement in its redevelopment plans, which means that for every unit of deeply subsidized housing demolished, another would be built.
RRHA’s primary solution for those tenants being displaced by redevelopment activities is to provide vouchers for use with private landlords. While vouchers do allow flexibility that can be preferred by some renters, replacing actual deeply subsidized housing units with portable vouchers without also rebuilding actual subsidized homes remains problematic. Large landlords are no longer allowed to discriminate against voucher-holders because of recently passed Fair Housing laws, but smaller landlords, owning four or fewer units still can lawfully refuse to rent to voucher holders. Additionally, private landlords often have more stringent screening criteria, such as credit requirements, that keep low-income families out, limiting options. Voucher funding can also be reduced easily by the federal government while actual deeply subsidized units guarantee long term availability of housing that is affordable to renters with very low incomes.
The public comment also asks for changes in RRHA’s leasing and application policies, most notably the criminal background screening policies including updating the list of exclusionary offenses and only allowing RRHA to look at the past five years of a prospective tenant’s criminal record. The public comment asks for similar changes in RRHA’s voucher program, as its current screening rules exclude many applicants with criminal records that are eligible to receive vouchers under HUD regulations.
And since marijuana became legal on July 1st, 2021, LAJC and VPLC are requesting that marijuana be formally removed as grounds for lease termination. RRHA has already removed marijuana-related crimes from their criminal background screening denial list, but it’s unclear whether marijuana use could still result in a tenant having their lease terminated.
The groups also note that RRHA’s plan was developed with insufficient opportunities for tenants to have input. RRHA submitted the plan to its Board of Directors more than two weeks before the end of the written comment period. Additionally, RRHA failed to provide the legally required 45-days notice before the public hearing on the plan, giving people an insufficient amount of time to plan for the hearing.
You can read the text of the public comment left by LAJC and VPLC here.