Overview
Title
30-Day Notice of Proposed Information Collection: Requirements for Designating Housing Projects; OMB Control No.: 2577-0192
Agencies
ELI5 AI
The Department of Housing and Urban Development (HUD) wants people to share their thoughts on some new rules they want to make about special homes for certain groups. They're asking if the rules are helpful, accurate, and if there's a better way to collect information.
Summary AI
The Department of Housing and Urban Development (HUD) is requesting public comments on a proposed information collection, as it seeks approval from the Office of Management and Budget (OMB). This notice allows 30 additional days for public feedback on the information collection related to requirements for designating housing projects. The collection seeks to gather details from Public Housing Agencies on why certain housing projects should be designated for specific groups like the elderly or disabled, including justifications and potential impacts. Comments are encouraged to focus on whether this information is necessary, its accuracy, and ways to improve or ease the data collection process.
Abstract
HUD is seeking approval from the Office of Management and Budget (OMB) for the information collection described below. In accordance with the Paperwork Reduction Act, HUD is requesting comment from all interested parties on the proposed collection of information. The purpose of this notice is to allow for an additional 30 days of public comment.
Keywords AI
Sources
AnalysisAI
Summary
The Department of Housing and Urban Development (HUD) has published a notice requesting public feedback on a proposed information collection process concerning designated housing projects. This initiative is moving towards obtaining approval from the Office of Management and Budget (OMB) and focuses on how Public Housing Agencies (PHAs) designate housing projects specifically for the elderly and disabled. The information sought includes reasons for designating such housing, potential impacts on housing availability, and plans to accommodate those not included in the designated categories.
Key Issues and Concerns
1. Variance in Cost Estimates:
A primary issue with the document is its treatment of cost estimates, which are based on a national average salary for PHA staff. This approach does not take into consideration regional differences in salaries, potentially skewing the overall cost predictions.
2. Ambiguity in Housing Resources:
The document mentions "alternative housing resources" that should be considered for non-designated populations but fails to provide specific examples or guidelines. This vagueness could lead to inconsistent interpretations and applications by different PHAs.
3. Submission Process Clarity:
While the document indicates that comments can be submitted through a government website, it lacks detailed, step-by-step instructions. More guidance could assist users in efficiently navigating the submission process.
4. Differentiation Between DHPs:
The notice references both new/amendment Designated Housing Plans (DHPs) and DHP renewals but does not clearly differentiate between the two. This lack of clarity might confuse individuals trying to determine their requirements under each category.
5. Repetition in Technological Solutions:
There are redundant mentions regarding the use of technology to reduce the burden of information collection. Consolidating these into a single, clear point would enhance the document’s clarity.
Impact on the Public
For the general public, particularly those living in or applying for public housing, this notice underscores the role of feedback in shaping housing policies that affect eligibility and access. By participating in the commentary process, people have a chance to voice concerns about how housing designations might impact them, helping ensure that any changes meet community needs.
Impact on Stakeholders
1. Public Housing Agencies (PHAs):
PHAs stand to be most affected by these changes. The requirement to submit comprehensive plans for designated housing imposes additional administrative tasks, which could require reallocating resources or increasing staff workload. They may need to better articulate their designation rationale clearly and efficiently to ensure compliance and approval by HUD.
2. Elderly and Disabled Populations:
For elderly and disabled individuals, the document signals a potential increase in housing designated specifically for their needs. If executed properly, this could mean more appropriate living arrangements. However, there may also be concerns about the availability of resources or housing for individuals who do not fall into these categories but are in need.
3. Legal and Policy Experts:
For professionals in legal and policy sectors, this document offers a case study in how federal agencies solicit public input to refine and gain approval for information collection activities. It highlights the importance of clarity, inclusivity, and precision in policy documents to ensure they are equitable and actionable.
Overall, this notice presents an opportunity for a diverse range of stakeholders to influence how housing projects are designated and managed, ensuring they cater to the needs of the populations they intend to serve.
Financial Assessment
The document from the Federal Register involves the U.S. Department of Housing and Urban Development's (HUD) proposed information collection regarding the designation of housing projects. It focuses on the financial aspects related to this initiative.
Summary of Financial References
In the document, $64,590 is cited as the national average salary for Public Housing Authority (PHA) staff, which breaks down to approximately $31.00 per hour. This hourly rate is pivotal in calculating the costs associated with the proposed information collection requirements.
For new and amended Designated Housing Plans (DHPs), the estimation process includes multiplying the number of respondents, which is 21 PHAs, by the 15 hours expected per response. This results in a total of 315 hours dedicated to these tasks. Utilizing the national average hourly rate, the estimated cost for completing the new and amended DHPs is $9,765.
The document also details the expenses for DHP renewals. Here, 22 PHAs are projected to spend 3 hours each on their responses, amounting to 66 total hours. Using the same hourly rate, the cost associated with DHP renewals is calculated to be $2,046.
Financial References and Related Issues
These financial calculations raise a few significant concerns. Firstly, the document does not account for potential variations in PHA staff salaries across different regions. Therefore, the actual fiscal burden on PHAs may be underrepresented or overestimated depending on regional wage differences. Adopting a uniform national average may not accurately reflect localized cost variances.
Additionally, while there is a mention of "alternative housing resources" as a component of the designated housing plan, the document offers no concrete examples or guidelines. This vagueness could lead to inconsistent or arbitrary financial assessments across different localities. The cost estimates could be skewed if housing resource availability varies significantly across regions, affecting the justification process for DHPs financially.
Lastly, there seems to be a lack of clarity and specificity in the process described for submitting comments or feedback. More detailed guidance might help mitigate potential inefficiencies or additional costs PHAs might experience due to uncertainties in submission protocols. Consolidating and clarifying these processes would ensure smoother operations and potentially reduce any added procedural financial burdens.
Overall, while the document outlines basic assumptions for estimated financial burdens, a more nuanced approach could help address the identified regional salary variation issue, ensuring equitable and accurate assessments across all PHAs involved.
Issues
• The cost estimates do not account for potential variance in PHA staff salaries across different regions, which could impact the accuracy of the cost estimate.
• The document refers to 'alternative housing resources' but does not provide specific examples or guidelines, which could lead to varied interpretations.
• The process for submitting comments via the website is mentioned briefly but lacks detailed, step-by-step instructions that could aid users.
• The distinction between new/amendment DHPs and DHP renewals is not explicitly clarified, which might cause confusion.
• There is redundant mention of minimizing the burden of information collection using technology; this could be consolidated into a single bullet point for clarity.