Comment on DOD-2009-OS-0090-DRAFT-0022

I would like to comment on eligibility requirements. 239.6 The rule states eligibility is based on economic impact, timing, price, orders, and submission of application. Applicants have to have suffered at least a 10% market impact zone home value loss between July 1, 2006 and date of application for Expanded HAP benefits for the county/parish/city in which thier primary residence is located. Homeowners, like myself, followed the initial guidance when the program was first announced. The written guidance and telephone interaction with USACE reps encouraged members to submitt applications as soon as possible. I think we will be penalized by doing so if the "date of application" is used in determining economic impact. In my case specifcially, my house was placed on the market in Jan 09 and did not sell until Sept 09. My application for Expanded HAP benefits was submitted in Fec 09 however. The timeframe from listing the property to selling it contains valuable indicators of local market conditions and will be omitted if the rule goes unchanged. Suggestion 1: Delete the "date of application" from the requirement Suggestion 2: If the "date of application" goes unchanged, then better guidance should be issued as to what consitutes a 'complete' application. In my specifice case, I submitted documents all the way up closing the sale of my property. Suggestion 3: If teh "date of application? goes unchanged, then in the case of private sale, the date of application should be adjusted to closing date of sale of property.