Comment Submitted by Jonathan Zimmerman, NAHRO

July 19, 2010 Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street, SW., Room 10276 Washington, DC 20410-0001 Re: [Docket No. FR-5413-N-01] Section 8 Housing Choice Voucher Program--Demonstration Project of Small Area Fair Market Rents in Certain Metropolitan Areas for Fiscal Year 2011 To Whom It May Concern: On behalf of the National Association of Housing and Redevelopment Officials (NAHRO) and its members, we would like to thank you for the opportunity to comment on the Department’s proposed Section 8 Housing Choice Voucher Program--Demonstration Project of Small Area Fair Market Rents in Certain Metropolitan Areas for Fiscal Year 2011. Since HUD’s proposed small area Fair Market Rent (FMR) demonstration will be used only in the Section 8 Housing Choice Voucher (HCV) program and will not affect rents in any other HUD or federal program, NAHRO’s comments are confined to the HCV program. In addition to our July 19, 2010 comment letter, there are two other related documents attached that we are including as part of our comments to HUD's proposed small area FMR demonstration. One document is NAHRO's comment letter on September 2, 2009, and the other document is NAHRO’s Housing Choice Voucher Program Regulatory and Administrative Reform Recommendations (March 2010). If you have any questions, please feel free to contact me at 202-289-3500 or via e-mail at jzimmerman@nahro.org. Thank you for your consideration of our comments. Sincerely, Jonathan Zimmerman Senior Policy Advisor – Housing Assistance Programs / NAHRO