NLIHC has prepared a short sample comment letter advocates may use to submit comments to HUD regarding proposed changes to the project-based voucher regulations. On May 15, HUD’s Office of Public and Indian Housing (PIH) issued the proposed rule intended to implement changes made to the project-based voucher program by the Housing and Economic Recovery Act of 2008 (HERA) (see Memo, 5/18).
NLIHC is participating with a broad group of stakeholders preparing detailed, technical comments on a number of complex issues, some of which are important primarily to particular project-based voucher stakeholders. While those details are still being discussed by the large group, NLIHC urges advocates to submit comments pertaining to three simple yet very important general issues:
- HUD proposes to limit the maximum possible period for which a unit can be under a project-based voucher contract to 30 years. All stakeholders agree that this is contrary to the statute, which permits a potentially unlimited number of 15-year contract extensions.
- The preamble to the proposed rule states the intent to provide tenants with a reliable long-term lease unless an owner has a “good cause” to terminate or not renew a lease. However, one paragraph of the proposed regulatory text continues to allow an owner to terminate a lease without good cause.
- Advocates should endorse a provision which would require owners to provide tenants with a one-year notice of intent to not renew a project-based voucher contract.
The sample comment letter and a more detailed explanation are attached to this page.
NLIHC will report on the more extensive list of technical comments when available.
Comments are due July 16, 2012. HUD strongly suggests submitting comments electronically.