ICP v. HUD Small Area FMRs
ICP Comment on HUD, "Establishing a More Effective Fair Market Rent System; Using Small Area Fair Market Rents in Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs," 81 Fed. Reg. 39218 (June 16, 2016), 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.
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.html or 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.