Comment Submitted by Mike McLoone, Mayor's Office of Housing, City & County of San Francisco

The City & County of San Francisco supports the proposal to end the "Hold Harmless" policy in calculating income limits under Section 8. The departments working within local government in San Francisco to create and maintain affordable housing have taken the position that altering the "raw" calculations of Area Median Income is generally inappropriate. One reflection of this policy stance is that since 2001, for most of the local housing programs, San Francisco has used HUD's calculation of Area Median Income that is "unadjusted" for "high housing cost". There is no perfect process for setting income eligibility and rents in affordable housing. While well-intentioned, the efforts to mitigate the negative impacts of the use of AMI via "hold harmless" and other special exceptions only complicate operations in a field that is already complex. In addition, when the impact of the mitigations result in calculations of AMI that are higher than what is derived from the data from the Census and the American Community Surveys, low-income tenants wind up bearing a real heavier rent burden without the benefit of any of the artificially-inflated income. These side-effects raise serious questions about the appropriateness of the remedy. The City & County of San Francisco recognizes that there is a legitimate basis for seeking a solution that would prevent any year-to-year reductions in the income that affordable housing projects can generate. However, San Francisco believes that the solution for achieving this goal should be created without manipulating the calculations of Area Median Income.