HUD posted slides and a recording of a webinar explaining the expanded use of combining Rental Assistance Demonstration (RAD) with unique features of the Section 18 disposition regulations as presented in Notice PIH 2021-07 (see Memo, 1/25).
In short, HUD drastically changed provisions in the earlier Notice PIH 2018-04 allowing a public housing agency (PHA) to convert anywhere from 40% to 80% of the units in a RAD project to Project-Based Vouchers (PBVs) under Section 18. The percentage of units eligible for disposition within a RAD project is based on the “hard construction costs” of the proposed rehabilitation or new construction. Hard construction costs include overhead and profit, payment and performance bonds, and “general requirements.”
Although Notice PIH 2021-07 makes only indirect reference to the large RAD notice guiding the entire RAD program, residents in units in a RAD project that are converted under Section 18 must have all of the RAD resident protections afforded to their neighbors in the “regular” RAD units. Protections include: no permanent displacement, relocation assistance if temporary relocation is needed to rehabilitate units, right to return, no rescreening upon returning, $25 per unit for resident participation activities, right to organize, and the right to the Housing Choice Voucher program grievance and termination procedures.
PIH began allowing 25% of the units in a RAD project to convert PBVs under Section 18 in PIH Notice 2018-11 on July 2, 2018. The new notice further accelerates PIH’s public housing “repositioning” policy (see Memo, 11/19/18).
The webinar slides are at: https://bit.ly/3v0srll
The webinar recording is at: https://youtu.be/p2wOjO1V2rs
Notice PIH 2021-07 is at: https://bit.ly/365eeZs
Notice PIH 2018-04 is at: https://bit.ly/3o6YHP1
More information about Section 18 Demolition/Disposition is on NLIHC’s public housing webpage at: https://bit.ly/2XZle5H
More information about public housing repositioning is on page 4-30 of NLIHC’s 2020 Advocates’ Guide.