Comment Submitted by Robert Pearson, Housing Authority of the City of Santa Barbara

We view the following proposed rule changes as positive: No resident survey; Basing financial sub-indicators on public housing financial data only, rather than using entity-wide amounts, and having a firm threshold for these sub-indicators, rather than scoring on a curve which changes over time; No longer considering agencies which score over 60 but fail one indicator (such as financial) as troubled; Not designating individual projects which score below 60 as troubled; Reducing the value of the economic self-sufficiency indicator from 7 points to 1 and the security indicator from 4 to 1; Automatically giving properties scoring an ‘A’ in certain sub-indicators, such as leasing, an ‘A’ in related sub-indicators, such as vacancy turnaround. However, we view the following rule changes as ones that will reduce the accuracy of the PHA's assessment: 1. Not providing any accommodation in the scoring to account for less than 100 percent funding. 2. Not providing a three year hiatus in the physical inspection when a property scores well as is done in multifamily. 3. The addition of the “Appearance and Market Appeal” sub-indicator worth five points in the management indicator, since it is duplicative of the physical inspection and scored subjectively. 4. Establishing more stringent standards for several sub-indicators, such as requiring a 98 percent occupancy rate, turning tenant-generated work orders around in 3 days, and completing vacancy turnaround in 15 days, to get an ‘A’ in these respective sub-indicators. 5. Scoring the economic self-sufficiency and security sub-indicators on criteria that HAs cannot control, such as the percent of eligible adults working and the project’s crime rate in relation to the surrounding neighborhood. 6. Increasing the value of the leasing sub-indicator alone to 16 points. 7. Establishing an ‘Accounts Payable’ sub-indicator in the management component that requires payment of 100 percent of non-disputed bills within 30 days in order to get an ‘A.’ 8. The elimination of the Board of Review process for appeals of either PHAS scores or troubled designation. We thank you for the opportunity to be able to submit these comments.