Comment Submitted by Kitsap County Consolidated Housing Authority dba Housing Kitsap

HUD should continue to use the Methodology it used in Fiscal Year (FY) 2023 to calculate the renewal funding inflation factors (RFIFs). Using an average of 2.337% does not adequately take into account individual Housing Authorities housing markets, and will, in fact, cause the program to be further reduced, as those with lower costs may not adequately utilize their funds, and those with higher costs will continue to be under funded. It is illogical to penalizing a housing authority for local land use policies or other regulatory policies and land use practices that they have no control over. This potential penalty of reducing a Housing Authority's renewal funding inflation factor is not productive, as this will not impact the policies HUD intends to impact. Further, this can have the effect of limiting the availability of rental assistance for those areas that may need it most. If HUD is intent on changing replacement funding factors from Housing Agency to Housing Agency, is could base these criteria on practices and policies the Housing Authorities actually have control over, such as mobility practices that encourage movement to higher economic opportunity areas, or other policies that support increased economic independence for the households served. HUD should focus its efforts to increase housing supply by implementing the 21st Century Road to Housing Act efficiently and quickly (within the next 12 months) Thank you for your consideration, Heather Blough, Executive Director Kitsap County Consolidated Housing Authority dba Housing Kitsap