HUD Secretary Shaun Donovan announces RAD implementation at the Housing Authority of Savannah, January 2013
In a Federal Register notice yesterday, the Department of Housing and Urban Development (HUD) announced to the public the online publication of revised program instructions for the Rental Assistance Demonstration (RAD) in Notice PIH 2012-32, REV-1.
The Federal Register notice serves several functions, including these:
- It provides background information on RAD and summarizes the changes to the program instructions.
- It requests public comments on the revisions to be sent by e-mail to rad@hud.gov by August 1.
- It explains when the program revisions are effective.
- All revisions not subject to notice and comment are effective today.
- Revisions subject to notice and comment will become effective on August 1 unless HUD receives adverse comments that lead to reconsideration.
- It includes an appendix listing new statutory and regulatory waivers and alternative requirements.
- The waivers and alternative requirements that pertain to public housing conversions under RAD are listed in section I of the appendix. They have a separate effective date of July 12.
Notice PIH 2012-32, REV-1, which fills 230 pages, also contains a brief list of the major revisions made to the original RAD program instructions, which were published on July 26, 2012. For public housing, the list includes four major changes that are subject to 30-notice and comment:
- Providing RAD awards for projects requiring multiphased development to facilitate the assembly of financing (see section 1.9.E)
- Allowing a PHA to apply for a portfolio award for a set of projects if the PHA submits individual completed applications for at least 50 percent of the projects and then submits a completed application for each of the remaining projects within a year (see section 1.9.F and Attachment 1C)
- Expanding eligibility of HOPE VI projects (see section 1.11.C.2.c)
- Allowing PHAs to apply for a joint RAD–Choice Neighborhoods implementation grant under the notice of funding availability (NOFA) for these grants (see section 1.11.C.2.c)
Also for public housing, the list includes five changes that are not subject to notice and comment:
- Eliminating the caps on awards to PHAs and to mixed-finance projects (see section 1.11.C.2.c)
- Exempting awarded projects from scoring under the Public Housing Assessment System (PHAS) to support redevelopment planning and the need for temporary relocation during construction (see section 1.5.I)
- Providing contract rents at fiscal year 2012 rent levels (as posted in the RAD application) for all applications submitted before the end of calendar year 2013 (see sections 1.6.B.5 and 1.7.A.5 and Attachment 1C)
- Allowing PHAs to adjust subsidy (and initial contract rents) across multiple projects to facilitate financing (see sections 1.6.B.5, 1.7.A.5, and 1.9.D)
- Allowing Moving to Work (MTW) agencies applying to convert two or more projects to use their MTW block grant flexibility to set initial contract rents, subject to RAD rent caps and continued service requirements (see sections 1.6.B.5, 1.7.A.5, and 1.9.D)
For a more comprehensive section-by-section summary of changes that HUD has made to the RAD program instructions, see Appendix V of Notice PIH 2012-32, REV-1, which includes two tables, one listing program revisions and the other listing program clarifications. HUD has also posted another very helpful tool—a redline version of Notice PIH 2012-32, REV-1, which highlights all of the changes to the RAD program instructions.
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