Mass Mail Campaign 1: Housing Authority Concerns- Total as of 12/11/08 (3); Comment Submitted by Shannon Barrios, Auburn Housing Authority

Document ID: HUD-2008-0170-0002
Document Type: Public Submission
Agency: Department Of Housing And Urban Development
Received Date: December 09 2008, at 03:14 PM Eastern Standard Time
Date Posted: December 11 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: November 24 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: January 8 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 807d49bf
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This is comment on Proposed Rule

FR–5094–N–02 Public Housing Evaluation and Oversight: Changes to the Public Housing Assessment System and Determining and Remedying Substantial Default

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December 09, 2008 Regulations Division Office of General Counsel Department of Housing and Urban Development Room 10276 451 Seventh St., S.W. Washington, DC 20410-0500 RE: Docket No. FR-5094-P-01 Public Housing Evaluation and Oversight: Changes to the Public Housing Assessment System (PHAS) and Determining and Remedying Substantial Default To Whom It May Concern: Please consider this letter as Auburn Housing Authority’s comments on the above proposed rule. In the comment letter submitted to HUD by PHADA it refers to the organization representing 1900 housing authorities of which I am one. On behalf of the Auburn Housing Authority I want to endorse the comments, observations and recommendations contained in PHADA’s October 15, 2008 letter. This is especially true in the area of HUD taking into account proration of operating subsidy throughout the implementation and scoring under the new rule. Funding levels cannot be divorces, compartmentalized or separated from the ability of a housing authority to comply with all of the requirements and thresholds contained in the proposed rule. I am also concerned about the subjective nature of the Management Indicator. It appears that a majority of what is included under this indicator is covered by the physical inspection. The new scoring method will prevent many well run housing authorities from being able to reach and be designated High Performers. I would also like to highlight and endorse PHADA’s implementation schedule of the rule once it becomes final. Housing authorities will need a full fiscal year under the new requirements to allow them to learn about and comply with the new standards before the first scoring. This will also allow HUD to receive better and more complete information and statistics in regards to the status and condition of each housing authority under the new rule’s criteria. Thank you for considering my comments and those provided by PHADA. Sincerely yours, Shannon Barrios Property Manager