Audit Report on the New York City Housing Authority’s Emergency Preparedness

Audit Report on the New York City Housing Authority’s Emergency Preparedness

EXECUTIVE SUMMARY

The New York City Housing Authority (“NYCHA”) was chartered in 1934 under the New York State Public Housing Law as a public benefit corporation, three years before the enactment of a national federal housing program. Its mission “is to increase opportunities for low- and moderate-income New Yorkers by providing safe, affordable housing and facilitating access to social and community services.” Pursuant to its charter and its status as a federal Public Housing Agency (“PHA”), NYCHA develops, constructs, and manages affordable housing in New York City. Currently there are more than 400,000 residents in 328 public housing developments comprised of 177,666 apartments in 2,553 residential buildings throughout the five boroughs.

On October 29, 2012, Hurricane Sandy (“Sandy”) hit New York City, causing massive flooding and other damage in all five boroughs. The storm directly affected many NYCHA residents, and resulted in damage to 402 NYCHA buildings that contained over 35,000 apartments. Approximately 80,000 residents lost essential services including electricity, elevator service, heat, and hot water because their heating and electrical systems were located in basements that flooded.

Audit Findings and Conclusions

Our audit found that NYCHA’s efforts to prepare for emergencies contain significant deficiencies that increase the risk that NYCHA will not be able to effectively handle emergency situations and restore the agency to a normal level of operation in an expeditious manner. Specifically, we found that NYCHA’s Emergency Procedures Manual does not properly define the emergency management leadership; does not adequately identify a distinct hierarchy of who would be in charge in the event of an emergency situation; does not have a communication plan that specifies how critical information will be disseminated to NYCHA’s employees, residents, and other stakeholders; and does not incorporate an overall view of NYCHA’s capabilities and potential hazards during major emergencies, including identification of its resources, critical services and operations, and community groups that could potentially assist with the emergency response.

We also found that to the extent that NYCHA’s Emergency Procedures Manual does set out procedures to follow in cases of different types of emergencies, NYCHA has not complied with certain key provisions. Further, we found that NYCHA does not maintain accurate information on its disabled tenants in its Tenant Data System (“TDS”) and that NYCHA’s Property Managers do not maintain complete lists of tenants with physical disabilities. Finally, we found that NYCHA has poor controls over its inventory of generators.

At the exit conference, NYCHA officials stated that NYCHA has made strides in its emergency preparedness and is addressing many of the issues identified in this audit report. The Director of Emergency Preparedness also stated that NYCHA is in the process of rolling out a new emergency plan. This rollout is expected to take five years. The Emergency Procedures Manual will continue to be a guide for emergency preparedness during the rollout process.

Audit Recommendations

To address these issues, we recommend among other things that NYCHA:

• Develop and implement an emergency preparedness plan to include an overall view of NYCHA’s capabilities and potential hazards for major emergencies, and identify its resources, critical services, and the operations needed before, during, and after an emergency. The plan should include:
  • Defined roles and responsibilities for emergency management leadership.
  • Distinct hierarchy and levels of command and control for every type of emergency.
  • Clear instructions on when the Incident Command System should be used and for those instances, the instructions for the establishment of an incident commander and a hierarchy of support staff using the ICS.
  • Specific methods of disseminating critical information to NYCHA employees regarding their roles and responsibilities for various types of emergencies.
  • A communication plan that includes specific methods of dissemination of emergency information to NYCHA employees, residents, relevant City agencies, and community groups.
• Require each development to adhere to the Emergency Procedures Manual and develop, maintain, and continually update a staffing plan for maintaining essential services in the event of an emergency. For each development employee, the staffing plan should include contact information, home location, and means of reporting to work if public transportation is not available. The plan should also include specific guidelines and procedures for the staff to follow.
• Ensure that information on all disabled occupants is current and consistently and accurately recorded and reported in each of the relevant systems, files, and lists. This includes the number of disabled occupants residing at the location, the type of disability, and the emergency contact information.
• Develop a plan that will ensure that all emergency contact information for the disabled tenants is accurate and is being properly updated in NYCHA’s TDS.
• Maintain an accurate record of NYCHA staff attempts to contact disabled tenants in the event of an emergency and whether or not contact was made.

Agency Response

In its response, NYCHA stated that it is “committed to protecting the welfare of its residents. . . . We have enhanced our emergency management programs to plan for, manage and recovery [sic] from major disasters. . . . Due to the time period for this audit, we believe the findings and recommendations miss significant improvements NYCHA has made in relation to its emergency preparedness and response.” In addition, NYCHA stated that many of the audit’s recommendations are “in agreement with NYCHA’s current preparedness actions.”

We strongly support NYCHA’s commitment to protecting the welfare of its residents and are pleased that it has taken concrete steps to improve its capacity to respond to emergencies. We note, however, that many of the programs NYCHA describes in its response have not been completed or tested and that some will take as long as five years to roll out. This is particularly troubling since Hurricane Sandy struck more than three years ago, which means that some of the fixes won’t be fully implemented until eight years after the disaster. We also note with concern that NYCHA does not directly respond to any of our findings, including particularly the inaccurate information we found in NYCHA’s tenant database concerning tenants with disabilities, the inaccurate information we found in NYCHA’s records concerning the number and location of emergency generators, and the differing understandings among staff at every level in the developments regarding their roles and the roles of others in NYCHA in case of different types of emergencies. Absent NYCHA taking into consideration and addressing the findings we have made in this audit, its reformulated emergency response plans are at significant risk of encountering the exact same problems encountered when Hurricane Sandy hit, thereby causing the residents to needlessly suffer yet again. The full text of NYCHA’s response is included as an addendum to the report.