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woucher
KS.
/
$8 terms
approve the
a project. However, to the extent that PHAs use this option, it results in voucher holders having to reside
in a project for one year before they are eligible to move. Thus, there is some reduction in voucher
benefits resulting from mobility and choice.
makes
We note that project-basing of units is likely to concentrate voucher holders in fewer properties, but this
HE but
effect is minimized as long as project-basing in each PHA remains capped at 15 percent of the vouchers.
?
that
We note that the incentive for good operation is considerably weakened by the commitment to replace
they
departing voucher holders and by the payments for vacant units. The latter also works against the goal of
choice?
have
increasing voucher utilization and reduces tradeoff the number of voucher holders aided at a given level of
cess
appropriations.
currentpolity
payment
allowspetas
to
pug
for
1
inspections
required
$at ther
mode
Our greatest concern is that PHAs will use project to create new 100 percent subsidized projects
mergin must
at rents that are not based on the market and are
ner than those set for other voucher holders. We see
what
in this at least the potential for collusive arrang
between PHAs and developers that would conflict
disirition
with the interests of tenants and ultimately damage the program's reputation through a subsequent
at
scandal.
if
it's
could reduce Shborhood to 25%
in
poverty
existing
authority
We also are concerned that Barbara's carefully crafted proposal could be readily modified on the Hill,
either initially or over time, to favor the interests of developers over those of program recipients. If PHAs
and development interests find project-basing attractive, they may try over time to raise the percentage
cap; and, if they find the voucher holder's option to move creates cash flow problems for these properties,
they may attempt to restrict their option to leave a bad property.
At a minimum, we would recommend the following changes to the proposal, in priority order: up to 10 at
discretion BPHAS- eliminate requirement
statute
1.
Restrict
the
term
of
assistance
contracts
with
whe to the existing five years rather than the
now requies
proposed 10 years (with renewal at PHA
or
years
(for
HPVs)
If
the
goal
is
to
address
a
ownebt
cyclical problem of tight market conditions,
more and better properties, in a greater rang
ive years is sufficient. We also think that owners of accerval. accept
me
locations, would be more interested if they are not
locked in for such a long period. In fact, we wonder about the motives of owners/developers who
dispecting
would enter into such a long-term deal with a one-sided renewal option. For the Government, a
shorter contract period reduces the risks associated with long-term entanglements with particular)
properties and owners.
we reduced the MSts w/ chone K
2. Cap the percentage of units in any one property that can be covered by a project-basing contract to term
25 percent of the units in all cases, not just for the HPV component. This reduces the risk of
not
concentration and of creating projects that are developed primarily because the PHA has ensured
option
continued cash flow to the project from subsidy holders and not because the developer thinks the
cannot
property can be supported over a long period by the market. NONPROFIT DEVELOPERS
ensure
3. Restrict rents to the local payment standard fo: other vouchers and consider applying the
project-based comparability test now in statute for other project-based Section 8 subsidies or another
as long
market test to limit rents. This reduces the risk of subsidizing properties in excess of their market
as
too
low it
value and of non-competitive, above-market deals between PHAs and developers.
4.
Restrict the payment for vacant units to 30 day with an option for the PHA to extend for another 30
you're
days only if it has failed to deliver an accepts numbe of voucher holders in that time period. This
restricting
in
eal
minimizes the reduction in voucher utilization and encourages quick replacement of departing voucher
the
we are only
holders. why is reasonableness? this better rent
capping
sprobably would serve
Fpl. at market neighborhod
mode
developed
Message Copied To:
need to proposea change.
how is this prevented?
under unit statute
PHAS can dothis
now continuos
can be about where they're based
Barbara's proposal nothing only if it helps wf decomentrat high pruty 100
only to > 5090 if in wish joint growth area
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"ocrText": "woucher\nKS.\n/\n$8 terms\napprove the\na project. However, to the extent that PHAs use this option, it results in voucher holders having to reside\nin a project for one year before they are eligible to move. Thus, there is some reduction in voucher\nbenefits resulting from mobility and choice.\nmakes\nWe note that project-basing of units is likely to concentrate voucher holders in fewer properties, but this\nHE but\neffect is minimized as long as project-basing in each PHA remains capped at 15 percent of the vouchers.\n?\nthat\nWe note that the incentive for good operation is considerably weakened by the commitment to replace\nthey\ndeparting voucher holders and by the payments for vacant units. The latter also works against the goal of\nchoice?\nhave\nincreasing voucher utilization and reduces tradeoff the number of voucher holders aided at a given level of\ncess\nappropriations.\ncurrentpolity\npayment\nallowspetas\nto\npug\nfor\n1\ninspections\nrequired\n$at ther\nmode\nOur greatest concern is that PHAs will use project to create new 100 percent subsidized projects\nmergin must\nat rents that are not based on the market and are\nner than those set for other voucher holders. We see\nwhat\nin this at least the potential for collusive arrang\nbetween PHAs and developers that would conflict\ndisirition\nwith the interests of tenants and ultimately damage the program's reputation through a subsequent\nat\nscandal.\nif\nit's\ncould reduce Shborhood to 25%\nin\npoverty\nexisting\nauthority\nWe also are concerned that Barbara's carefully crafted proposal could be readily modified on the Hill,\neither initially or over time, to favor the interests of developers over those of program recipients. If PHAs\nand development interests find project-basing attractive, they may try over time to raise the percentage\ncap; and, if they find the voucher holder's option to move creates cash flow problems for these properties,\nthey may attempt to restrict their option to leave a bad property.\nAt a minimum, we would recommend the following changes to the proposal, in priority order: up to 10 at\ndiscretion BPHAS- eliminate requirement\nstatute\n1.\nRestrict\nthe\nterm\nof\nassistance\ncontracts\nwith\nwhe to the existing five years rather than the\nnow requies\nproposed 10 years (with renewal at PHA\nor\nyears\n(for\nHPVs)\nIf\nthe\ngoal\nis\nto\naddress\na\nownebt\ncyclical problem of tight market conditions,\nmore and better properties, in a greater rang\nive years is sufficient. We also think that owners of accerval. accept\nme\nlocations, would be more interested if they are not\nlocked in for such a long period. In fact, we wonder about the motives of owners/developers who\ndispecting\nwould enter into such a long-term deal with a one-sided renewal option. For the Government, a\nshorter contract period reduces the risks associated with long-term entanglements with particular)\nproperties and owners.\nwe reduced the MSts w/ chone K\n2. Cap the percentage of units in any one property that can be covered by a project-basing contract to term\n25 percent of the units in all cases, not just for the HPV component. This reduces the risk of\nnot\nconcentration and of creating projects that are developed primarily because the PHA has ensured\noption\ncontinued cash flow to the project from subsidy holders and not because the developer thinks the\ncannot\nproperty can be supported over a long period by the market. NONPROFIT DEVELOPERS\nensure\n3. Restrict rents to the local payment standard fo: other vouchers and consider applying the\nproject-based comparability test now in statute for other project-based Section 8 subsidies or another\nas long\nmarket test to limit rents. This reduces the risk of subsidizing properties in excess of their market\nas\ntoo\nlow it\nvalue and of non-competitive, above-market deals between PHAs and developers.\n4.\nRestrict the payment for vacant units to 30 day with an option for the PHA to extend for another 30\nyou're\ndays only if it has failed to deliver an accepts numbe of voucher holders in that time period. This\nrestricting\nin\neal\nminimizes the reduction in voucher utilization and encourages quick replacement of departing voucher\nthe\nwe are only\nholders. why is reasonableness? this better rent\ncapping\nsprobably would serve\nFpl. at market neighborhod\nmode\ndeveloped\nMessage Copied To:\nneed to proposea change.\nhow is this prevented?\nunder unit statute\nPHAS can dothis\nnow continuos\ncan be about where they're based\nBarbara's proposal nothing only if it helps wf decomentrat high pruty 100\nonly to > 5090 if in wish joint growth area"
}