Comment Submitted by Anonymous

HUD should not consider local land use and housing policies when adjusting the RFIFs. PHAs have no control over these policies and should not be penalized for perceived influence of such policies on local rents. As stated in this notice, there are many factors that influence local rents beyond local land use and housing policies; it would be impossible to reasonably identify what percentage of rent inflation (if any) is attributable to any one factor. In states hit hardest by natural disasters, for example, rents increase dramatically due to construction and insurance costs, limited housing supply, displacement of tax base, etc. Additionally, local policies may be in place to address other housing factors or regulatory needs specific to an area. Having a one-size-fits-all approach and then penalizing housing providers serves no one. At a time when housing costs continue to skyrocket making housing less affordable for middle and low income families, reducing housing assistance only serves to worsen affordability. The federal government can best address housing shortages and rising rents by encouraging development in underserved areas, incentivizing affordable rents, and by quickly implementing provisions of the 21st Century Road to Housing Act. Finding ways to increase housing supply along with increasing wages, is the best approach to addressing rising housing costs. PHAs and HCV programs are already facing funding shortfalls. The changes proposed in this notice would only increase the financial burdens on families and providers.