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Report Fraud, Waste and Abuse
January 11, 2022
  • Public and Indian Housing
2022-NY-1001
2022-NY-1001.pdf

We audited the Buffalo Municipal Housing Authority’s management of its Commodore Perry Homes development.  We selected the Authority based on congressional interest.  Half of the development’s buildings were demolished more than 20 years ago, and the majority of the remaining buildings and units have been vacant for years without redevelopment activity.  The objective of the audit was to determine whether the Authority properly managed its Commodore Perry Homes development.  Our work focused on the period beginning in July 2013.

The Authority did not properly manage the Commodore Perry Homes development to address longstanding redevelopment needs and health and safety issues.  While the Authority had made various redevelopment plans for the property since 2013, none fully materialized, and all dwelling units in the development are now vacant.  Further, the Authority did not adequately address urgent, ongoing health and safety issues with the vacant development.  These issues occurred for various reasons, including that the Authority did not consistently prioritize taking action at its Commodore Perry Homes development, lacked a cohesive redevelopment strategy over time, and lacked sufficient processes to address recurring issues.  While HUD and the Authority had recently taken steps toward developing a plan forward, no redevelopment had occurred at the site.  As a result, fewer low-rent units were available to families in need, the vacant development continued to deteriorate, and the surrounding residents and local community continued to be exposed to significant blight and health and safety issues.

We recommend that HUD determine (1) whether the development represents an imminent threat to public safety and activities to control the situation could be taken before the full environmental review process, and (2) which environmental review process would be most beneficial to ensure that it is completed as soon as possible.  Further, we recommend that HUD continue to provide training and technical assistance to the Authority and require it to (1) identify and address urgent health and safety issues; (2) develop and implement a plan to routinely identify and address recurring urgent health and safety issues; and (3) develop and implement plans for the remaining public housing units at the development and for the original property related to the units converted during previous redevelopment efforts.  Last, if the Authority does not follow through on its asset repositioning plans, misses deadlines, or the plan is no longer feasible, we recommend that HUD consider and use available remedies.

Recommendations
Recommendation Status Date Issued Summary
2022-NY-1001-001-A Closed January 11, 2022 Work with the Authority to determine whether the buildings represent an imminent threat to public safety from physical deterioration and whether activities to control the situation would be exempt under the Part 58 environmental review process or excluded under the Part 50 environmental review process. If it qualifies, require the Authority to immediately take actions necessary to control the imminent threat to public safety before the full environmental review is done.
2022-NY-1001-001-B Open January 11, 2022 Determine whether it would be beneficial for HUD to conduct a Part 50 environmental review of the development or if the Authority should conduct a Part 58 environmental review, and implement the decision to ensure that the environmental review is conducted as soon as possible as required under the action plan.
2022-NY-1001-001-C Closed January 11, 2022 Continue to provide training and technical assistance to ensure that the Authority understands relevant requirements for the various asset repositioning options, including milestone and disposition requirements.
2022-NY-1001-001-D Closed January 11, 2022 Provide certifications and supporting documentation to show that it has identified and addressed urgent health and safety issues at the development, such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors.
2022-NY-1001-001-E Open January 11, 2022 Develop and implement a plan to routinely identify and address recurring urgent health and safety issues such as flooded stairwells, accessible crawlspaces, and unsecured windows and doors while the property remains vacant and throughout future asset repositioning efforts.
2022-NY-1001-001-F Open January 11, 2022 Develop and implement a plan to use available asset repositioning options for the remaining 284 public housing units at the Commodore Perry Homes development, including 274 dwelling units and 10 nondwelling units.
2022-NY-1001-001-G Open January 11, 2022 Develop and implement a plan for the original property related to the 46 units converted under the RAD transfer of assistance option to ensure that the property and proceeds from its disposition are used in accordance with requirements.
2022-NY-1001-001-H Open January 11, 2022 If the Authority does not follow through on its asset repositioning plans, misses deadlines, or it otherwise becomes clear that the plan is no longer feasible, work with the HUD’s Special Applications Center, Office of Recapitalization, and other offices as appropriate, to consider and use available remedies such as revoking approval and enforcing required conversion.