As a coalition whose members include voices from both the owner and resident side of the affordable housing ecosystem, The Coalition for Nonprofit Housing and Economic Development (CNHED) has a unique and irreplaceable role in the District. We recognize that DC’s renters need a compassionate safety net to endure unexpected hardships. We also acknowledge that no renter is truly stable unless DC’s rental housing is stable.
CNHED commends Chairman Phil Mendelson’s Emergency Rental Assistance Reform Emergency Amendment Act of 2024 as a welcome step toward acknowledging that a District of renters needs both rental property owners and residents who can thrive. CNHED urges the passage of the Bill without amendments.
The Emergency Rental Assistance Program (ERAP) was designed to provide emergency rent payments for households who faced a temporary inability to pay due to unusual circumstances. It was not designed to serve as a long-term rent subsidy to fill predictable gaps between rents and income in DC’s high-cost rental market. Pandemic pressures and related changes in policy and practice have called on ERAP to do more than it can and should do. We must get back to its basic purpose or the needs of households facing an emergency will be crowded out of the assistance program designed for them. The Chairman’s bill takes important steps to do so.
The improvements in this bill are essential, most notably eliminating self-attestation and right-sizing ERAP-related eviction stays.
Eliminating self-attestation allows ERAP providers to support residents with income-based subsidies in getting their ongoing subsidy level adjusted to reduce affordability problems moving forward. As long as ERAP providers retain flexibility about which documents to use in certifying eligibility, eliminating self-attestation is neither onerous on residents nor burdensome in terms of processing time.
Pausing the eviction process to confirm eligibility for ERAP and allow time for applications to proceed is both smart and humane. Allowing overly long and repeated delays, however, destabilizes rental properties when it begins to happen on a system-wide basis and may actually result in residents digging a deeper financial hole by building up larger balances of unpaid rent as the months pass by. The likelihood of eviction as the only realistic outcome grows higher and higher when renters end up multiple months behind, and that serves no one well.
Looking forward, we see additional issues that the District needs to address to restore a healthy affordable rental housing ecosystem. Our working groups have been looking at these needs more broadly, including but not limited to regulatory and process changes that could make ERAP more effective. For example, even if the current ERAP reform passes, people relying on ERAP would need help ensuring that approved applications do not get stuck in administrative or purchase order delays that hold up payment. We would welcome the opportunity to work with the Administration and the Council to ensure that the Chairman’s bill is the start and not the end of ERAP reforms.
Even with these needed improvements, we must recognize that there continues to be a mismatch in DC’s rental market between prevailing rents and what many households can pay. We must continue to invest in the production and preservation of affordable housing at rent levels that match household incomes, while also helping households find pathways to increasing their incomes.
Signed,
