On July 16, CLPHA submitted two sets of joint comments to HUD on proposed changes to project-based voucher regulations. As previously reported, on May 15, the Federal Register published a proposed rule, “The Housing and Economic Recovery Act of 2008 (HERA): Changes to the Section 8 Tenant-Based Voucher and Section 8 Project-Based Voucher Programs.” This proposed rule seeks to establish, in regulation, the HERA reforms made as discussed in a November 24, 2008 notice and also to make other related regulatory changes, particularly to the project-based voucher program.
The proposed rule represented the first occasion to comment on project-based voucher regulations since they were established in 2005. CLPHA was pleased to have this opportunity, as we recognize project-based vouchers as essential tools in the ongoing effort to produce and preserve affordable housing for extremely low-income households. We have been fortunate to be able to work closely with HUD to develop new applications for these tools, in the form of the Rental Assistance Demonstration, and look forward to seeing the program help preserve portions of the public housing stock that are currently at-risk. As the PBV program continues to grow in size, we welcome implementation of HERA provisions designed to facilitate use of PBV and other needed regulatory changes to the program. As seen in the attached comments, there are some places where the proposed rule does not conform to our reading of HERA, some places where the proposed rule might actually make use of the program more difficult, and some areas for clarification that we believe should be addressed in the final rule that are not currently a part of the proposed rule.
For more information, contact CLPHA Research & Policy Analyst Leah Staub.