Responses Requested by November 15
On September 17, HUD published a request for information (RFI) in the Federal Register regarding the administration’s proposal (including its 2025 budget proposal) to make some Lead Hazard Reduction and Healthy Homes Program funding awards based on formula. Currently, funding designated for these programs is statutorily required to be awarded via competition.
HUD’s Office of Lead Hazard Control and Healthy Homes administers this funding program which targets privately owned rental and owned housing where lead risk, especially to children, is high. Generally, public housing authorities are not eligible for this funding, in part due to earlier funding targeting lead in public housing. Unfortunately, lead risk remains high in some older public housing properties due to high levels of lead in the environment resulting from past air pollution and industrial activity, and because prior lead risk levels and abatement protocols were much less stringent than current standards.
HUD’s proposal to Congress is to modify some portion of the funding to be distributed by formula. HUD requests feedback regarding “the specific criteria or objective measures that HUD should consider using in a formula” such as what data sources should be used and how those sources should be weighted.
HUD’s rationale is that awarding some Lead Hazard Reduction Grants, all Lead Hazard Reduction Demonstration Grants, and proportional Supplemental Healthy Homes grants (to address related non-lead hazards) by formula “may allow more efficient distribution of funding to highest need communities, streamline the selection and award of grants, and help maximize funding utilization.” Specifically, HUD says the change will “reduce the procedural complexity placed on jurisdictions to apply for grants, streamline the process for HUD to select jurisdictions to receive these formula grants, allow more efficient distribution of funding to communities facing the most substantial lead paint hazard problems, and help maximize funding utilization when complemented by a portion of the funds being used for competitive grants.”
Specific Questions
HUD poses four specific questions in the RFI:
- Funding Criteria, with lots of details on data alternatives and possibilities. Data sources on children at risk are part of the discussion of factors to consider in responding to this question.
- Additional Criteria, if any, relating to high-performing programs, sequencing of awards, and actions in response to poor performance.
- If smaller grants should be awarded to achieve broader geographic dispersal of funding, or should larger grants be awarded to higher-risk communities, resulting in less geographic dispersal of funds?
- What should be the duration of the period of performance for a formula grant?
The full notice, with a link to submit comments, can be found here. Responses to HUD are due by November 15, 2024, but “Late-filed comments will be considered to the extent practicable.”
Legislative Action Needed
Since legislative action would be required for this change, comments could recommend adding public housing authorities as eligible entities (if they have or can obtain the appropriate qualifications and certifications to perform Lead Hazard Reduction activities and/or administer Lead Hazard Reduction grants), as an increasing number of public housing agencies own or manage potentially eligible properties. Further, housing stock currently renting at below market averages to households with Housing Choice Vouchers are likely to overlap substantially with areas of high risk. Housing authorities can build on their relationships with landlords to connect funding and funded entities with eligible property owners.
Theoretically, Congress could also remove the restriction on eligibility to privately owned properties and focus funding on properties with high risk, regardless of ownership, making current and former public housing eligible if warranted by lead risk levels.
Member feedback is requested and can be sent to: dweber@phada.org or: policy@phada.org.