CLPHA earlier in July submitted comments to HUD in response to the agency’s Small Area Fair Market Rents Notice of Proposed Rulemaking urging that the program be made voluntary while stressing the Council’s position that HUD lacks evidence supporting its proposal.
HUD has proposed replacing the current 50th percentile FMRs with Small Area FMRs “to provide HCV tenants greater access to higher opportunity, lower poverty neighborhoods,” according to HUD’s notice. As we informed HUD in our comments, a “significant majority of the current 50th percentile FMR areas include CLPHA members and a number of our members have used Moving to Work (MTW) flexibility to implement submarket payment standards. Our comments are grounded in that experience.”
Among CLPHA’s concerns is the relative lack of data HUD behind HUD’s proposal. As we wrote: “HUD is indicating an intention to move forward with requiring a subset of housing authorities to set their payment standards based on SAFMRs, before obtaining significant data from the SAFMR Demonstration… This is not the way to make evidence-based policy.”
More fundamentally, CLPHA’s position is that the use of SAFMRs should be up to the PHAs themselves. “HUD should make use of SAFMRs entirely voluntary. It should enable housing authorities to make local decisions about the best ways to serve their communities.”
In addition, we expressed our position that all FMRs should be set at the 50th percentile level, including SAFMRs. “Voucher holders deserve access to units that rend for up to the median price for a given area,” we wrote in our comments.