This spring, the U.S. Department of Housing and Urban Development (HUD) issued a draft proposal for finalized Section 3 rules. The issued rules included several changes to the Section 3 program, discussed in this RHLS blog post from March. Public comments on the changes were due on May 26th.
Regional Housing Legal Services Staff Attorney, Bob Damewood, worked with the Housing Justice Network, a nationwide group of attorneys and advocates work with low-income tenants and applicants for HUD-assisted housing, to author comments on the proposed new rules.
The Housing Justice Network’s comments emphasize effectiveness, clarity, transparency, and an improved targeting of those intended to benefit from Section 3. Some key recommendations provided by the Housing Justice Network include:
- Prescribing minimum efforts to link Section 3 residents and businesses with economic opportunities.
- Opposing onerous minimum qualifications on residents and and businesses.
- Quality control for the self-certification of businesses to protect the integrity of the system.
- A rule that would require recipients to ensure that their subrecipient and contractor selection procedures assess bidders’ previous compliance and ability to retain Section 3 hires, comply with requirements, and provide training opportunities.
- Eliminating the “new hire” standard of measuring compliance and using a flat percentage of hours worked instead.
- Incentives for apprenticeship, training, and retention of low-income workers.
- Providing higher priority consideration for employment and contracting opportunities to all recipients, including residents of HUD multifamily housing.
The full document submitted by the Housing Justice Network can be read here. Check back for further developments as the proposed rules move through the regulatory process.