FR 2021-01489

Summary of the Notice

The Department of Housing and Urban Development (HUD) has issued a notice inviting public comments on a proposal related to the collection of information concerning the designation of housing projects. This proposed revision seeks to update current processes used to determine whether housing projects should be designated as “elderly only,” “disabled only,” or for both groups. Public feedback is being solicited for 60 days, focusing on the usefulness and efficiency of this data collection, expected to become less frequent due to shifts in public housing strategies.

Issues and Concerns

Several issues emerge from this notice that merit discussion. Firstly, the reduction in the estimated burden from 585 to 270 hours is briefly explained; however, it lacks detailed reasoning, potentially leaving readers questioning the basis for this significant adjustment. The use of generalized salary data from external sources to estimate costs further complicates matters, presenting another area where the methodology could benefit from a clearer explanation.

The notice mentions compliance with various legal acts, such as the Civil Rights Act and the Americans with Disabilities Act, but does not provide specific examples or requirements. This may create ambiguity for the Public Housing Agencies (PHAs) who need to understand these compliance obligations clearly. Additionally, while the document encourages feedback on minimizing the information collection burden, it does not offer explicit guidance on using automated technologies, potentially hindering more efficient compliance.

Impact on the Public

Broadly, this document could affect public engagement in housing policy and resource allocation discussions. The potential decline in agency participation as stated in the document might reduce input from PHAs, possibly impacting the overall diversity and representativeness of feedback.

For individuals who might be directly affected, such as residents in public housing, the implications are significant. The designation of housing projects can influence the availability of accessible housing and the resources provided during relocations. As these housing policies shift, maintaining transparent and comprehensive communication with affected groups will be crucial to mitigate any negative impacts.

Impact on Specific Stakeholders

For Public Housing Agencies, the changes proposed in the notice could either streamline operations due to reduced data collection requirements or present new compliance challenges without clear guidance on process enhancements. The impact on PHAs largely depends on the clarity and feasibility of implementation strategies suggested by HUD.

State and local governments are also key stakeholders. The lack of specific measures to ensure these entities are informed about the notice might limit their engagement, potentially affecting the breadth of feedback HUD receives. Ensuring these governments are adequately prepared to participate will be vital for obtaining comprehensive public input. Engaging these stakeholders effectively could also address broader housing needs and support the achievement of HUD's objectives.

The Federal Register document under review outlines a proposed information collection by the Department of Housing and Urban Development (HUD) concerning the designation of housing projects. The document mentions specific financial figures related to the operational costs of Public Housing Agencies (PHAs) that are responsible for implementing designated housing plans.

Summary of Financial References

The document states that the national average salary for PHA staff is $51,000 per year, which translates to an hourly rate of $24.00. This hourly rate is used to calculate the total cost associated with the estimated burden hours for the PHAs required to submit plans for designating housing projects. The calculation provided is based on 18 PHAs each spending 15 hours to prepare and submit their plans, leading to a total of 270 hours of work. Consequently, the cost of this labor, using the established hourly wage, amounts to $6,480. This cost estimation is critical for understanding the financial burden placed on PHAs when complying with HUD's information collection requirements.

Relation to Identified Issues

The document indicates a reduction in the estimated burden from 585 hours to 270 hours. However, it lacks specific justification or data supporting this adjustment. This reduction could potentially affect the accuracy of the financial estimates presented. Without a detailed explanation of why fewer hours are estimated, stakeholders might question the reliability of the projected financial burden.

Moreover, the determination of cost relies on generalized data retrieved from sources such as ziprecruiter.com and the use of a specific divisor from opm.gov to convert annual salaries into hourly rates. This reliance on generalized data may not reflect variations in salaries across different regions or individual PHAs, leading to possible discrepancies in financial predictions.

Finally, while the document calculates a monetary value for the time spent on compliance, it does not discuss measures that could potentially optimize or reduce these costs, such as automated data collection techniques. This omission might imply that PHAs could face higher costs if they do not utilize efficient processes or technology, leading to an unnecessary financial burden on these agencies.

In summary, the financial references within the document provide important context regarding the economic implications for PHAs but are clouded by issues surrounding their overall justification and the methodology used to arrive at these figures. Such ambiguity necessitates a carefully detailed explanation to ensure transparency and trust in the decision-making process regarding financial estimations and allocations.