August 15, 2016
Helen R. Kanovsky, General Counsel
Regulations Division, Office of General Counsel
Department of Housing and Urban Development
451 7th Street, SW, Room 10276
Washington, DC 20410-0500
Re: “Establishing a More Effective Fair Market Rent System; Using Small Area Fair Market Rents in Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs,” 81 Fed. Reg. 39218 (June 16, 2016)
Dear Ms. Kanovsky and colleagues,
We are writing to support HUD’s proposal to implement Small Area Fair Market Rents (SAFMRs) in selected metropolitan areas, and to offer our suggestions for improving the proposed rule from the perspective of a housing mobility program that has been operating in an extremely high cost county (Westchester County, NY) for over two decades. Our experience with a pilot implementation of SAFMRs over the past two years is that the published SAFMR rent levels are insufficient to give our clients meaningful access to many high opportunity areas of the County. Accordingly, our comments are primarily focused on the importance of providing an easy and flexible approach to adjusting exception payment standards within SAFMRs.
