Rule Comments – Texas Department of Housing and Community Affairs, Mfg Housing

TCDD Letterhead

October 30, 2013
J. Paul Oxer, PE, Chair
Tim Irvine, Executive Director
Texas Department of Housing and Community Affairs
P.O. BOX 13941
Austin, TX 78711-3941
Dear Mr. Oxer and Mr. Irvine:
Thank you for your leadership in developing affordable housing options for low income people, especially those with disabilities. This is to request reconsideration of the new rule TAC 10.1.20.4(c) that removes manufactured housing units from eligibility for the Amy Young Barrier Removal Program.
The Amy Young Barrier Removal Program was named in memory of an advocate who worked on behalf of the Texas Council for Developmental Disabilities (TCDD) which is established by federal law in the Developmental Disabilities Assistance and Bill of Rights Act. The Council’s governing board is a 27 member body, appointed by the Governor, 60 percent of whom are individuals with developmental disabilities or family members of individuals with disabilities. TCDD’s purpose in law is to encourage policy change so that people with disabilities have opportunities to be fully included in their communities and exercise control over their own lives.
The Amy Young Barrier Removal Program provides funds to eligible entities to improve the accessibility of homes for low-income individuals with disabilities. These funds can be used for reasonable accommodations or modification for tenants, homeowners or a member of their household with disabilities who needs assistance to fully access their home.
Amy Young, as stated on the TDHCA’s website, “gave shape to the much-needed program, she also urged the Department to offer the program through its state funded Housing Trust Fund (HTF), which provided greater flexibility and fewer regulatory restrictions than federally funded programs, making it an ideal vehicle for this initiative.” This rule will decrease flexibility and impose undue regulatory restrictions.
Harvard University’s Joint Center for Housing finds low-income families still dominate the market for manufactured homes. In a survey of 21,866 residents of manufactured homes the mean household income for those in owner-occupied manufactured homes is $28,874 compared to $66,699 for homeowners.i And, adults in poor families are more than twice as likely as adults in families that were not poor to have severe difficulty in each of the nine physical activities included in the Survey of Vital and Health Statistics collected annually by the Centers for Disease Control (CDC).ii Removing manufactured housing from the Amy Young Barrier Removal Program removes that opportunity for a significant number of Texans with disabilities who live in manufactured housing. The U.S. Census estimates from 2000 found that mobile homes in Texas reflect at least 9% of the housing units.iii
Amy was tireless in her efforts to educate legislators, state agency personnel and others about the changes needed to allow every person, including persons with disabilities that live in manufactured housing, to live independently in the community. Thank you for your consideration of our request to return the Amy Young Barrier Removal Program as an option for persons with disabilities in manufactured housing.
Sincerely,
/S/
Roger A. Webb
Executive Director


i Manufactured Homes a Big Factor in Rural Homeownership in U.S. Population Reference Bureau. Retrieved April 7, 2011 from http://www.prb.org/Articles/2004/ManufacturedHomesaBigFactorinRuralHomeownershipinUS.aspx
iiSummary Health Statistics for U.S. Adults: National Health Interview Survey, 2003. U.S. Department Of Health And Human Services Centers for Disease Control and Prevention National Center for Health Statistics. Retrieved April 7, 2011 from https://www.cdc.gov/nchs/data/series/sr_10/sr10_225.pdf
iiiHistorical Census of Housing Tables. U.S. Census Bureau. Retrieved October 29, 2013 from http://www.census.gov/hhes/www/housing/census/historic/units.html