Comment Submitted by Tim Sovold, Washington State Housing Finance Commission

See attached letters. Propose that HUD publish only two sets of income limits in FY2010. 1. Section 8 Rental Subsidy limits: these limits would apply only to units with direct section 8 rental subsidy, project-based or voucher and would no longer employ the Hold Harmless provision to allow rental subsidies to be targeted to families most in need of assistance. 2. Multifamily Affordable Housing limits: these limits would apply to all other units in all affordable housing programs, including HOME, CDBG, Tax Credit, Bond and other federal programs and would continue to employ the Hold Harmless provision to ensure continued economic viability of affordable housing projects. These limits should apply for any given county or metropolitan area, regardless of the Placed-In-Service year of that project. Counties with HERA limits in 2008 should continue to employ those limits to all projects in those counties, regardless of the federal program. This would greatly simplify income limits for program administrators, owners, managers and residents and ensure that congressional intent of having federal programs work in-tandem is enhanced. This would also solve significant problems for state, county and city funding housing grant and loan programs that contractually tie income limits to Seciton 8.