ALLIANCE FOR HEALTHY HOMES
From: Don Ryan [mailto:DRyan@AFHH.org]
Sent: Wednesday, September 15, 2004 5:15 PM
To: Comments
Subject: RE: RIN 3064-AC50
September 20, 2004
Mr. Robert E. Feldman
Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th St., NW
Washington, DC 20429
RE: RIN 3064-AC50
Dear Mr. Feldman:
On behalf of the Alliance for Healthy Homes, a national non-profit
organization working to address environmental health hazards in housing,
I am writing in opposition to the Federal Deposit Insurance
Corporation’s August 20, 2004, proposed rule that would exempt some 96%
of all FDIC-regulated banks from many of the requirements of the
Community
Reinvestment Act (CRA).
CRA has helped leverage billions of dollars in resources for decent
and affordable housing over the past two and a half decades. In many
cases, funding leveraged using CRA has improved the physical condition
and affordability of homes, making the living environment more healthful
for lower income occupants.
Housing conditions are an important factor in the health of
occupants. Indoor exposures far exceed outdoor levels for most
pollutants - often by a factor of at least 10 for many pollutants of
concern. Moreover, most people spend about 90% of their time indoors.
Infants and toddlers, whose developing bodies and brains make them most
sensitive to pollutants, spend the most time at home. Older people, who
are very sensitive to environmental toxins, also tend to stay at home
more than most other age groups.
Each year in the U.S., two million people make emergency room visits
for asthma. Damp, cold, and moldy housing is associated with asthma and
other chronic respiratory problems. Pest infestations are also
associated with asthma. In particular, cockroaches have been found to
trigger asthma attacks. Lead poisoning affects some 434,000 U.S.
children. Lead-based paint in older housing is the primary cause of the
disease, which results in reduced intelligence and learning and behavior
problems. Exposures to asbestos particles, radon gas, and carbon
monoxide are far higher indoors than outside. Annually, radon causes
between 15,000 and 22,000 deaths annually in the U.S., according to the
U.S. EPA and the National Academy of Sciences, and carbon monoxide
claims more than 200 lives.
While homes of any age and value can pose serious environmental
hazards, older, low-income properties in substandard condition typically
present the greatest risks. According to the U.S. Centers for Disease
Control and Prevention, there are currently 6 million homes classified
as substandard.
In some places (New Jersey, Massachusetts, and Long Beach, CA, are
ready examples), CRA has been used to convince banks to create
discounted financing programs specifically for lead paint other
health-related repairs.
The FDIC’s proposed new rule would relieving some 2,000 banks - with
total assets of more than $754 billion and branches in more than 18,800
communities - of their obligation to provide investments and services in
low-income areas. This will undermine the ability of advocates for
healthy homes to convince these banks to address these and other issues
of housing condition and affordability. We strongly urge FDIC to
withdraw its proposed rule in the interest of promoting a more healthful
housing stock in low-income communities.
Sincerely,
Don Ryan
Executive Director
Alliance for Healthy Homes
227 Massachusetts Ave. NE #200
Washington, DC 20002
Phone: 202-543-1147
Fax: 202-543-4466
dryan@afhh.org
www.afhh.org
Founded in 1990 as the Alliance To End Childhood Lead Poisoning, we
have expanded our work on lead poisoning prevention to address other
housing-related health hazards.
