Comment Submitted by Robin Amadon, Amadon Consulting

Please see Attached File with Comment regarding my strong encouragement to sustain the Hold Harmless policy in calculating income limits that relate to low-income housing development that utilizes tax credits, bonds, federal, state, county and city resources to sustain and produce housing to meet the needs of lowest income citizens. This proposed change will make tax credit equity investors so skittish that it could effectively kill the ability to underwrite deals and create public/private partnerships that have successfully developed low-income housing across our nation since the tax credit program began. In addition, the shift in incomes limits and eligibility, ultimately affecting rent levels, will jeopardize the break-even operating economics on which most low-income developments depend. Finally, predictability is a key feature of our ability to attract private equity into public/private partnerships. HUD's proposed change overturns decades of success in this endeavor and threatens the ability of jurisdictions to produce housing targeted at providing permanent solutions to homelessness. Projects to meet this need require a complex blend of resources and those resources need a common income eligibility and rent level protected against year-to-year reductions. Please see my expanded Comment in the attachment included herein. Thank you for your attention. Robin Landy Amadon, Development Consultant, Seattle, WA.