Endorse Joint Comments on Small Area Fair Market Rents
Prepared by Community Service Society, Legal Aid and New York Housing Conference
DEADLINE AUGUST 12th

Overview of HUD Proposal:

HUD proposes to introduce Small Area Fair Market Rents (SAFMR) to New York City. With promising outcomes in a Dallas demonstration program, HUD proposes new rules for New York City and other regions with high levels of voucher concentration to both encourage and enable voucher holders to move to areas of higher opportunity and lower poverty. Instead of a citywide fair market rent (FMR), rents will be set by zip code. This “cost effective” proposal will raise allowable rents in some zip codes and lower them in others to more accurately reflect housing sub-markets within a region. This proposal is full of promise and may work well in some localities but in a high-cost, extremely low-vacancy city like New York, it will have disastrous consequences. Nearly 56,000 voucher holders’ rental assistance payments would go down.

HUD’s proposal is made without a Section 8 budget increase, so housing “opportunity” for some low-income families will come at the expense of others.  Families who choose to stay in their current homes in low-income areas or those who are unable to move, will literally pay the price of higher rents for families using their voucher in more expensive neighborhoods.  Half of impacted households are elderly and/or disabled with average annual income of less than $15,000. In a red hot real estate market which has driven homelessness to all-time heights and a vacancy rate of 3.4%, classified at emergency level by HUD, finding an apartment at all will be a challenge, even in an only marginally lower-poverty neighborhood.

With 246 zip codes in New York City, this proposal would also be a very complicated and confusing system for new voucher holders and landlords to navigate.

Overview of Recommendations in Joint Comments:

  1. HUD should add vacancy rate to its methodology for selecting SAFMR areas and exempt all areas with vacancy rate below 5%.
  2. HUD’s hypothetical SAFMR should be revised to reflect current market conditions in New York City’s rapidly gentrifying neighborhoods.
  3. HUD should hold harmless all current tenants.
  4. Project based vouchers should be exempt from these new rules.
  5. HUD should delay implementation until a significant budget is available to accompany this proposal and also to allow more time to study a more effective approach to achieve stated goals in low-vacancy areas.

Additional Information:

Endorse Join Comments:

If you support the goals of reducing areas of concentrated poverty and increasing access to high opportunity neighborhoods but are concerned about the proposed rule’s impact on X existing Section 8 households whose subsidy will decrease, forcing tenants to move in a tight rental market or pay more of their income towards rent to stay in their current home, please consider endorsing these comments or submitting your own. Endorse our comments by completing the form below or feel free to copy any parts of these comments and submit your own.  Organizations can endorse by Aug. 12th.

SAFMR Sign-On (for Organizations Only)