Testimony of Charisse Lue, Staff Attorney and Brittany K. Ruffin, Legal Director, Systemic Advocacy and Litigation of The Washington Legal Clinic for the Homeless
February 26, 2026
The Washington Legal Clinic for the Homeless envisions a District of Columbia where housing is a human right, racial justice is a reality, and all people have true and meaningful access to the resources needed to thrive.
The Washington Legal Clinic for the Homeless strongly recommends that this Committee uses its oversight authority to ensure DCHA adheres to local and federal laws and establishes policies and systems designed for better accessibility and preservation of affordable housing through transparent reporting and open communication with DCHA applicants, participants, stakeholders, and board members. We urge the council to continue to invest into the repair and maintenance of the neglected and dilapidated public housing infrastructure that so many D.C. families, disabled and elderly residents had to endure for so many years. However, it is also crucial that this committee use its oversight authority to ensure that D.C. Housing Authority is efficient, flawless, and transparent when appropriating those funds for that purpose. D.C. Housing Authority is executing a large-scale public housing demolition and renovation of several public housing properties. This Committee should use its oversight authority to ensure that DCHA lays out a clear organizational plan that includes an effective resident engagement process and centers the needs of those impacted, leaving no resident behind. Council should utilize its authority to protect displaced residents and codify their rights including residents’ right to return by reintroducing and passing the Public Housing Preservation and Tenant Protection Amendment Act of 2020 and including its language in the Budget Support Act (BSA).
After many proposed iterations of the Administrative Plan and the Admissions and Continued Occupancy Plan (ACOP), DCHA began engaging legal service providers and tenant advocates in workgroup sessions where advocates detail the many concerns and offer solutions to the very problematic and overly burdensome changes to the regulations. We appreciate those meetings and know that the agency did as well, as they have highlighted the engagements in their responses and testimony. However, advocates, stakeholders and participants need DCHA to demonstrate meaningful consideration of the feedback and solutions provided. Some of the proposed final regulations increase barriers to affordable housing such as the dramatic increase of the criminal “look-back” periods. DCHA proposes that instead of HUD’s recommended three years “look-back” period, D.C. residents in need of affordable housing will need to overcome a more burdensome “look-back” period of five and seven years for the ACOP and Admin plans, respectively. Not only are these increased “look-back” periods draconian, but they are also arbitrary, confusing and ignore the well-known and documented relationship between racism, poverty, and over-policing. At this time, when D.C. residents are facing unprecedented obstacles, DCHA opted to be more restrictive than HUD requires for admission to the most basic of human needs, housing. Additionally, for each of the emergency and proposed regulations advocates have provided the feedback that DCHA neglects to cite to the local laws where applicable. This is not a harmless error, citing applicable federal and local laws that DCHA and its residents are governed by, are there to protect and educate DCHA staff, applicants, and residents.
Communication and transparency continue to be issues. We are looking forward to the roll-out of improved systems, however as it stands, DCHA continues to fail in its obligation to produce requested documents and files before hearings, a barrier that further diminishes agency accountability and violates due process rights. Applicants and residents still find it incredibly difficult to contact the appropriate staff members or even know which staff member assigned to their case, no matter how urgent their matter may be. At the most recent STAR Board meeting the board was unable to vote on the resolution to adopt the proposed final administrative plan when the agency failed to provide the amendments in advance for the Board to review. These are only a few examples. DCHA must develop and execute systems and policies designed to be responsive and transparent to its residents, applicants, stakeholders, and its oversight bodies.
While we are supportive of the rent-reasonableness policy there continues to be a lack of transparency and guidance that is causing confusion with its implementation. The process continues to cause barriers for voucher holders. This confusion and lack of transparency encourage housing discrimination and continues to result in prolonged housing instability and homelessness. Additionally, DCHA needs to be more transparent with voucher holders during the lease-up process. Not providing voucher holders information or status updates during the RFTA process and denying the applicants access to view the portal is resulting in voucher holders losing their voucher due to no fault of their own. DCHA’s efforts should focus on clear instructions and equitable transparency to both voucher holders, and landlords. Currently, DCHA only informs the landlord of the rent-reasonable range, and what documents DCHA needs from the landlord during lease-up, leaving applicants unaware and powerless. Additionally, DCHA should use improved technology that allows for greater agency accountability, transparency for the applicants, better collaboration with DHS, and a much shorter lease-up period.
Finally, we know that Washington D.C. is pleasantly unique, as it has enacted locally funded permanent housing programs. This body specifically enacted and funded these programs to provide affordable housing to our residents in need without the limitations of the federal program. We ask that DCHA, with the guidance and oversight of this committee, continue to manage our local programs in a manner that coincides with D.C.’s values and the intentions of our local permanent housing programs, including record keeping, eligibility standards and reporting mechanisms. The WLCH is hopeful that the Council accepts our recommendations and uses its legislative and oversight authority to ensure that DCHA becomes an agency that all D.C. residents in need can rely on to provide safe, healthy, and affordable housing.