Comment submitted by Paul Ludwick, Maricopa HOME Consortium

The proposed rule for the Consolidated Plan Revisions states that it does non impose a federal mandate on a local government within the meaning of the Unfunded Mandate Reform Act of 1995. Then Section I of the preamble describes the implementation of Sections 568 and 583 of QWARA requiring the jusridiction to describe how it will address the needs of public housing and what financial or other assistance the jurisdiction will provide to improve the operations of a troubled housing agency. Further in this section, the rule states that HUD can disapprove a consolidated plan that does not describe the financial or other assistance it will provide. How can this not be an unfunded mandate? It requires a commitment of public resources, specifically financial resources, to an agency that may not even be an agency of the grant recipient. Maricopa HOME Consortium