NAHRO Policy Team Blog

  • Emily Pasi September 12, 2011 03:52pm EDT

    On the evening of Thursday, September 8, the House Appropriations Subcommittee marked up the FY 2012 Transportation-HUD spending bill. The Senate Appropriations Subcommittee is expected to mark up its version of the FY 2012 THUD at some point this week. 

    The House bill limits the compensation of PHA employees; cuts funding for the Public Housing Operating Fund, Public Housing Capital Fund, and HOME; and provides no funding for Hope VI or Choice Neighborhood programs.  The bill provides a 5 percent increase in CDBG funding compared to FY 2011; however, bill language reduces the CDBG administration and planning cap from 20 to 10 percent.

    The THUD bill is not expected to come up in front of the Full House Committee for some time. In the meantime, proposals for amendments have been offered by both Democrats and Republicans—an unusual development in subcommittee markup proceedings.

    Rep. David Price (D-N.C.) offered an amendment requiring HUD to submit an operating reserve offset plan for approval by House and Senate Appropriations Committee within 30 days of the THUD’s bill passage.  

    To view the draft of the subcommittee bill, click here.

    NAHRO will continue to provide you with the latest information regarding the progress of the FY 2012 markup process.

  • Emily Pasi September 06, 2011 11:52am EDT

    On Wednesday, August 31, HUD Secretary Shaun Donovan announced five grantees will receive Choice Neighborhoods implementation funding totaling $122 million.  The recipients are the Cities of Boston, Chicago, New Orleans, San Francisco, and Seattle. The as-yet unauthorized Choice Neighborhood Initiative is the administration’s proposed replacement for the established Hope VI Program, which is dedicated to revitalizing public housing.

    Attention NAHRO members! The latest edition of the NAHRO Monitor was recently released on Wednesday, August 31. Be sure to read “NAHRO Urges HUD to Abandon Offset Proposal” as well as other up-to-the-minute news from Washington. 

    NAHRO has responded to the August 17, 2011 OpEd piece in the Wall Street Journal by James Bovard entitled “Raising Hell in Subsidized Housing.” In a letter to the WSJ, NAHRO’s CEO Saul Ramirez addressed the concerns NAHRO had regarding the accuracy of the statements Mr. Bovard made in his piece. A copy of the letter can also be found here:

    Finally, registration for NAHRO’s 2011 National Conference and Exhibition in St. Louis, MO is open. Sign up here to take advantage of early bird registration rates!

  • Jeff Falcusan September 01, 2011 09:29am EDT

    NAHRO members:  Be sure to check out our August 30 Direct News item, which provides updates on the administration's operating reserves offset proposal as well as HUD's initiative to collect PHA compensation information.  

    Even if you're not a NAHRO member (we'd of course love for you to change that), we strongly encourage you to read NAHRO CEO Saul Ramirez's August 29 letter to HUD Secretary Shaun Donovan on the offset proposal.  The letter urges the Secretary to abandon the proposal and instead embrace NAHRO's alternative to fund the Operating Fund at a responsible level for 2012. 

    Here are some key excerpts from NAHRO's letter: 

    The Department’s embrace of the proposed offset represents a breach of trust between HUD and the nation’s public housing professionals. Although senior HUD officials repeatedly claimed that the Department pushed back against the imposition of the offset, we know now that events unfolded in a much different manner, culminating in the inclusion of a $1 billion offset proposal in the President’s budget request.  And after spending months analyzing the proposal and the data provided by the Department intended to justify it, we have no choice but to conclude that HUD has essentially manufactured the concept of “excess” reserves for the sole purpose of delivering on $1 billion in savings prematurely and rashly promised to the White House... 

    In the interest of full disclosure, NAHRO is now in possession of the FY 2012 Office of Management and Budget passback, and we are aware that the Department, to its credit, initially requested $4.962 billion for the Operating Fund for 2012, a figure that represents 100 percent of estimated operating subsidy eligibility for the upcoming year.  We also know that OMB denied HUD’s request, with the passback instead providing $4.462 billion and assuming an offset of $500 million “based on operating reserves greater than three months of…PHAs’ 2012 subsidy eligibility under the Operating Fund formula.” 

    While it would appear that OMB played a role in originating the offset proposal, NAHRO notes that the passback invited the Department “to provide justification for a lower offset” if the Department “believe[d] the passback offset… [was] too high.”  We note also that the passback proposed several additional offsets that the Department could have accepted in order to “cover the difference” and restore the Operating Fund request for 2012 to 100 percent of formula eligibility.  Unfortunately and surprisingly, rather than opposing the imposition of a $500 million offset against PHAs’ operating reserves and appealing to OMB for the restoration of full funding to the Operating Fund for 2012, it is now clear to us that the Department not only abandoned its original request and embraced the proposed offset, but ultimately recommended to OMB that the offset be doubled from $500 million to $1 billion. This represents, frankly, a stunning and deeply disappointing reversal...

    Surely, the Department is well aware that this concept of so-called “excess” reserves is a fiction.  Furthermore, the Assistant Secretary’s overly simplistic characterization of PHA reserves as “rainy day” funds that exist only for management and operation purposes is easily refuted.

    HUD’s own policies disprove the Department’s political leadership’s claims surrounding so-called “excess” reserves.  As you know, HUD intends to implement the offset based on PHA year-end financial statements dating from June 2010 to March 2011.  During the time period reflected by these statements, PHAs were assessed under the PHAS II rule, which defined optimal reserve levels as up to the equivalent of 11 to 15 months of expenses, depending on agency size.   Under the PHAS II rule, the Department imposed a penalty on PHAs with reserve balances below the optimal range. And while a small scoring penalty was imposed on agencies with reserves above the optimal range, there has been absolutely no statutory, regulatory, or administrative limitation on the amount of reserves that PHAs may accumulate since the Department issued PIH Notice 1995-7, over sixteen years ago, in order to administratively remove the maximum allowable operating reserve level.

    Using the 2008-2009 FDS data provided by the Department, NAHRO estimates that only approximately $364 million in reserves nationwide exceeded the optimal thresholds defined by HUD for the point in time the data reflects.  Furthermore, of this amount, $161 million was held by agencies with fewer than 250 units of public housing.  This distinction is important, because QHWRA provided small PHAs with total interoperability and fungibility between Operating and Capital Funds, giving these agencies the ability to save up over time in order to accumulate sufficient reserves to complete important capital projects like roof replacements and new boilers.  For these small agencies, the Department is well aware that reserves represent much more than a backstop that would allow agencies “to continue to effectively manage and operate their public housing properties if ever there were a rainy day.” Indeed, for small agencies, the offset proposal is perhaps the ultimate “rainy day”: a perfect storm of irresponsible public policy that threatens to forever wash away small agencies’ ability to physically maintain their public housing units as safe, decent, and affordable housing for low-income families...

    On February 22, the Assistant Secretary transmitted a letter to every PHA executive director in the country warning them of the “potentially dire consequences” of spending down reserve balances.  Despite the fact that no new rulemaking was undertaken or notice issued, the letter contradicted longstanding regulatory and administrative policy by stating that “Operating Reserve balances may only be used for Operating Fund purposes and cannot be used for capital or modernization activity as defined within the United States Housing Act of 1937.”  The letter emphasized that “there is a strong possibility that the reserve estimate used to determine a PHA’s potential offset could be based on prior year financial statements,” a reminder clearly intended to produce a chilling effect on PHAs’ reserve expenditures. 

    On April 15, the counsel to the three public housing industry groups transmitted a letter to the Assistant Secretary that, among other purposes, took issue with the February 22 letter’s directive that operating reserves not be used for modernization.  The letter reviews the numerous administrative and regulatory policies that support the industry’s belief “that substantial capital work can be undertaken with operating funds,” including operating reserves.  We remain convinced that the administration’s proposal to effectively confiscate reserves, in combination with HUD’s sudden onset of amnesia regarding the use of operating subsidy for expenditures such as property betterments and extraordinary maintenance, will short-circuit the ability of PHAs to maintain their public housing units and ameliorate to a small extent the negative consequences of inadequate capital subsidy.    NAHRO notes that the Department has not yet responded to the April letter. 

    There is no disputing that the February letter’s blanket assertion concerning the use of reserve balances for capital or modernization activity is demonstrably false as it pertains to agencies with fewer than 250 units of public housing.  Section 9(g)(2) of the 1937 Act, as amended by QHWRA, clearly states that non-troubled PHAs with less than 250 units may use capital or operating funds interchangeably for any eligible capital or operating expense.  Small PHAs receive small annual funding allocations; these agencies must accumulate funds over a period of years in order to make major purchases.  Because Capital Funds must be obligated within two years, small PHAs typically transfer these funds to operations in order to comply with statutory timelines and enable effective capital planning. 

    NAHRO has repeatedly urged the Department to formally clarify that the ability of small PHAs to use operating reserves for Capital Fund-eligible activities is embedded in statute and has not changed.  On February 28, a senior HUD official notified NAHRO by email that the Department would make such a clarification as part of forthcoming guidance advising PHAs on the eligible uses of operating subsidy and reserves.  On March 1, this same official advised NAHRO that the Department was reviewing a draft of the guidance and hoped to issue it within 48 hours.  Nearly six months later, the Department has failed to issue this guidance and has still done nothing to formally clarify that key portions of the February letter were not applicable to small agencies...

    NAHRO continues to believe that the most judicious course of action would be to fully fund public housing operations for 2012 through direct appropriations.  If, however, the Congress insists on identifying savings as provided for under the Administration’s proposal, then a more prudent approach should be considered.  To that end, we note that on several occasions the Assistant Secretary has encouraged public housing industry groups to put forward an alternative to the administration’s offset proposal.  NAHRO took this charge seriously and has shared a proposed alternative with the Congress. 

    Although the approach NAHRO suggests would still result in what we consider to be an inadequate level of federal investment in the public housing program, NAHRO’s proposed alternative would lessen the threat of irreparable harm to the public housing inventory.  Furthermore, NAHRO’s approach would affect all agencies proportionately, rather than impose ill-conceived penalties for responsible and entrepreneurial behavior. We therefore urge you to abandon the proposed offset and instead lend your support to NAHRO’s proposal, which would provide PHAs with an estimated 95 percent proration for 2012 while still producing a total of $1 billion in savings by combining direct appropriations for the Operating Fund with a rescission against prior year unobligated balances throughout the Department...

    Again, we strongly urge all PHAs to read NAHRO's letter to the Secretary in its entirety.  If you have any comments, questions, or concerns regarding the letter, please feel free to email me

  • Jonathan Zimmerman August 31, 2011 11:13am EDT
  • Emily Pasi August 09, 2011 01:35pm EDT

    On Monday, August 8, HUD and the Department of the Treasury released the Obama Administration’s July Housing Scorecard. The scorecard provides a comprehensive look at the nation’s housing market. The results of the scorecard continue to paint a murky picture of the nation’s housing situation. For the full report, click here.

    In other news, NAHRO recently participated in a stakeholder’s meeting to discuss the Administration’s efforts to improve affordable rental housing programs by reducing duplicative regulations. A Rental Policy Working Group has begun to draft preliminary policy proposals and is looking for your help! NAHRO is seeking feedback from members to inform our comments.  Please send your suggestions to policyresearch@nahro.orgby August 26, 2011. 

    Attention NAHRO members! With Summer Conference behind us, it is time to look forward towards NAHRO’s National Conference. This year’s National Conference will be held in St. Louis, MO on October 23-25, 2011.  Be on the lookout for information about registration coming soon!

  • Emily Pasi August 05, 2011 02:04pm EDT

    On August 3, NAHRO issued a statement on the agreement to increase the nation’s debt ceiling. Issued on behalf of NAHRO, Saul N. Ramirez Jr. NAHRO CEO, made the Association’s position clear that while it is relieved the debt ceiling crisis was resolved, the agreement does nothing to alleviate the $26 billion backlog in public housing capital needs nor does it address any other longstanding housing and community development needs. For the full statement, click here.

    On Thursday, July 28, HUD Secretary Shaun Donovan announced the availability of $95 million in competitive grants to support sustainable local initiatives through the FY 2011 Regional Planning and Community Challenge Planning Grant Programs from HUD’s Office of Sustainable Housing and Communities. In its second year, the DOT, the EPA, and HUD continue to encourage communities to strive for collaborative redevelopment and revitalization progress.

    In other news, Maine is the first state to ban smoking in all of its housing authorities state-wide. With 250 housing authorities across the country already on board, the momentum to ban smoking is growing.

    Finally, San Antonio Housing Authority’s non-profit arm, Education Investment Foundation, will honor 23 low-income students with $1,500 scholarships at tonight’s “Rising Stars” Banquet. Students will be recognized for their outstanding academic achievements in the face of diversity.


  • Emily Pasi July 28, 2011 05:11pm EDT

    Tomorrow is day two of NAHRO’s 2011 Summer Conference and attendees will not have a moment to rest with all that’s in store for them. NAHRO’s prestigious Awards of Merit given to innovative housing authorities will be showcased from 8 to 9:30 a.m.  Beginning at 10 a.m., conference goers will be able to choose from a list of 12 exciting and informative sessions ranging on topics from legislative advocacy to strategies for acceptability compliance. 

    Don’t miss This Just In from Washington—Part II Friday from 2:45 to 4:15 p.m. Hosted by NAHRO Policy and Program Development staff, This Just In from Washington—Part II will offer a comprehensive review of regulatory and programmatic development in the housing and community development industry. This session will focus on the latest policy proposals regulations issued by HUD and other federal agencies.

    For the full list of sessions available, click here.

    Wondering what there is to do after the sessions end? We have just the treat for you! Discover the best of the great state of Kentucky at Friday Night Live: A Taste of Kentucky from 7 to 9:30 p.m. To see the entire schedule of events, click here.

  • Emily Pasi July 28, 2011 10:48am EDT

    Today marks the start of the 2011 NAHRO Summer Conference in Louisville, KY. The day kicked off with featured speaker, Judge Greg Mathis—famous television personality and Civil Rights activist.  Day one of the Conference will be busy for attendees with 12 sessions planned throughout the morning and afternoon. 

    Be sure to catch the latest updates on the Administration’s Operating Reserves Offset Proposal from 10:15-11:45 a.m. NAHRO staff, Jeff Falcusan and Tamar Greenspan, will explain the political process surrounding the proposal as well as a technical assessment of the information available on HUD’s implementation plans. For a complete list of today’s sessions, click here.

    Continue to watch for Conference updates right here!

  • Emily Pasi July 27, 2011 02:47pm EDT

    As you know, this week NAHRO is hosting its annual Summer Conference in Louisville, Kentucky. NAHRO recognizes that not all of our members are able to attend the Summer Conference, so we are bringing the conference to you. On Thursday and Friday, I will be reviewing the list of sessions for the day as well as giving a brief synopsis of topics covered in each session. For those of you at the Conference, let us know what you found most informative in break-outs! Be sure to read the blog Thursday and Friday for the latest Conference updates!

    Don’t forget: This summer, anyone who registers for a NAHRO seminar will be eligible to win an iPod Shuffle! A winner will be randomly selected for each seminar held in July and August. Click here to register.

    In other news, HUD announced its 2011-2012 Fair Housing Accessibility FIRST Program’s Training Cycle yesterday. The aim of the program is to provide training and technical guidance to help architects and builders comply with the accessibility requirements for the Fair Housing Act. HUD’s Fair Housing Accessibility FIRST Program is slated to start on August 22, 2011 at the Mississippi Housing Conference.

  • Emily Pasi July 25, 2011 12:23pm EDT

    HUD’s Office of Community Planning and Development will be holding a series of three Consolidated Plan webinars beginning this Wednesday, July 27. The aim of the webinars is to educate grantee staff on the development of new web tools and system upgrades that will help in making future plans more efficient. Each of the three seminars will cover a specific topic—CDBG, Entitlement Grantees and Participating Jurisdictions, and states. All webinars will be held from 2:00-3:30 p.m. EST: 

    Wednesday, July 27 –CDBG-only grantees

    Wednesday, August 3 – Entitlement Grantees and Participating Jurisdictions

    Wednesday, August 10 – States

    HUD and NeighborWorks® America have extended their deadline for the Emergency Homeowners’ Loan Program until this Wednesday, July 27 in an effort to give homeowners in danger of foreclosure more time to apply for the program.  The Emergency Homeowners’ Loan Program provides eligible homeowners assistance with mortgage payments for a specified amount of time.

    Finally, NAHRO needs your help! NAHRO is working with PHADA and CLPHA on a study to model the potential costs of converting public housing to project-based Section 8 contracts. The study is funded by the Housing Authority Insurance Group and conducted by Recap Advisors. In order to complete the study, NAHRO is asking that members complete a brief data collection tool and submit it directly to the project coordinator at Recap.  Remember, this could have a significant effect on your housing authority’s future, so participate today!