Comment Submitted by Christine Gouig

The draft regs in part define existing housing as "There is no plan to perform rehabilitation work on the units within one year after HAP contract execution... that would total more than $1,000 per assisted unit.... If a tenant vacates a unit within one year after HAP execution (we understand the tenant has an initial one-year lease but suppose the PHA terminates the tenant for program violation, the owner evicts the tenant, tenant passes away, etc.) an owner should have the abililty to do more than $1,000 work of work on the unit. Just to do a simple "unit turnover"-- painting, cleaning and perhaps recarpeting-- would cost more than $1,000. A responsible owner would "have a plan" to do such work upon tenant move-out. Further, a unit could pass HQS but then if, in the first year, a tenant moved out for the type of reasons listed above an owner could want to take the opportunity to do a more complete rehab (e.g., kitchen and bath upgrades).