ICP v. HUD Small Area FMRs
Comment on HUD, "Establishing a More Effective Fair Market Rent System;
Area Fair Market Rents in Housing Choice Voucher Program Instead of the Current
FMRs," 81 Fed. Reg. 39218 (June 16, 2016), Docket Number FR-5855-P-02
ICP comment on Docket Number FR-5855-P-02
This ICP comment supports the
required use of SAFMRs as a remedy for racial segregation in the voucher
program. However, HUD’s proposal to limit the areas for SAFMR designation using
arbitrary and artificial formulas will perpetuate racial segregation. ICP’s comment
sets out in detail the objections to the HUD proposed method for designating
areas for SAFMR use.
ICP v. HUD - Complaint
ICP v. HUD- First Amended Complaint
Guidance for preparing comments on Small Area FMRs
For the first time HUD is making available guidance
for allowing 40% of the units in a zip code to be made available with its Small
Area FMRs (SAFMR). The Guidance on HUDUSER at this link http://www.huduser.org/portal/datasets/fmr.html allows a commenter
to follow the steps using HUD Zip Code Tabulation Area (ZCTA) Distribution data
(available at this link http://www.huduser.org/portal/datasets/fmr.htmlor from HUD) and see the percentage of 2 BR
units made available with HUD’s proposed SAFMRs. The HUD Guidance provides step
by step instructions on how to perform the analysis in order to comment to HUD
on the units made available with HUD’s proposed SAFMR for a particular ZCTA.
If a proposed SAFMR for
a ZCTA does not make 40% of the units available a commenter can point this out
to HUD and HUD will adjust the SAFMR upward for that ZCTA to make 40% of the units
available. This opens up additional units in high opportunity areas with low
poverty and opportunity for jobs and education. In addition, if a HUD proposed
SAFMR for a ZCTA makes over 40% of the units available which is usually the case
in ZCTAs in racially concentrated areas of poverty, the guidance allows a
commenter to point this out to HUD. HUD will then adjust the SAFMR to lower it
to make only 40% of the units in that ZCTA available.
For assistance on using
the Guidance please contact us.