During the week of October 31, advocates communicated significant concerns to HUD concerning the October 17 NOFA on the Tenant Resource Network program, which would distribute $10 million to approximately 20 grantees to educate tenants and preserve HUD-assisted housing (see Memo, 11/4). While pleased with the release of the long-awaited NOFA, advocates are concerned that the list of eligible properties where awardees can work is too restrictive and prescriptive and that the outcome measures for TRN are unrealistic.
“NLIHC appreciates that HUD is trying to target the most at-risk properties but we have come to believe that the list is so narrow that it will leave behind properties that could be preserved with tenant involvement through the TRN,” NLIHC President and CEO Sheila Crowley wrote in a November 3 letter to HUD Secretary Shaun Donovan.
On unrealistic performance measures, Ms. Crowley said in her letter, “NLIHC agrees with HUD’s efforts to ensure these precious resources are well-spent. But, some of the outcome measurements, e.g., that 51% of owners demonstrate knowledge of owner rights and responsibilities, are out of the control of TRN awardees and could set the program up for failure before it has even begun. NLIHC supports eliminating the performance outcomes that awardees cannot reasonably be expected to influence.”
In a November 3 letter from the National Housing Law Project, Deputy Director James Grow urged HUD to make technical corrections to the NOFA, which if done by November 6 would not delay the NOFA’s progress. The NOFA’s list of TRN eligible properties “plays a vital role in determining whether an applicant can even apply for their service area (since the NOFA requires applicants to commit to working in a minimum number of units from the List), the amount of the award, and where the work can be done,” wrote Mr. Grow.
In his critique of the TRN list of properties, Mr. Grow said “First, after comparing the List to local data, some analysts have seriously questioned the accuracy of HUD’s List, even under the stated NOFA criteria. Second, while the concept of creating a List represents a noble attempt to define ‘high risk’ properties, more flexibility is required to account for the conditions actually experienced by tenants and properties located in a wide variety of housing markets with diverse owner motivations.”
The National Alliance of HUD Tenants has also asked HUD to make corrections to the scope of the eligible properties list and performance outcomes. “The Appendix listing ‘eligible properties’ is seriously flawed, and needs to be corrected,” NAHT said in a late-October memo to HUD officials. On the NOFA’s performance outcomes, NAHT wrote to HUD that, “for Performance Based measures to work, they must include realistic End Outcomes, based on what is possible and within the scope of grantees to perform. We are concerned that some of the specific End Outcomes in the NOFA may not meet this test.”
View the NLIHC letter at: http://www.nlihc.org/doc/NLIHC_TRN_Ltr_11-3-11.pdf
View the NHLP letter at: http://www.nlihc.org/doc/NHLP_TRN_Ltr_11-2-11.pdf