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AGENCY TESTIMONY
HPD Deputy Commissioner AnnMarie Santiago testifies on certificate of no harassment program and related legislation
0:19:42
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AnnMarie Santiago, Deputy Commissioner for Enforcement Neighborhood Services at HPD, testified about proposed changes to the certificate of no harassment pilot program and related legislation. She expressed concerns about using administrative orders as criteria for denying certificates and discussed the timeline for program assessment and reauthorization.
- Santiago highlighted legal concerns about using administrative orders as criteria for denying certificates without proper due process.
- She mentioned that HPD will assess the impact of proposed changes (Intro 749) during the period leading up to the program's reauthorization in 2026.
- The testimony also touched on Intro 817, stating that the administration is still reviewing the legislation and will follow up with the council later.
AnnMarie Santiago
0:19:42
Good morning chairs Sanchez and Ariola and committee members.
0:19:46
My name is Anne Marie Santiago, deputy commissioner for enforcement neighborhood services at HPD, and I am joined by my colleague, Young Ju Kim, assistant commissioner for emergency housing services.
0:19:58
Regarding the changes to the certificate of no harassment pilot program, and the criteria for an automatic denial of such certification, a report from HPD on the program and its effectiveness is due to the city council in November 2025, and the program will require reauthorization in 2026 by the city council.
0:20:18
We would like to assess the impact of the change recommended by Intro July during this period, and if appropriate, make any changes to the program during the reauthorization.
0:20:30
On initial assessment, we have some legal concerns that including administrative orders as a criteria upon which to deny the certificate.
0:20:39
We have some legal concerns that including administrative orders as criteria upon which to deny the certificate.
0:20:46
A finding of harassment, unlawful eviction, or arson, which are the current criteria, are determined after due process is given to the owner, and so the department can use these previous findings as a basis for the denial of the certificate without additional investigation or review.
0:21:03
The agency's administrative issuance of an order to correct does not have the same due process history.
0:21:09
Which could, excuse me, which could be problematic in terms of the owner's rights to challenging the finding.
0:21:16
In addition, in the context of the pilot program, permitting a denial of the CONH without a hearing at oath for the issuance of an AEP administrative order to correct specific to correct specifically is contradictory to the intent of the program.
0:21:31
Existing criteria involving the addition of a e of buildings in AEP to the pilot list is fashioned to qualify the building for the pilot after the building has been discharged to avoid any added delays or administrative hurdles to the owner completing the work required under the program under the order.
0:21:50
Regarding intro eight seventeen, we will not be able to take a stance on that piece of legislation today.
0:21:57
The administration is still reviewing and will work with counsel on clear follow ups after the hearing.
0:22:02
Thank you for the opportunity to testify today.
0:22:05
I, along with my colleagues from FDNY and DOB, look forward to answering your questions.