Comment Submitted by Aaron Gornstein, Citizens' Housing and Planning Association

July 19, 2010 Office of General Counsel Attention: 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 Comments on Section 8 Housing Choice Voucher Program – Demonstration Project of Small Area Fair Market Rents in Certain Metropolitan Areas for Fiscal Year 2011 Dear Sir/Madam: Citizens’ Housing and Planning Association (CHAPA) is statewide non-profit housing advocacy organization in Massachusetts. We welcome the opportunity to respond to the recent request for comments on the concept of small area FMRs and on the proposed demonstration project for Fiscal Year 2011. We appreciate HUD’s willingness to tackle the complex challenges involved in changing the FMR system to address two long-standing concerns: the difficulties voucher holders often face trying to access housing in low poverty neighborhoods and the financial inefficiencies that result when units are over-subsidized. We believe small area FMRs can plan an important role in increasing the availability of affordable housing in high-opportunity areas. At the same time, care will be needed to limit negative impacts in areas likely to face FMR reductions as the program goes forward. Zip Codes as Geographic Unit Zip codes represent an improvement in setting boundaries for FMRs in metropolitan areas because they are smaller. They are also much more easily identified by consumers than census tract boundaries. However, zip codes are based on postal delivery routes and are subject to change. In addition, they frequently cross municipal or other boundaries. As a result, neighborhoods and thus rents can vary significantly within a zip code for a variety of reasons (school district or municipal boundaries, access to transit). HUD will need to allow exception rents to accommodate this variation. (It may also want to consider testing an approach that bases the FMR areas on clusters of c