We applaud HUD for considering the many comments it received on the Advanced Notice of
Proposed Rulemaking that was issued last summer. There are many improvements we saw in
the proposed rule that indicates thoughtful consideration of issues raised by the commenters.
There still may be unintended consequences that arise in the move to the new system,
however, and it is important to guard tenants against reduction in their housing choices. The
behavior of landlords and tenants may confound the system that HUD and the PHAs are trying
to institute, and thus the new system needs to be flexible to adapt so that families don’t lose