HUD released on October 22 a Final Report: Evaluation of HUD’s Rental Assistance Demonstration (RAD). The report has a chapter on the impact on residents of converting their public housing to one of two forms of Section 8 rental assistance under RAD. There are also chapters on the experiences of public housing agencies (PHAs), developers, tax-credit syndicators, and lenders; how prior capital needs were addressed, financing and construction spending, and changes in the physical conditions at properties post-RAD; and the financial performance of RAD projects. This Memo article focuses on the chapter pertaining to the effects on residents.
Congress created RAD in FY12 as a demonstration to test whether PHAs could leverage Section 8 rental assistance contracts to raise private debt and equity to make public housing capital improvements and thereby preserve low-income housing. RAD has two components. The first, the subject of the latest evaluation and this Memo article, initially allowed up to 60,000 public housing units to be converted from public housing capital and operating assistance to Section 8 project-based vouchers (PBVs) or to Section 8 project-based rental assistance (PBRA). Congress has increased the unit cap three times despite the absence of an evaluation of the impact of the demonstration on residents. The cap was raised in FY18 to 455,000 units.
An interim evaluation of RAD was published in September 2016 focused primarily on financing-related issues, the types of projects selected for RAD, and the degree of rehabilitation planned. The interim report stated that the impact of RAD conversion on residents would be covered by the next phase of the evaluation and reported in December 2018.
The final report of the demonstration program just released does not address key resident protections and rights. When designing RAD in 2010 and 2011, to HUD’s credit it invited concerted resident-leader input through a HUD-created Resident Engagement Group. As a result of strong advocacy on the part of the Resident Engagement Group, a number of resident protections and rights are embedded in the FY12 appropriations act that created RAD and in all subsequent HUD guidance. Those protections include: no permanent involuntary displacement, a right to return, no rescreening of residents upon return, just-cause eviction, one-for-one replacement of units, continued affordable rents, resident organizing rights, continued receipt of $25 per unit for resident participation activities, and grievance and termination rights under the existing public housing program law. The evaluation did not assess compliance with these resident protections and rights.
Findings Regarding Effects on Residents
Just 298 completed resident surveys from 18 RAD projects from the early days of the Demonstration are reflected in the in the tenant-impact portion of the evaluation. Of the 18 RAD projects, 13 (72%) were in the South, reflecting the fact that HUD disproportionately authorized conversions to RAD in the South during the early stages of the program. The evaluation states that this sample does not likely reflect the current universe of RAD projects. NLIHC provides more details about how projects were selected and how residents were surveyed in “A Brief Summary of HUD’s 2019 RAD Evaluation’s Methodology.”
PHA Communications with Residents
The RAD regulations early in the demonstration required PHAs to have at least two meetings with residents before applying for RAD, and then one more meeting after HUD gave a PHA preliminary approval to convert under RAD, called a “CHAP.” (Starting on September 5, 2019, an additional meeting is required.) The purpose of these meetings is to explain RAD to residents, the PHA’s plans for converting, and how conversion might affect residents.
The report found that while 69% of the residents had heard about RAD, 29% said that they had not heard of it until the researchers described RAD in the survey long after conversion had taken place.
Residents were asked whether they were satisfied or not satisfied with how their PHA communicated with them about RAD. According to the report, 79% said they were very or somewhat satisfied with the PHAs’ communication with them about RAD. This result contradicts the admittedly non-scientific feedback many advocates have received from residents since the beginning of the program. Residents often complained that information provided by PHAs at the required meetings was superficial, leaving residents insufficiently informed about RAD, the potential effects on residents of the options to convert to PBVs or PBRAs, temporary relocation options, or the statutory resident rights and protections.
The purpose of RAD is to preserve public housing. For many years Congress has not appropriated adequate capital funds to meet critical property repair needs. Therefore, significant rehabilitation might be expected at RAD properties (or demolition and new construction of replacement units). Sixty-three percent of the residents in the 18 RAD properties reported, however, that they did not have to move from their home during the RAD process, implying that little or no in-unit rehabilitation was needed (but external renovations or other capital investments such as improvements to heating and cooling systems might have taken place).
Of those who had to temporarily relocate while rehabilitation took place, 29% ultimately returned to their previous, now refurbished homes. Sixty-four percent temporarily moved but did not return to their original home; of these, 50% returned to the original property but a different home while 15% moved to a different property. Out of all 298 respondents, 82% remained at the same property throughout the RAD conversion process, either because they never moved from their unit or because they moved from one unit to another within the same property. A remaining 2% of respondents no longer live in assisted housing.
If residents are temporarily relocated due to RAD, or if they voluntarily decide to permanently relocate, the PHA is required to provide relocation assistance, including reimbursement for out-of-pocket costs such as moving expenses and increased rent and utilities.
Out of 105 residents’ responses to a question regarding whether they received help with moving expenses, only 77% said yes. The report does not address why so many did not receive the required relocation assistance.
Post-RAD conversion, 82% of residents at the 18 projects reported that they were now very satisfied or somewhat satisfied with the quality of their homes. One might wonder why residents’ responses were not closer to 100% satisfaction with the quality of their post-RAD homes. The answer might have to do with the 63% of people who did not have to move during the RAD conversion process. According to the report, these non-mover residents indicated conditions were about the same after RAD conversion. The report points out that this finding makes intuitive sense because non-mover residents’ units probably did not undergo significant in-unit rehabilitation work. Eighty-two percent of households that had to temporarily move reported better unit conditions than non-movers (43%).
The survey asked residents to compare the extent of specific housing problems before and after RAD. Even after RAD, 9% of residents indicated their units sometimes would not have running water, 13% sometimes had uncomfortably cold units, 9% had experienced unusable toilets, 15% had mold or mildew, 8% had broken or damaged doors, 15% reported cracks or holes in the wall, and 18% had peeling paint or broken plaster.
Unique to RAD, residents have the option to leave their RAD-assisted units and move with a regular tenant-based Housing Choice Voucher, if one available at their PHA. If a voucher is not available, the household is placed at the top of the voucher wait list for the next available voucher. This “Choice Mobility” option is open to households after they have lived in their RAD units for one year if their property converted to PBV or after two years if their property converted to PBRA.
According to the report, 49% of all respondents indicated they were not informed about the Choice Mobility option during the RAD process. In addition 49% of respondents reported they would like to exercise the Choice Mobility option. Sixty-two percent of working-age respondents were interested in Choice Mobility, while only 32% of elderly respondents were.
NLIHC’s “A Brief Summary of the Evaluation’s Methodology” is at: https://bit.ly/349Obgn
The Final Report: Evaluation of HUD’s Rental Assistance Demonstration (RAD) is on the RAD website at https://www.hud.gov/RAD
More information about RAD is on page 4-33 of NLIHC’s 2019 Advocates’ Guide, and on NLIHC’s public housing webpage: https://bit.ly/2WlrlQd