HUD released Revision 3 of the Notice implementing the Rental Assistance Demonstration (RAD). Notice PIH 2012-32/H 2017-03 REV-3 provides instructions for implementing the RAD program. In a RADBlast email, HUD lists 16 major changes to RAD’s first component that pertains to public housing.
RAD is intended to preserve and improve low income housing by enabling public housing agencies (PHAs) to leverage Section 8 rental assistance contracts to raise private debt and equity for public housing capital improvements. RAD has two components. The first allows up to 185,000 public housing units to be converted from their existing public housing assistance to project-based vouchers (PBVs) or to Section 8 project-based rental assistance (PBRA) by September 30, 2018. The second component allows private properties assisted through the Rent Supplement (Rent Supp), Rental Assistance Program (RAP), Moderate Rehabilitation (Mod Rehab), and Mod Rehab Single Room Occupancy (SRO) programs to convert an unlimited number of Tenant Protection Vouchers (TPVs) to PBRA, or as of the FY15 Appropriations Act, to PBVs.
Several of the major changes listed by HUD that pertain to residents include:
- Eliminating the cap on the number of PBV units at a project (the current cap is 50%).
- Improving the quality of information that PHAs must provide to residents of properties undergoing conversion and requiring PHAs to submit responses to resident comments in connection with meetings held following the issuance of a Commitment to enter into a Housing Assistance Payments (CHAP) contract.
- Extending the prohibition on tenant re-screening of current public housing households who will live in non-RAD PBV or non-RAD PBRA units placed in a project that contains RAD PBV or RAD PBRA units in order to facilitate tenants’ right to return to the assisted property.
- Correcting the phase-in of rents for residents who may experience a rent increase as a result of conversion to ensure a more even distribution across years.
- Providing greater detail on the acceptable forms by which a public or nonprofit entity can demonstrate ownership or control of a RAD-converted property.
- Providing guidance on owners’ responsibilities to treat lead-based paint hazards in the context of a RAD conversion.
The RADBlast also indicates that the Notice encourages PHAs and their partners to grant current workers whose employment positions may be eliminated during conversion the right of first refusal for new employment openings for which they are qualified.
NLIHC will carefully review and assess all of the changes and, if warranted, provide more detail in a future Memo to Members.
PIH 2012-32/H 2017-03 REV-3 is at: http://bit.ly/2ipEF3v, and a redline version showing the changes in the Notice is at: http://bit.ly/2ilCquQ
More information about RAD is on page 4-13 of NLIHC’s 2016 Advocates’ Guide at: http://bit.ly/22QZiEm and on the National Housing Law Project’s website at: www.rad-watch.org