Use NAHRO’s Survey to Comment on BABA by April 15

By: Andrew Van Horn, Policy Analyst

Comments due April 15, 2024

As part of its ongoing implementation of the Build America, Buy America Act (BABA), HUD has published a new request for information (RFI). The RFI consists of five key questions that will help HUD and its federal partners implement the Build America, Buy America Act. Any requests any data or evidence you can provide that would help estimate the cost of BABA in terms of price and timing of project.

The topics listed above include specific questions. Responses can address specific materials covered by BABA or general data that would inform HUD’s implementation. The RFI emphasizes that responses should be as specific as possible and include specific data wherever possible.

NAHRO’s General Comments

NAHRO’s general comments about BABA are as follows:

  1. Difficulties securing contractors and partner organizations,
  2. Compliance and reporting burden concerns,
  3. The new definition of housing as infrastructure, and
  4. Cost and supply chain concerns.

In line with these concerns, NAHRO performed an online survey, which resulted in 304 responses from 274 unique housing and community development organizations who receive HUD funding for infrastructure projects. The results of this survey are below.

Below are the percentages of respondents buying each of the covered materials as defined by BABA.

Reach out to NAHRO if you are curious with any requests for survey results by agency size or funding stream.

Data to Include in Your Response

In order to finish implementing BABA—including potentially issuing new waivers—HUD requests data and tangible evidence showing the cost of BABA in terms of dollars and time. Please include any of the following information in your request:

  • Market conditions for the products you purchase—including whether materials are available and the proportion of those materials made in America,
  • Lead times for materials covered in the law,
  • The dollar amount that complying with the law would raise prices, and
  • Any other specific data that illustrates the potential effects of BABA.

Please comment on any of the RFI’s questions for which you have information.

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