File: 
NCSHA Comments on ESG Interim Rule.pdf

Summary

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    February 3, 2012

     
    Regulations Division, Office of General Counsel
    U.S. Department of Housing and Urban Development
    451 Seventh Street, SW, Room 10276
    Washington, DC  20410
     
    Re: Comments on Homeless Emergency Assistance and Rapid Transition to Housing: Emergency Solutions Grants Program and Consolidated Plan Conforming Amendments
     
    Docket No. FR-5474-I-01
     
    To whom it may concern: 
     
                    The National Council of State Housing Agencies (NCSHA) thanks you for the opportunity to comment on HUD’s interim rule on the Emergency Solutions Grants (ESG) program and Consolidated Plan Conforming Amendments. NCSHA represents the nation’s state Housing Finance Agencies (HFAs), which administer a wide range of affordable housing and community development programs, including tax‐exempt Housing Bonds, the Low Income Housing Tax Credit, HOME, Section 8, homeless assistance programs, and state housing trust funds. On behalf of NCSHA, I urge HUD to improve the interim rule by including the following changes.
     
                    NCSHA encourages HUD to extend beyond the 60-day limit included in § 576.203 the amount of time provided for states to obligate their grant amounts.  Some state grantees obligate their funds through a competition and 60 days is an insufficient amount of time for the states to conduct the competition. States require more than 60 days to issue and receive back applications, hold the judging, and announce and sign final contracts for subgrant allocations.  NCSHA requests that HUD provide states with at least the same amount of time it is providing to local governments to fully obligate their funds.
     
                    NCSHA requests that HUD make clear in its final rule that ESG eligible recipients include instrumentalities of the state.  This language is consistent with that used for the Continuum of Care program and for the Homeless Management Information Systems (HMIS).  Some states have determined that an instrumentality of the state is the most appropriate entity to administer the ESG program.  In some states, instrumentalities have administered McKinney-Vento programs successfully for years.  The final rule should explicitly permit this.  Thank you for your consideration of our comments.  Please contact me if we can provide additional information.
     
    Sincerely,

    Garth Rieman
    Director, Housing Advocacy and Strategic Initiatives