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NHLP and HJN Urge Improvement of HUD’s Public Housing Assessment System That Would Include a Robust Role for Resident Input.

One set of comments focused on the resident service and satisfaction indicator, which was formerly found at 24 C.F.R. § 902.50. The interim rule, which can be found at http://www.gpo.gov/fdsys/pkg/FR-2011-02-23/pdf/2011-2659.pdf, was effective March 25, 2011 and removed the resident service and satisfaction indicator. The comments urged HUD to restore the resident service and satisfaction survey to a prominent position in the PHAS, suggested important improvements to the former survey form and listed a number of mechanisms to obtain more robust responses to the survey. These comments arose out of discussions among public housing leaders and advocate members of four groups: the National Low Income Housing Coalition’s Resident Issues Policy Committee; the Resident Engagement Group convened by the National Housing Law Project; the Housing Justice Network, an informal network of legal services attorneys and advocates, and the National Housing Law Project, all of whom joined in the comments.

The second comment letter included a more detailed analysis of the entire interim rule and focused on a number of issues including:
• Providing more information to residents and the public
• Adding to the evaluation of the physical condition of the property a review of compliance with the accessibility features
• Emphasizing the critical importance of on-site management reviews and urging HUD to continue to consistently to use that tool
• The importance of evaluating public housing agencies on the extent and effectiveness of resident involvement, compliance with Section 3, and adoption and implementation of policies regarding reasonable accommodation, limited English proficiency (LEP) and language access plans (LAP), and implementing the Violence Against Women Act (VAWA),
• Evaluating the PHA’s response to crime and efforts to create a safe environment

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