A sample comment letter is available from NLIHC touching upon 12 provisions in the proposed changes to the HOME program regulations. NLIHC supports the vast majority of the proposed amendments, which are based on HUD’s experience since regulations last underwent a substantive revision. However, the sample comment letter suggests ways in which five of the provisions should be improved, and expresses opposition to six of the provisions.
In particular, given the shortage of resources available to community housing development organizations (CHDOs), NLIHC is very concerned about a change that would require CHDOs to have full-time paid staff who are experienced housing developers, rather than rely on consultants. Two of the provisions would jeopardize the housing stability of some renters. Another change would reduce on-site physical inspections at multifamily projects to every three years, potentially causing residents to endure years of poor housing quality.
The sample HOME regulations comment letter is available at: www.nlihc.org/doc/Sample_HOME_Regs_Comment_Letter.pdf
NLIHC’s summary of the proposed changes and recording of its January 23 briefing are at: www.nlihc.org/detail/article.cfm?article_id=8417
Materials from HUD are at: www.hud.gov/offices/cpd/affordablehousing/homeproposedrule/index.cfm
Comments are due February 14.