Skip to main content

  • Comment Detail

  • Date: 06/06/18
    First Name: Cynthia
    Last Name: Picone
    Organization: N/A
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA83

  • Comment

    The proposed changes to the AHP program will place urban rental projects that are either new construction or property reuse, including repurposing vacant, blighted, or substandard properties such as former industrial or warehouse buildings or former schools, will be placed at a competitive disadvantage. These are very worthy projects that not only provide much needed affordable housing in our urban areas where new housing construction is high end luxury market rate apartments that are way out of the reach of most renters in terms of affordability, but they also turn around underutilized parcels and buildings that have a negative impact on communities. The new income averaging permitted by the Low Income Housing Tax Credit Program enables projects to essentially self subsidize extremely low income units without an operating subsidy, but this is achieved by permitting the program to house households up to 80% of the area median income. The proposed rule will put these projects at a competitive disadvantage. Financial feasibility often depends on including market rate units in a low income building. This also provides for a mix of incomes, which is a good policy goal in and of itself. I also object to the increase of resources to special needs populations. The greatest need for affordable housing exists for low income renters of all abilities, not just those with special needs.