Comment Submitted by Christine Lewis, Housing Works

Thank you for this opportunity to comment on ending the “Hold Harmless” policy in calculating income limits under Section 8. After review of the published Notice and discussing with other housing authorities and multifamily tax credit subsidized property managers, we continue to be very much in favor of the “Hold Harmless” policy. Our main concern for ending the “Hold Harmless” policy in calculating income limits pertains to multifamily tax subsidy properties (MTSPs). It was stated in the notice that language in HERA would protect existing MTSPs. We saw no indication that future developments would be likewise protected. Declines in median incomes and allowable rents while expenses remain the same or increase would adversely impact multifamily properties. Again, thank you for this opportunity to express our opposition to ending the current “Hold Harmless” policy. Christine Lewis Housing Affairs Manager Housing Works 405 SW 6th Street Redmond, OR 97756 541-323-7404