Comment Detail

Comment

In response to the 41 questions:
Question 18: The advantage of limiting the total amount awarded to one sponsor is that it ensures that the funds will be spread out over more projects, which will effect a larger geographic area. Most sponsors have specific types of housing they develop, and providing too much funding to one sponsor would be at the detriment of other types of projects that one sponsor may not do.
Question 28: This would be going in the wrong direction. It is extremely difficult to develop housing for 50% AMI or below. The only models to do so are projects with rental subsidy or extremely large projects. Rental subsidy is limited and large projects are not feasible for all areas or populations, thus increasing the number of units requiring very-low income tenants may reduce housing opportunities to those areas or populations.
We often find that our 80% AMI units end up being occupied by a 50% AMI individual with subsidy. However, we cannot design an operating proforma on rent levels appropriate for 50% AMI folks.
Question 32: Our concerns with this change is the same as above. Requiring lower AMI customers is not feasible for most projects that rely only on development (not rental) subsidy. This will knock a lot of good projects out of contention, leaving only projects that might not be conducive to serving some of the populations you are seeking to serve.
Question 31: This seems to run counter to many HUD programs that discourage the concentration of special needs populations in specific projects, which arguably runs afoul of fair housing law. It would be better to encourage 20%-30% of the units be set aside for special needs populations, so as to integrate these populations into the community as much as possible. A better measure would be the quality and scope of the services provided to the special needs populations.