In response to the Department of Housing and Urban Development’s (HUD) solicitation of comment on its controversial “Promise Zones” program, Congresswoman Maxine Waters (D-CA-43) expressed her deep concerns with the proposed selection process and called on the Department to ensure that it does not leave our nation’s hardest hit communities behind.

In a letter to HUD Secretary Shaun Donovan, Waters, the top Democrat on the Financial Services Committee, expressed concern that the Department’s current place-based, neighborhood revitalization initiatives, including Promise Zones, are not reaching many of the country’s highest need, hardest hit communities.  As a result, many communities are being left behind, a consequence that Waters stressed is “not only unacceptable, but also unsustainable, as many of our country’s communities fall deeper into blight.”

Waters pointed out that the Promise Zones initiative has flawed criteria for selecting program designees:

“As currently proposed, the second round urban criteria for the Promise Zones initiative is skewed towards neighborhoods that already have resources and strong partnerships in place, leaving little to no chance for many of our country’s highest need communities to successfully compete.”

Waters criticized the proposed application criteria for prioritizing existing capacity over capacity building – and for not giving adequate consideration for the needs of a community.

She went on to make recommendations for a new Promise Zone program, proposing changes to the selection process that would specifically benefit communities such as South Los Angeles, by basing designation decisions on need, eliminating arbitrary population caps for Promise Zone applicants, and ending geographic diversity criteria that could leave behind many hard-hit neighborhoods, among others. She also called on HUD to find ways to increase the total number of Promise Zone designations in order to reach a broader number of communities.

Waters continued, “My recommendations call for a new kind of Promise Zones Initiative – a program that refocuses efforts on those hardest hit communities that need federal support the most.  I understand that resources can be a barrier, but with a need as important as revitalizing our poorest communities, it is incumbent upon the federal government to find ways to overcome such barriers.  With ten federal agencies involved and billions of dollars in budget authority, the Administration should find ways to reallocate resources to lift up all of our poorest, highest-need neighborhoods.  The core mission of HUD is to alleviate poverty, and if we are not working towards that goal for our poorest, highest-need neighborhoods, then we are not adhering to our mission at the most basic level.”

The text of the letter is below. A signed copy is available here.

Secretary Shaun Donovan
U.S. Department of Housing and Urban Development
451 7th Street, SW
Washington, D.C. 20410

Dear Secretary Donovan:

                I am deeply concerned that the Administration’s current placed-based, neighborhood revitalization initiatives are not reaching many of the highest need, hardest hit communities across our country.  Two main programs available to revitalize our nation’s severely distressed public and assisted housing, the Promise Zones (PZ) and Choice Neighborhoods (CNI) initiatives, have application structures that impede many of our highest need communities from successfully receiving the federal support these neighborhoods so desperately need.  These application structures are reflective of an Administration strategy to focus resources for revitalization efforts only in higher-resource communities as a way to guarantee a certain level of success.  As a result of this policy, however, the federal government is effectively leaving behind many of our hardest-hit neighborhoods.  This consequence is not only unacceptable, but also unsustainable, as many of our country’s communities fall deeper into blight.  Of particular concern to me right now, and the main subject of this letter, is the proposed second round urban application for the Promise Zone initiative.

                As currently proposed, the second round urban criteria for the Promise Zones initiative is skewed towards neighborhoods that already have resources and strong partnerships in place, leaving little to no chance for many of our country’s highest need communities to successfully compete.

                The Administration has made clear through the proposed second round application criteria, supporting materials, and external communications that they are looking for high capacity, “tipping point” neighborhoods that are currently engaged in comprehensive revitalization efforts.  The proposed second round application criteria prioritizes an applicant’s capacity and current resources over the needs of the community.  This decision to prioritize capacity over need is evident throughout the application, including in the point distribution and in the requirements for existing partnerships.  As a result, I am deeply concerned that the Promise Zones initiative will not even come close to reaching many of the “hardest hit” neighborhoods that President Obama referred to in his 2013 State of the Union speech when announcing this new initiative.

                Many high-needs, high-poverty neighborhoods have little to no resources available to improve and strengthen their capacities.  The first round of Promise Zones designations went to cities that previously received major federal grant support, thus saturating federal resources into specific neighborhoods and leaving many, many more neighborhoods without.  It is unclear to me why HUD would choose to provide technical assistance and preference priority for federal grants to cities that have already demonstrated high capacity by already receiving major federal grant support, rather than to cities that could use the benefits from a Promise Zones designation as a catalyst for revitalization efforts.

                In order for Promise Zones to truly address the needs of all of our hardest hit neighborhoods across the country, the Administration must consider substantial revisions to the program’s current structure so higher-needs, lower-capacity neighborhoods are prioritized and have the ability to successfully compete for the federal government support they so desperately need.  A more inclusive and refocused Promise Zones initiative would begin to more fully meet the needs of our nation’s truly hardest hit communities.  Helping to alleviate the deepest pockets of poverty in our country should be a top priority of HUD’s and reflected in the Department’s key neighborhood revitalization programs.  I have outlined my recommendations below, with additional comments in the subsequent table.

1. The Administration should expand and reprioritize Promise Zones to focus on communities where capacity building is needed and where a PZ designation could serve as a catalyst for revitalization. These “Promising Zones” neighborhoods should receive robust technical assistance from the federal government and preference priority for the Administration’s place-based initiatives. 

                Currently, the core benefit of Promise Zones is robust technical assistance, including on-the-ground intensive federal government support to carry out revitalization plans and to, according to the application, “smooth the way for problem solving among siloed federal programs, identify ways to use existing funding allocations more efficiently, and expedite consideration of waivers of federal provisions.” Again, it is unclear to me why this type of a program is focused on supporting communities that have already demonstrated high capacity and also have rather substantial federal government support. Rather, a program of this design should be focused on motivated, high-needs communities that want to work hard to increase their capacities and improve their neighborhoods.

                The Administration should expand and refocus the current Promise Zones initiative to prioritize higher-need “Promising Zones” communities that need extra support from the federal government to improve their capacities and strengthen their revitalization plans.  Promising Zones designees should receive similar intensive federal partnership and national service support as current Promise Zone designees, as well as preference points for federal grants to help with revitalization planning efforts, such as CNI Planning Grants.  Applicants who applied for but did not receive federal grants through Choice Neighborhoods and other similar place-based programs should be given priority consideration.

                The current allotment of twenty Promise Zones designations is too few, especially when the application criteria make it nearly impossible for the truly hardest hit neighborhoods across the country to successfully compete.  With reportedly over 1,000 participants on a recent national call to discuss the second round urban application, there is certainly not a lack of interest or need from a wide variety of communities across the country.  The Administration should find ways to increase the total number of Promise Zone designations in order to reach a broader number of communities.

2. A community’s need should be the main determinant in the application.

                The Promise Zones application point structure gives only 10 points out of a total of 100 points for the Need of the geographic area proposed as a Promise Zone, while giving a total of 40 points for the Strategy section, and 50 points for the Capacity and Local Commitment section. This point distribution marginalizes the needs of a community, when it should undoubtedly be the most important factor in choosing designations.  As a result, the scoring will inevitably weed out high-needs neighborhoods with lower capacities based on points alone.  Scoring should be much more heavily weighted toward the need of the community than what was in the first round criteria and what is currently proposed.  The Need category should account for a minimum of 50 out of 100 overall points, with the remaining points equally divided between the Capacity and Local Commitment and Strategy categories.   

3. The application should not include a cap on population.

                Many high-poverty, higher-needs neighborhoods are centered in urban cores, where population densities are high.  Potential Promise Zones applicants could have jurisdiction over geographic regions that are well over the 200,000 population cap in the proposed second round application, including, for example, communities in the City and County of Los Angeles.  The Administration has not given any reason for including a population cap, and there is no reason why a community should not be able to apply for a Promise Zones designation simply because of population size.  Neighborhoods with higher populations should not be disqualified based upon an arbitrary population cap, and the cap should be eliminated.

4. The application should not include a geographic diversity preference.

                Consistent with my previous recommendations, neighborhoods should be chosen upon need first and foremost, and merit.  Attempting to fulfill geographic diversity in the program could potentially result in more qualified neighborhoods not receiving a Promise Zones designation.  Qualifying neighborhoods in south Los Angeles, for example, stand little chance of receiving a designation if this preference is included in the final second round application, since central Los Angeles has already received a designation.  The geographic diversity component of the application criteria should be removed.

5. The Promise Zones Initiative should prioritize our nation’s most severe housing needs.

                Housing serves as a platform for improving a person’s quality of life, from education and health outcomes, to aging in place, to improving general family well-being.  Every individual, family, and child deserves access to a safe, secure, habitable, and affordable home. It is the government’s obligation to guarantee that everyone can exercise their right to live in safety and with dignity.  This right must be provided to everyone, regardless of income or access to economic resources.  The Housing First model has been tremendously successful in the homelessness community, demonstrating that solving one’s housing problems first means that other life needs can be addressed, including health, economic stability, and education.  Studies in Los Angeles show that placing someone in permanent supportive housing is 40 percent less costly than leaving them on the streets, where they utilize a variety of public resources.  Housing serves as a way to achieve both positive life outcomes and economic savings, which is why it is so important that the Promise Zones initiative maintain a sharp focus on affordable housing revitalization in its application structure and in its subsequent work with designee and grantee communities.  As a way to prioritize housing needs, the capital needs of any public and assisted housing within a proposed Promise Zone should be added to the Need category. Grantees who include a plan for preserving or creating affordable housing should receive additional points in their application.

                My recommendations call for a new kind of Promise Zones Initiative – a program that refocuses efforts on those hardest hit communities that need federal support the most.  I understand that resources can be a barrier, but with a need as important as revitalizing our poorest communities, it is incumbent upon the federal government to find ways to overcome such barriers.  With ten federal agencies involved and billions of dollars in budget authority, the Administration should find ways to reallocate resources to lift up all of our poorest, highest-need neighborhoods.  The core mission of HUD is to alleviate poverty, and if we are not working towards that goal for our poorest, highest-need neighborhoods, then we are not adhering to our mission at the most basic level.  
                
                Thank you for your consideration. 

Sincerely,

MAXINE WATERS
Ranking Member

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