SUFFICIENCY EFFORTS. THE BILL LANGUAGE DOES NOT PROVIDE SUFFICIENT GUIDANCE ON HOW THIS PROVISION WILL BE COORDINATED WITH STATE WELFARE REFORM REQUIREMENTS AS WELL. DUE TO THE DIVERSE REQUIREMENTS IMPOSED BY STATES IN ORDER TO COMPLY WITH WELFARE REFORM REQUIREMENTS, MANDATING A WORK REQUIREMENT COULD PLACE LHAS IN PRECARIOUS POSITIONS.

THIS PROVISION WILL RESULT IN WORK THAT IS UNRELATED TO OPPORTUNITIES THAT WILL ENSURE SELF SUFFICIENCY ON THE PART OF RESIDENTS. THIS PROVISION WILL ALSO RESULT IN CONFLICTS BETWEEN LHAS AND UNIONS AS WORK REQUIREMENTS INFRINGE ON UNION-RELATED JOBS.

PLACING MANDATORY TERM LIMITS ON HOUSING ASSISTANCE WILL PLACE LHAS
IN A PRECARIOUS POSITION WHEN ATTEMPTING TO ASSIST RESIDENT EFFORTS
TOWARDS SELF SUFFICIENCY.
BY PLACING LHAS IN A POSITION OF
ENFORCING THE TERM LIMITS PROVISION, LHAS COULD LOSE THE LEVEL OF
TRUST NEEDED TO HELP RESIDENTS MOVE UP AND OUT. ADDITIONALLY, THE
PROVISIONS ASSUMES THAT RESIDENTS WILL NOT VACATE UNITS ON THEIR
OWN VOLITION WHEN THEIR EARNINGS AND, CONSEQUENTLY, THEIR HOUSING
OPTIONS INCREASE.

SEC. 106. LOCAL HOUSING MANAGEMENT PLANS.

NAHRO SUPPORT ALL OF THE PROVISIONS IDENTIFIED IN THE BILL EXCEPT THE REQUIREMENT FOR AN ALLOCATION PLAN FOR ELDERLY/DISABLED HOUSING. NAHRO ALSO OPPOSES THE PROVISION THAT WILL ALLOW THE SECRETARY TO ESTABLISH ADDITIONAL REQUIREMENTS IN THE PLAN.

SEC. 107. REVIEW OF PLANS.

NAHRO SUPPORTS THE PROVISIONS OF THIS SECTION WITH A MODIFICATION OF THE PUBLIC COMMENT PERIOD TO 30 DAYS AND THE TIME PERIOD FOR HUD DISAPPROVAL TO 45 DAYS.

SEC. 108. REPORTING REQUIREMENTS.

NAHRO SUPPORTS THIS PROVISION.

SEC. 109. PET OWNERSHIP.

NAHRO OPPOSES THIS PROVISION. NAHRO BELIEVES THAT DECISIONS TO ALLOW PETS WITHIN UNITS SHOULD BE LEFT TO LOCAL AGENCIES TO DECIDE. SEC. 110. ADMINISTRATIVE GRIEVANCE PROCEDURE.

NAHRO SUPPORTS THIS PROVISION.

SEC. 113. NONDISCRIMINATION.

NAHRO STRONGLY SUPPORTS THIS PROVISION.

SEC. 114. PROHIBITION OF USE OF FUNDS.

NAHRO SUPPORTS THIS PROVISION.

TITLE II · PUBLIC HOUSING

SUBTITLE A BLOCK GRANTS

SEC. 201. BLOCK GRANT CONTRACTS.

NAHRO SUPPORTS THIS PROVISION OF THE BILL. NAHRO BELIEVES A
FLEXIBLE BLOCK GRANT PROVIDES A MORE EFFICIENT MEANS OF
DISTRIBUTING FUNDS TO LOCAL AGENCIES.

SEC. 202. GRANT AUTHORITY, AMOUNT AND ELIGIBILITY.

NAHRO SUPPORTS THE FLEXIBILITY TO USE UP TO 20 PERCENT OF CAPITAL FUNDS FOR OPERATING EXPENSES. AT A TIME OF DIMINISHING FEDERAL RESOURCES, NAHRO BELIEVES LHAS SHOULD BE PROVIDED WITH FLEXIBILITY TO USE PORTIONS OF ITS FUNDS IN A MANNER THAT IS BENEFICIAL TO THE SUCCESSFUL OPERATION OF THE AGENCY.

SEC. 203. ELIGIBLE AND REQUIRED ACTIVITIES.

NAHRO DOES NOT SUPPORT REQUIRING LHAS TO VOUCHER OUT DISTRESSED PROPERTIES. NAHRO BELIEVES THAT LHAS, IN CONSULTATION WITH LOCAL COMMUNITIES, SHOULD DETERMINE THE APPROPRIATE USE OF A DEVELOPMENT. NAHRO DOES SUPPORT THE ELIGIBLE ACTIVITIES DESCRIBED IN THIS SECTION.

SEC. 204. DETERMINATION OF GRANT ALLOCATION.

NAHRO SUPPORTS THE PROVISION THAT WILL CONTINUE THE USE OF EXISTING ALLOCATION FORMULAS UNTIL NEW FORMULAS ARE DEVELOPED. NAHRO BELIEVES THAT THERE SHOULD BE INDUSTRY INPUT INTO ANY RELEVANT STUDIES CONDUCTED BY THE DEPARTMENT PRIOR TO COMMENCEMENT OF NEGOTIATED RULE MAKING.

SUBTITLE B - ADMISSIONS AND OCCUPANCY REQUIREMENTS

SEC. 222. FAMILY ELIGIBILITY.

NAHRO SUPPORTS PROVIDING LHAS WITH THE FLEXIBILITY TO DETERMINE ELIGIBILITY REQUIREMENTS FOR PUBLIC AND ASSISTED HOUSING. NAHRO DOES NOT BELIEVE THE FEDERAL GOVERNMENT IS THE APPROPRIATE ENTITY TO DETERMINE ELIGIBILITY STANDARDS FOR A LOCAL PROGRAM. ANY ELIGIBILITY REQUIREMENTS SHOULD APPLY TO THE AGENCY PROFILE AND COMMUNITY NEEDS.

SEC. 223. PREFERENCES FOR OCCUPANCY.

NAHRO STRONGLY SUPPORTS THE ELIMINATION OF FEDERAL PREFERENCES AND FLEXIBILITY TO CREATE LOCAL PREFERENCES TO BETTER SERVE LOCAL NEEDS.

SEC. 224. ADMISSION PROCEDURES.

NAHRO SUPPORTS THIS PROVISION.

SEC. 225. FAMILY CHOICE OF RENTAL PAYMENT.

NAHRO HOLDS FIRMLY TO ITS BELIEF THAT LHAS SHOULD HAVE THE FLEXIBILITY TO DETERMINE RENT STRUCTURES THAT REFLECT TENANT'S ABILITY TO PAY AND LOCAL CONDITIONS. AS PART OF THAT FLEXIBILITY, NAHRO SUPPORTS A MINIMUM RENT THAT GOES UP TO $50 AND THE FLEXIBILITY TO INCLUDE A HARDSHIP PROVISION WHERE APPROPRIATE.

NAHRO ALSO SUPPORTS LHA FLEXIBILITY TO RECERTIFY INCOME BASED ON LOCAL NEEDS AND POPULATION. FOR LHAS WITH A SIGNIFICANT AMOUNT OF ELDERLY WITH LITTLE CHANGE OF INCOME, COULD WARRANT RECERTIFICATION EVERY TWO YEARS UNLESS THE TENANT'S INCOME IS REDUCED OR CHANGES MORE THAN 10 PERCENT.

LAST YEAR, NAHRO AGGRESSIVELY SUPPORTED THE ELIMINATION OF THE BROOKE AMENDMENT. NAHRO BELIEVED THAN, AND WE MAINTAIN THAT BELIEF, THAT THE BROOKE AMENDMENT IS A DISINCENTIVE TO WORK. NAHRO MAINTAINS ITS POSITION OF ELIMINATING THE BROOKE AMENDMENT AND PROVIDING LHAS WITH THE FLEXIBILITY TO DEVELOP RENT STRUCTURES THAT ARE APPROPRIATE FOR LOCAL COMMUNITIES.

HOWEVER, NAHRO UNDERSTANDS THE POLITICAL REALITY THAT THE
ELIMINATION OF THE BROOKE AMENDMENT WILL NOT OCCUR WITHIN THE
NEXT FEW YEARS. CONSEQUENTLY, NAHRO WILL WORK WITH TO FASHION AN
AGREEMENT ON RENT REFORM AND TARGETING THAT SATISFIES ALL
PARTIES.

NAHRO DOES NOT BELIEVE THAT THE APPROACH TAKEN IN H.R. 2 IS APPROPRIATE. FIRST, GIVING RESIDENTS THE OPTION TO CHOOSE THEIR RENTAL PAYMENT RUNS COUNTER TO EVERY MANAGEMENT PRINCIPLE THAT IS FOLLOWED IN THE PRIVATE OR PUBLIC SECTOR.

SECOND, PART OF THE ADDITIONAL RESPONSIBILITY PLACED ON LHAS IS TO HELP CURRENT RESIDENTS BECOME SELF SUFFICIENT AND PREPARE THEM FOR LIFE IN THE "REAL WORLD". HOW WILL THIS PROVISION ACCOMPLISH THAT PURPOSE? RESIDENTS WILL BE IN FOR A RUDE AWAKENING AS THEY SEEK HOUSING IN THE PRIVATE MARKET WHEN THEY REALIZE THEY CAN NOT CHOOSE THEIR RENT PAYMENT. OUR CHALLENGE AS MANAGERS OF PUBLIC AND ASSISTED HOUSING SHOULD BE TO DEVELOP RENT STRUCTURES THAT ARE AFFORDABLE BUT REALISTIC IN PREPARING RESIDENTS FOR THE PRIVATE MARKET.

THIRD, THIS POLICY HAMPERS A LHA'S ABILITY TO DEVELOP A RENT STRUCTURE THAT MAKES SENSE FOR ITS DEVELOPMENTS. A LHA WOULD SIMPLY HAVE TWO OPTIONS, A CEILING RENT OR 30 PERCENT OF INCOME. WHAT IF AN AGENCY WANTED TO DEVELOP A TIERED RENT STRUCTURE? THIS PROVISION IS SIMPLY ANOTHER EXAMPLE OF MICROMANAGEMENT THAT WILL NOT WORK.

FINALLY, THIS PROPOSAL COULD RESULT IN A LOSS IN OPERATING REVENUE FOR AGENCIES. ASSUMING THAT EACH RESIDENT CHOOSES THE LEAST EXPENSIVE PAYMENT OPTION, LHAS WILL LOSE REVENUE THAT CURRENTLY HELPS TO OFFSET EXPENSES NOT COVERED BY EXISTING LEVELS OF OPERATING SUBSIDY. AT A TIME WHEN WE ARE STRUGGLING TO ADJUST TO REDUCED LEVELS OF OPERATING SUBSIDIES, YOUR PROPOSAL WILL ADD TO THE FINANCIAL CHALLENGES LHAS ALREADY FACE.

SEC. 226. LEASE REQUIREMENTS.

NAHRO SUPPORTS THE PROVISIONS OF THIS SECTION WITH THE EXCEPTION OF 14-DAY NOTICES. NAHRO RECOMMENDS THAT LHAS FOLLOW LOCAL LAW IN ALL CASES. IN CASES WHERE THERE IS NO LOCAL LAW, THEN THE 14DAY NOTICE SHOULD APPLY.

SEC. 227. DESIGNATED HOUSING.

AS STATED EARLIER, NAHRO OPPOSES ANY REQUIREMENT THAT CALLS FOR AN EXPLANATION ON HOW FAMILIES ON THE WAITING LIST NOT HOUSED AS A RESULT OF DESIGNATION WILL BE SERVED.

SUBTITLED - HOMEOWNERSHIP

SEC. 251. RESIDENT HOMEOWNERSHIP.

NAHRO SUPPORTS LOCALLY DESIGNED EFFORTS TO IMPROVE HOMEOWNERSHIP OPPORTUNITIES FOR RECIPIENTS OF OUR PROGRAMS. NAHRO BELIEVES THAT ANY DETAILS REGARDING RESALE RESTRICTIONS AND RECOUPMENT OF FUNDS SHOULD BE LOCAL DECISIONS, BASED ON LOCALLY DESIGNED PROGRAMS. NAHRO IS CONCERNED THAT NON FEDERAL FUNDS MAY BE CONTRIBUTING TO THE LOCAL PROGRAM THAT WOULD HAVE COMPETING REQUIREMENTS.

SUBTITLE E ·

DEMOLITION, SITE REVITALIZATION, REPLACEMENT HOUSING, AND CHOICE BASED ASSISTANCE GRANTS FOR DEVELOPMENTS

SEC. 261. DEMOLITION.

NAHRO SUPPORTS THIS PROVISION. NAHRO BELIEVES THAT LHAS SHOULD DETERMINE THE APPROPRIATE USE OF A BUILDING AND/OR DEVELOPMENT IN CONSULTATION WITH THE LOCAL COMMUNITY.

SEC. 262. SITE REVITALIZATION.

NAHRO SUPPORTS THE DIRECTION OF THIS SECTION WHICH IS TO REDUCE

DENSITY AND DECREASE THE CONCENTRATION OF VERY LOW INCOME FAMILIES. NAHRO BELIEVES THAT CLARIFICATION OF THE TERMS MAJOR RECONSTRUCTION AND MAJOR REDESIGN IS NEEDED TO MEAN MORE THAN JUST GUT REHABILITATION. NAHRO OPPOSES THE 5 PERCENT MATCH REQUIREMENT. NAHRO IS CONCERNED THAT WITH LIMITED RESOURCES, A MATCH REQUIREMENT COULD IMPEDE THE DEVELOPMENT OF NEEDED PROJECTS AND ADD ADDITIONAL CONDITIONS OR REQUIREMENTS BY THE PARTY PROVIDING MATCHING FUNDS.

NAHRO ALSO BELIEVES THERE NEEDS TO BE ADDED FLEXIBILITY ON THE PERCENTAGE ALLOWED FOR SUPPORTIVE SERVICES. THERE COULD BE VARYING DEGREES OF SUPPORT SERVICES NEEDED FOR VARIOUS TYPES OF FAMILIES SUCH AS ELDERLY, DISABLED OR LARGE FAMILIES. MANY OF THE PROJECT DESIGN TO DATE HAVE FOCUSED A GREAT DEAL OF ATTENTION ON TRYING TO ASSIST RESIDENTS IN THEIR RELOCATION EFFORTS. IN SOME CASES, THERE IS CONSIDERABLE NEED FOR SUPPORTIVE SERVICES TO FACILITATE RELOCATION.

SUBTITLE F GENERAL PROVISIONS

SEC. 271. PAYMENT OF NON-FEDERAL SHARE.

NAHRO SUPPORTS THIS PROVISION.

SEC. 272. AUTHORIZATION OF APPROPRIATIONS FOR BLOCK GRANTS.

NAHRO BELIEVES THAT THE AUTHORIZED LEVEL $2.5 BILLION FOR FISCAL YEARS 1998 THROUGH 2002 IS DANGEROUSLY LOW GIVEN THE NEED THAT EXIST IN LOCAL COMMUNITIES. WITH THE UNCERTAINTY OF WELFARE REFORM AND CONTINUED EFFORTS TO BALANCE THE FEDERAL BUDGET, LHAS NEED, AT LEAST $3.2 BILLION IN OPERATING FUNDS FOR FISCAL YEARS 1998 THROUGH 2002.

SEC. 273. FUNDING FOR OPERATION SAFE HOME.

SEC. 274. FUNDING FOR RELOCATION OF VICTIM OF DOMESTIC VIOLENCE.

NAHRO OPPOSES SET ASIDES WITHIN EXISTING PROGRAMS. NAHRO BELIEVES THAT LHAS SHOULD BE ALLOWED TO USE BLOCK GRANT FUNDS IN A WAY THAT ADDRESSES LOCAL NEEDS. SIMILAR TO THE MANNER IN WHICH THE COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM OPERATES, LHAS SHOULD DETERMINE THEIR NEEDS IN A GIVEN YEAR AND ALLOCATE FUNDS ACCORDINGLY. NAHRO IS ALSO CONCERNED THAT THE WITNESS RELOCATION PROGRAM IDENTIFIED IN SECTION 273 IS A DUPLICATION OF EXISTING PROGRAMS FUNDED BY OTHER DEPARTMENTS.

TITLE III - CHOICE-BASED RENTAL HOUSING AND HOMEOWNERSHIP
ASSISTANCE FOR LOW-INCOME FAMILIES

SUBTITLE A- ALLOCATION

SEC. 301. AUTHORITY TO PROVIDE HOUSING ASSISTANCE AMOUNTS.