Comment Submitted by Ryan Parker

Re: Docket No. FR-6607-N-01 / HUD-2026-0958 Section 8 Housing Assistance Payments Program - Fiscal Year (FY) 2026 Inflation Factors for Public Housing Agency (PHA) Renewal Funding As an American citizen and a resident of Dakota County, Minnesota, I strongly object, on principle, to HUD's FY 2026 Renewal Funding Inflation Factor methodology. I also strongly oppose changing the FY 2027 methodology to discount local inflation adjustments based on HUD's judgment that local land-use, permitting, or development policies have constrained housing supply. This creates a serious appearance that HUD is politicizing a housing-funding formula that should be neutral, objective, and based on the actual cost of keeping people housed. That concern is especially troubling given the Trump administration's broader federal-funding actions directed at Minnesota and other Democratic-led states. Low-income Americans who depend on Section 8 do not deserve to become collateral damage in political conflicts between the administration and state or local governments. HUD forecasts that the national average per-unit cost of the Housing Choice Voucher program will increase by 2.337 percent in 2026. HUD's own published Fair Market Rent for a two-bedroom unit in the Minneapolis-St. Paul-Bloomington area increased from $1,685 in FY 2025 to $1,709 in FY 2026. Yet strangely, HUD assigned this area, which includes Dakota County, a 2026 RFIF of 1.000000. That is a zero-percent adjustment under this inflation factor. The attached official HUD tables document these figures. This makes no practical sense. I live in Dakota County and see the effect of high housing costs on people with low and fixed incomes. A formula that recognizes a 2.337 percent increase in voucher costs nationally, and a rise in HUD's own local Fair Market Rent, but provides no local inflation adjustment fails to reflect the reality faced by local renters and public housing agencies. I understand HUD will not revise the FY 2026 factors through this comment process. However, this result shows why the methodology must be corrected before future funding cycles. The Housing Choice Voucher program exists to help low-income people afford safe, stable housing. Renewal funding should reflect the actual cost of keeping them housed, not be reduced to pressure local governments over zoning, permitting, or development policy. Discounting a local inflation adjustment would not primarily punish the officials or planning departments responsible for those policies. It would punish low-income families and individuals who depend on Section 8 assistance to remain housed. Voucher recipients do not control zoning laws, permitting delays, construction costs, interest rates, utility costs, housing supply, or decisions made by governments and developers. If HUD provides less renewal funding than local rental conditions require, foreseeable consequences include fewer vouchers, longer waiting lists, greater difficulty finding units within payment standards, and increased risk of displacement, housing instability, or homelessness. Families with children, seniors, people with disabilities, veterans, low-wage workers, and people on fixed incomes would bear those consequences. They should not be used as leverage in a dispute between HUD and local governments. HUD's notice acknowledges that local rent growth may result from factors beyond a jurisdiction's control, including changes in demand, construction costs, interest rates, utility costs, and tenant income. It would be extremely difficult to determine how much of a rent increase was caused by local regulation and translate that into a fair reduction in voucher funding. An inaccurate formula could misclassify communities while harming people who had no role in creating the problem. If HUD wants to encourage less restrictive zoning, faster permitting, or more housing construction, it should use separate grants, incentives, technical assistance, or other measures directed at the government entities that control those policies. It should not withhold needed inflation funding from public housing agencies or make housing less secure for low-income Americans. I urge HUD to correct the RFIF methodology so local factors reflect actual housing costs; reject any method that discounts local inflation adjustments because of zoning or permitting policies; base renewal funding on documented rents, utility costs, tenant incomes, and the cost of maintaining existing voucher assistance; protect voucher households and public housing agencies from future land-use adjustments; and publish all data, assumptions, calculations, and classifications with a meaningful appeal and correction process. Housing assistance should respond to the costs citizens actually face. It should not become a punishment mechanism that harms low-income families and individuals for political or policy decisions they did not make and cannot control.