Comment Submitted by Reid Gilliam

Rental prices have been increasing around the country for the past couple of years, and they are likely to continue increasing. The demand for rental properties has risen substantially as home ownership declines under the weight of millions of non-performing mortgages. Coupled with low levels of new construction, this rising demand is resulting in large drops in rental vacancy rates. This phenomenon portends continued increases in asking rents and effective rents in most areas around the country. The 2012 proposed Fair Market Rents are, on average, 2.4% lower than the finalized 2011 values based on a simple average of county-level comparisons. This is inconsistent with the trends of rising rents. Although the primary use of the HUD Fair Market Rents is to determine threshold values for voucher eligibility, researchers use these data for other purposes. Establishing 2012 values that are lower than 2011 values renders these data useless for tracking trends in rental prices. There may be quite reasonable arguments that the 2012 values need to be lower than the 2011 values for the Housing Choice Voucher Program and Moderate Rehabilitation Single Room Occupancy Program. However, making these adjustments sacrifices accuracy in tracking historical, current, and future rental prices. As such, I would recommend HUD publish bedroom-specific rental price data for researchers' use independent of the Fair Market Rent data required for these programs. Thank you for your consideration.