Comment Submitted by Anonymous

1. Adjusting the FY 2027 RFIF methodology: HUD should consider a markup of the inflation factor for based on actual housing costs in the most recent two year period. Discounting the inflation factor for any area of the Country (or a State or region) ignores cost of living factors contribute to high housing costs particularly those driven by the conversion of formerly affordable units to be used as vacation and short term rentals, high costs of property taxes that influence the availability of affordable housing generally, and lack of housing capacity within almost all areas of the Country. Areas that tend to be attractive to tourists and retirees from higher costs areas of the Country show a direct impact on the cost of housing, availability of affordable housing and quality of affordable housing which creates a bubble of housing cost inflation driving local residents into cost burdened housing situations and homelessness through no fault of their own. Low income disabled households and seniors cannot out compete with the influx of higher income/higher asset incomers to the community and in most of these communities local governments lack the tools to understand the nuances of competition for housing resources as well as lacking the understanding of the need to balance community resources. Improving the timing and comprehensiveness of the data used to determine the real inflation factor for these communities should give the PHAs serving those communities an improved chance of helping low-income households achieve decent, safe and cost-effective stable housing. 2. What type of factor could HUD incorporate into the RFIF methodology: HUD should look at the comparative availability of long-term versus short-term rentals in communities which also considering the higher cost of construction since the pandemic that has not moderated, and the recent impacts of natural disasters on the availability of housing in areas with documented recent history (particularly the last 10 years) of high impact disasters such as Hurricane Florence, devastating wildfires in the western US, and catastrophic flooding events. 3. Data Sources: State level publicly available data on disaster impacts within a State are a place to start to access data identifying areas of low housing supply & many communities collect data on conditions & comparative availability before & after disasters. HUD can also use statistical information published by State Agencies & State HFAs to analyze housing starts, cost of existing housing, impacts of taxes, insurance costs & other factors. Public information from affordable housing non-profits is published annually & can be compared again publicly available from housing industry groups including the association of realtors and groups like the NLIHC. HUD should also consider trends in population aging as well as trends showing where population is growing from an influx of higher wealth families from other parts of the country spiking housing competition & driving up costs of existing units. Including price-to-construction cost ratios, impacts of tariffs, higher fuel prices & other cost factor that have both direct & indirect impacts on what type of housing gets created in communities is also key. Information is available from State governments, the National Assn of Homebuilders & similar groups is available. 4. State level data & local government associations may publish data on land use restrictions, density requirements and lot size restrictions within communities to help HUD understand how local governments are & are not contributing to reducing housing costs in a given area. 5. Local rent inflation can be assessed regionally & state-by-state using information from utility commissions, census data, interest rates over the last 2 years & documentation on natural disasters within a region. 6. The methodology should take both a year-over-year view & also project a calculation of housing costs for a three-to-five year period based on current trends in construction, cost of materials & changes in population. 7. A cap is artificial & by its nature will further erode the ability of PHAs to receive enough funding to maintain their current portfolio of families not to mention hurt the potential for PHAs to make a dent in the increasing need of eligible households that they cannot address with current funding. 8. If HUD adjusts the methodology to further support large PHAs in urban areas, it will create a disparate impact on poor communities causing more of the lowest income families to be forced into substandard housing, over-crowing & homelessness. Rural areas & small communities have fewer tools to address housing needs without federal help & have few non-profits to fill in the gaps compared to urban areas. 9. HUD must make it easier for PHAs to appeal/amend FMRs & allow conversations with local information. The current methodology is too general & relies heavily on outdated data.