2006-07-19 (Report)
~'
CITY OF ENCINITAS
HOUSING AUTHORITY
AGENDA REPORT
Meeting Date: July 19,2006
TO:
Housing Authority of~e Iii ~frn~ir~as
Kerry L. Miller, Exec ':J1.~
~atriCk Murphy, PI .~ & Building Director
vid de Cordova, Principal Planner
David Harris, Housing Coordinator
VIA:
FROM:
SUBJECT: Approval of the 2006-2007 Annual PHA Plan of the Encinitas Housing Authority
and amendments to the Section 8 Administrative Plan
BACKGROUND: As a Public Housing Authority (pHA), the Encinitas Housing Authority is
required to prepare a five-year Agericy Plan in compliance with the Quality Housing and Work
Responsibility Act of 1998. The Agency Plan identifies the housing needs of lower income
households on the waiting list for the Section 8 Housing Choice Voucher program. The plan
includes goals, objectives, and priorities to meet those needs over the next five years.
Additionally, the Encinitas Housing Authority must file annual updates to the five-year plan,
even if there are no changes.
The 2006-2007 Annual PHA Plan outlines the goals, objectives, and priorties for the rental
assistance and related activities during the upcoming program year year. The City expects to
receive about $1.1 million from the U.S. Department of Housing and Urban Development to
assist eligible households with rental assistance through the Section 8 Housing Choice Voucher
program. The Annual Plan is available for public review and comment from June 18 to July 18,
2006.
The Section 8 Administrative Plan outlines the Housing Authority's policies and procedures for
administration of the program, including the waiting list, local preferences, income calcuations,
housing payment standards, inspections, recertifications, terminations, and appeals.
ANALYSIS;
The 2006-2007 Annual PHA Plan is attached (see Attachment A). There are no c~anges from
the prior year plan.
The proposed amendments to the Section 8 Administrative Plan (Attachment B) are in response
to recommendations made by the HUD regional office in a letter dated June 12,2005. The letter
H3-\
was sent to the Housing Authority after a monitoring visit in which the HUn representative
reviewed our Administrative Plan. The Housing Authority has already implemented the changes,
so approval of these amendments is to update the written policies and procedures contained in
the Adminstrative Plan. These amendments include:
1) Disallowance of Earned Income: If a disabled person begins working, only part of the
wages will be included in determining the family's rent portion.
2) A $400 household deduction is given to each elderly or disabled household.
3) Verification of Citizenship/Eligible Immigration Status: clarification that our citizenship
verification procedure shall follow federal regulations.
4) Rent Reasonableness: Additional language to clarify that the EHA tests Rent
Reasonableness according to nine required factors.
FISCAL AND STAFF IMPACT
The Housing Authority anticipates receiving about $1.1 million of HUn in fiscal 2006-2oo7to
provide rental assistance to 136 families. The Housing Authority budget was approved on June
21,2006.
RECOMMENDATION: Approve the 2006-2007 Annual PHA Plan and approve changes to the
Administrative Plan.
ATTACHMENTS:
"A" - 2006-2007 Annual PHA Plan
"B" - Section 8 Administrative Plan Text Amendments
H3.~
Attachment "A"
2006-2007 Annual PHA Plan
H3-3
PHA Plans
u.s. Department of Housing and
Urban Development
Office of Public and Indian
Housing
OMB No. 2577-0226
(exp.06/30/2006)
Streamlined Annual
Version
This information collection is authorized by Section S II of the Quality Housing and Work Responsibility Act, which added a new section SA to
the U.S. Housing Act of 1937 that introduced S-year and annual PHA Plans. The full PHA plan provides a ready source for interested parties to
locate basic PHA policies, rules, and requimnents concerning the PHA's operations, programs, and services, and informs HUD, families served
by the PHA, and members of the public of the PHA's mission and strategies for serving the needs oflow-income and very low-income families.
This form allows eligible PHAs to make a streamlined annual Plan submission to HUD consistent with HUD's efforts to provide regulatory relief
for certain types ofPHAs. Public reporting burden for this information collection is estimated to average 11.7 hours per response, including the
time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the
collection of information. HUD may not collect this information and respondents are not required to complete this form, unless it displays a
currently valid OMB Control Number.
Privacy Act Notice. The United States Department of Housing and Urban Development, Federal Housing Administration, is authorized to
solicit the information requested in this form by virtue ofTitle 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at
Title 12, Code ofFedera1 Regulations. Information in PHA plans is publicly available.
Streamlined Annual PHA Plan
for Fiscal Year: 2006-2007
City of Encinitas Housing Authority
NOTE: This PHA Plan template (HUD-S0075-SA) is to be completed in accordance with instructions
contained in previous Notices pm 99-33 (HA), 99-51 (HA), 2000-22 (HA), 2000-36 (HA), 2000-43 (HA), 2001-
4 (HA), 2001-26 (HA), 2003-7 (HA), and any related notices HUD may subsequently issue.
H3-1
form HUD-50075-SA (0413012003)
Streamlined Annual PHA Plan
Agency Identification
PHA Name: City of Encinitas Housing Authority
PHA Number: CA155
PHA Fiscal Year Beginning: (mmlyyyy) 07/2006
PHA Programs Administered:
OPubUc Housing and Section 8 ~Section 8 Only OPublic Housing Only
Number of public housing units: Number ofS8 units: Number of public housing units:
Number of S8 units:
OPHA Consortia: (check box if submitting a joint PHA Plan and complete table)
Participating PBAs PHA Program(s) Included In Programs Not In # 01 Units
Code the Consortium the Consortium Each Program
Participating PHA 1:
Participating PHA 2:
Participating PHA 3:
PHA Plan Contact Information:
Name: David Harris
TDD:
Phone: 760-633-2724
Email (ifavailable):dharris@ci.encinitas.ca.us
Public Access to Information
Information regarding any activities outlined in thi~lan can be obtained by contacting: (select aU that apply)
~ PHA's main administrative office U PHA's development management offices
Display Locations For PHA Plans and Supporting Documents
The PHA Plan reVised policies or program changes (including attachments) are available for
public review and inspection. [8J Yes 0 No.
If yes, select all that apply:
[8J Main administrative office of the PHA
o PHA development management offices
o Main administrative office of the local, county or State government
o Public library 0 PHA website 0 Other (list below)
PHA Plan Supporting Documents are available for inspection at: (select all that apply)
[8J Main business office of the PHA 0 PHA development management offices
o Other (list below)
Streamlined Annual PHA Plan
1-\3.5
form HUD-50075-SA (04130/2003)
Fiscal Year 2006-2007
[24 CFRPart903.12(c)]
Table of Contents
[24 CPR 903.7(r)]
A. PHA PLAN COMPONENTS
o 1. Site-Based Waiting List Policies
903.7(b)(2) Policies on Eligibility, Selection, and Admissions
o 2. Capital Improvement Needs
903.7(g) Statement of Capital Improvements Needed
~ 3. Section 8(y) Homeownership
903. 7(k)(1 )(i) Statement ofBomeownenhip Programs
~ 4. Project-Based Voucher Programs
~ 5. PHA Statement of Consistency with Consolidated Plan. Complete only ifPHA has
changed any policies, programs, or plan components from its last Annual Plan.
~ 6. Supporting Documents Available for Review
o 7. Capital Fund Program and Capital Fund Program Replacement Housing Factor,
Annual Statement/Perfonnance and Evaluation Report
o 8. Capital Fund Program 5- Year Action Plan
B. SEPARATE BARD COpy SUBMISSIONS TO LOCAL BUD FIELD OFFICE
Form BUD-SOO76, PHA Certifications of ComDliance with the PHA Plans and Related
Ref!Ulations: Board Resolution to AccomDanv the Streamlined Annual Plan identifying policies
or programs the PHA has revised since submission of its last Annual Plan, and including Civil
Rights certifications and assurances the changed policies were presented to the Resident
Advisory Board for review and comment, approved by the PHA governing board, and made
available for review and ins ection at the PHA's rinci aloffice;
Form BUD-S0070, Certification for a Drufl-Free Workolace:
Form BUD-S0071, Certification of Payments to Influence Federal Transactions; and
Form SF-LLL &SF-LLLa, Disclosure of Lobbvinfl Activities.
f-t 3. G,
form HUD-5007s..5A (04/30/2003)
1. Site-Based Waitin2 Lists lEli2ibilitv.. Selection.. Admissions Policies}
24 CFR Part 903.12(c), 903.7 2
A. Site-Based Waiting Lists-Previous Year
1. Has the PHA operated one or more site-based waiting lists in the previous year? If yes,
complete the following table; ifnot skip to B.
Site-Based Waiting Lists
Development Date Initial mix of Current mix of Percent
Information: Initiated Racial, Ethnic or Racial, EthDic or change
(Name, number, Disability Disability between initial
location) Demographics Demographics and current
since Initiation of mix of Racial,
SBWL Ethnic, or
Disability
demo2raphics
2. What is the number of site based waiting list developments to which families may apply
at one time?
3. How many unit offers may an applicant turn down before being removed from the site-
based waiting list?
4. 0 Yes 0 No: Is the PHA the subject of any pending fair housing complaint by BUD
or any court order or settlement agreement? If yes, describe the order, agreement or
complaint and describe how use of a site-based waiting list will not violate or be
inconsistent with the order, agreement or complaint below:
B. Site-Based Waiting Lists - Coming Year
If the PHA plans to operate one or more site-based waiting lists in the coming year, answer
each of the following questions; if not, skip to next component.
1. How many site-based waiting lists will the PHA operate in the coming year?
2. 0 Yes 0 No: Are ,any or all of the PHA's site-based waiting lists new for the upcoming
year (that is, they are not part of a previously-BUD-approved site based
waiting list plan)?
If yes, how many lists? U 3. 1
form HUD-50075-SA (0413012003)
3. DYes D No: May families be on more than one list simultaneously
If yes, how many lists?
4. Where can interested persons obtain more information about and sign up to be on the site-
based waiting lists (select all that apply)?
D PHA main administrative office
o All PHA development management offices
o Management offices at developments with site-based waiting lists
D At the development to which they would like to apply
D Other (list below)
A. Capital Fund Program
1. 0 Yes 0 No Does the PHA plan to participate in the Capital Fund Program in the
upcoming year? If yes, complete items 7 and 8 of this template (Capital
Fund Program tables). Ifno, skip to B.
2. D Yes D No: Does the PHA propose to use any portion of its CFP funds to repay debt
incurred to finance capital improvements? If so, the PHA must identify in
its annual and 5-year capital plans the development(s) where such
improvements will be made and show both how the proceeds of the
financing will be used and the amount of the annual payments required to
service the debt. (Note that separate HUD approval is required for such
financing activities.).
H- 3. 8
form HUD-50075-SA (0413012003)
B. HOPE VI and Public Housing Development and Replacement Activities (Non-
Ca ital Fund
1. 0 Yes 0 No: Has the PHA received a HOPE VI revitalization grant? (if no, skip to #3; if
yes, provide responses to the items on the chart located on the next page,
copying and completing as many times as necessary).
2. Status of HOPE VI revitalization grant(s):
HOPE VI Revitalization Grant Status
a. Development Name:
b. Development Number:
c. Status of Grant:
DRevitalization Plan under development
DRevitalization Plan submitted, pending approval
DRevitalization Plan approved
DActivities pursuant to an approved Revitalization Plan underw~
3. 0 Yes 0 No: Does the PHA expect to apply for a HOPE VI Revitalization grant in the
Plan year?
If yes, list development name( s) below:
4. 0 Yes 0 No: Will the PHA be engaging in any mixed-finance development activities for
public housing in the Plan year? If yes, list developments or activities
below:
5. 0 Yes 0 No: Will the PHA be conducting any other public housing development or
replacement activities not discussed in the Capital Fund Program Annual
Statement? If yes, list developments or activities below:
3. Section 8 Tenant Based Assistance-Section 8
1. ~ Yes 0 No: Does the PHA plan to administer a Section 8 Homeownership program
pursuant to Section 8(y) of the U.S.H.A. of 1937, as implemented by 24
CFR part 982 ? (If''No'', skip to the next component; if''yes'', complete
each program description below (copy and complete questions for each
program identified.)
H- 3. 9
form HUD-50075-SA (0413012003)
2. Program Description:
a. Size of Program
~ YesD No:
Will the PHA limit the number of families participating in the Section 8
homeownership option?
If the answer to the question above was yes, what is the maximum number
of participants this fiscal year? 2
b. PHA-established eligibility criteria
DYes ~ No: Will the PHA's program have eligibility criteria for participation in its
Section 8 Homeownership Option program in addition to HUD criteria?
If yes, list criteria:
c. What actions will the PHA undertake to implement the program this year (list)?
Since the price of homes in Encinitas are beyond the budget oflow-income households, the only
units that lower-income tenants may afford are restricted units developed and sold under the
City's affordable housing programs. These affordable units have resale restrictions on the title to
ensure the affordability for 30 to 55 years. The HA will notify potential participants of any
affordable homeownership opportunities that become available.
3. Capacity of the PHA to Administer a Section 8 Homeownership Program:
The PHA has demonstrated its capacity to administer the program by (select all that apply):
D Establishing a minimum homeowner downpayment requirement of at least 3 percent of
purchase price and requiring that at least 1 percent of the purchase. price comes from the
family's resources.
[gI Requiring that financing for purchase of a home under its Section 8 homeownership will
be provided, insured or guaranteed by the state or Federal government; comply with
secondary mortgage market underwriting requirements; or comply with generally
accepted private sector underwriting standards.
[gI Partnering with a qualified agency or agencies to administer the program (list name(s) and
years of experience below): ACORN Housing Corporation
D Demonstrating that it has other relevant experience (list experience below):
4. Use of the Proiect-Based Voucher Proeram
Intent to Use Project-Based Assistance
DYes [gI No: Does the PHA plan to "project-base" any tenant-based Section 8 vouchers in
the coming year? If the answer is ''no,'' go to the next component. If yes, answer the following
questions.
H,- 10
form HUD-50075-5A (0413012003)
1. DYes D No: Are there circumstances indicating that the project basing of the units,
rather than tenant-basing of the same amount of assistance is an appropriate option? If
yes, check which circumstances apply:
D low utilization rate for vouchers due to lack of suitable rental units
D access to neighborhoods outside of high poverty areas
D other (describe below:)
2. Indicate the number of units and genera1location of units (e.g. eligible census tracts or
smaller areas within eligible census tracts):
5. PHA Statement of Consistency with the Consolidated Plan
24 CFR Part 903.15]
[8]
D
[8]
[8]
D
1. Consolidated Plan jurisdiction: City of Encinitas
2. The PHA has taken the following steps to ensure consistency of this PHA Plan with the
Consolidated Plan for the jurisdiction: (select all that apply)
The PHA has based its statement of needs of families on its waiting lists on the needs
expressed in the Consolidated Plan/so
The PHA has participated in any consultation process organized and offered by the
Consolidated Plan agency in the development of the Consolidated Plan.
The PHA has consulted with the Consolidated Plan agency during the development of
this PHA Plan.
Activities to be undertaken by the PHA in the coming year are consistent with the
initiatives contained in the Consolidated Plan. (list below)
Other: (list below)
3. The Consolidated Plan of the jurisdiction supports the PHA Plan with the following actions
and commitments: (describe below)
H 3. t I
fonn HUD-50075-SA (04/30J2003)
6. Supportin2 Documents Available for Review for Streamlined Annual PHA
Plans
PHAs are to indicate which documents are available for public review by placing a mark in the "Applicable & On
Display" column in the appropriate rows. All listed documents must be on display if applicable to the program
activities conducted by the PHA. .
List of SunnnrtinlJ Documents A vaUable for Review
Applicable Supporting Document Related Plan Component
&On
DisDlav
PHA Certifications of Compliance with the PHA Plans and Related Regulations 5 Year and Annual Plans
and Board Resolution to Accompany the Standard Annual, Standard Five- Year,
and Streamlined Five-Year/Annual Plans;
X PHA Certifications of Compliance with the PHA Plans and Related Regulations Streamlined Annual Plans
and Board Resolution to Accomoanv the Streamlined Annual Plan
Certification by State or Local OjJicial of PHA Plan Consistency with 5 Year and standard Annual
Consolidated Plan. Plans
X Fair Housing Documentation Supporting Fair Housing Certifications: Records 5 Year and Annual Plans
reflecting that the PHA has examined its programs or proposed programs,
identified any impediments to fair housing choice in those programs, addressed or
is addressing those impediments in a reasonable fashion in view of the resources
available, and worked oris working with local jurisdictions to implement any of
the jurisdictions' initiatives to affirmatively further fair housing that require the
PHA's involvement.
X Housing Needs Statement of the Consolidated Plan for the jurisdiction(s) in which the Annual Plan:
PHA is located and any additional backup data to support statement of housing needs for Housing Needs
families on the PHA's ooblic housinll and Section 8 tenant-based waitinlllists.
X Most recent board-approved operating budget for the public housing program Annual Plan:
Financial Resources
X Public Housing Admissions and (Continued) Occupancy Policy (A&O/ACOP), Annual Plan: Eligibility,
which includes the Tenant Selection and Assignment Plan [TSAP} and the Site- Selection, and Admissions
Based Waitin~ List Procedure. Policies
Deconcentration Income Analysis Annual Plan: Eligibility,
Selection, and Admissions
Policies
Any policy goveming occupancy of Police Officers and Over-Income Tenants in Annual Plan: Eligibility,
Public Housing. 0 Check here if included in the public housing A&O Policy. Selection, and Admissions
Policies
X Section 8 Administrative Plan Annual Plan: Eligibility,
Selection, and Admissions
Policies
Public housing rent determination policies, including the method for setting public Annual Plan: Rent
housing flat rents. Determination
o Check here if included in the Dublic housinl!: A & 0 Policv.
Schedule of flat rents offered at each public housing development. Annual Plan: Rent
o Check hereifincluded in the Dublic housing A & 0 Policy. Determination
Section 8 rent determination (payment standard) policies (if included in plan, not Annual Plan: Rent
necessary as a supporting document) and written analysis of Section 8 payment Determination
standard policies: ~ Check here if included in Section 8 Administratiye Plan.
Public housing management and maintenance policy documents, including policies for Annual Plan: Operations and
the orevention or eradication of nest infestation (includinll cockroach infestation). Maintenance
Results of latest Public Housing Assessment System (pHAS) Assessment (or other Annual Plan: Management
applicable assessment). . and Operations
Follow-up Plan to Results of the PHAS Resident Satisfaction Survey (if necessary) Annual Plan: Operations and
Maintenance and Community
Service & Self-Sufficiency
X Results of latest Section 8 Manallement Assessment System (SEMAP) Annual Plan: Manal!:ement
fonn HUD-SO075-SA (0413012003)
f-t~. I~
List of SUDDortintl Documents Available for Review
Applicable Supporting Document Related Plan Component
&On
Display
and Ooerations
Any policies governing any Section 8 special housing types Annual Plan: Operations and
o Check here if included in Section 8 Administrative Plan Maintenance
Public housing grievance procedures Annual Plan: Grievance
[] Check here if included in the public housin2 A & 0 Policy Procedures
Section 8 informal review and hearing procedures. Annual Plan: Grievance
181 Check here if included in Section 8 Administrative Plan. Procedures
The Capital Fund/Comprehensive Grant Program Annual Statement /Performance Annual Plan: Capital Needs
and Evaluation Reoort for any active 2r8Dt year.
Most recent ClAP Budget/Progress Report (HUD 52825) for any active ClAP Annual Plan: Capital Needs
2r8Dts.
Approved HOPE VI applications or. if more recent. approved or submitted HOPE VI Annual Plan: Capital Needs
Revitalization Plans. or any other aooroved for development of DUblic housinlt.
Self-evaluation, Needs Assessment and Transition Plan required by regulations Annual Plan: Capital Needs
implementing Section 504 of the Rehabilitation Act and the Americans with
Disabilities Act. See PIH Notice 99-52 (HA).
Approved or submitted applications for demolition and/or disposition of public housing. Annual Plan: Demolition
and Disposition
Approved or submitted applications for designation of public housing (Designated Annual Plan: Designation of
Housinlt Plans). Public Housing
Approved or submitted assessments of reasonable revitalization of public housing Annual Plan: Conversion of
and approved or submitted conversion plans prepared pursuant to section 202 of Public Housing
the 1996 HUD Appropriations Act. Section 22 of the US Housing Act of 1937. or
Section 33 of the US Housinlt Act of 1937.
Documentation for required Initial Assessment and any additional information Annual PIan: Voluntary
reauired by HUD for Voluntary Conversion. Conversion of Public Housin2
Approved or submitted public housing homeownership programs/plans. Annual Plan:
Homeownershio
X Policies governing any Section 8 Homeownership program Annual Plan:
(Section XIII of the Section 8 Administrative Plan) Homeownershio
Public Housing Community Service PolicylPrograms Annual Plan: Community
o Check here if included in Public Housinlt A & 0 Policy Service & Self-Sufficiency
Cooperative agreement between the PHA and the T ANF agency and between the Annual Plan: Community
PHA and local ernoloyment and trainin2 service aJ;!encies. Service & Self-Sufficiency
FSS Action Plan(s) for public housing and/or Section 8. Annual Plan: Community
Service & Self-Sufficiency
Section 3 documentation required by 24 CFR Part 135. Subpart E for public Annual Plan: Community
housin2. Service & Self-Sufficiency
Most recent self-sufficiency (ED/SS, TOP or ROSS or other resident services Annual Plan: Community
grant) grant oro2l'llll1 reports for public housing. Service & Self-Sufficiency
Policy on Ownership of Pets in Public Housing Family Developments (as required Annual Plan: Pet Policy
by regulation at 24 CFR Part 960, Subpart G).
[] Check here if included in the public housing A & 0 Policy.
X The results of the most recent fiscal year audit of the PHA conducted under the Annual Plan: Annual Audit
Single Audit Act as implemented by OMB Circular A-133, the results of that audit
and the PHA's response to any findinJ;!s.
Other supporting documents (optional) (specify as needed)
(list individually; use as many lines as necessary)
Consortium agreement(s) and for Consortium Joint PHA Plans Only; Certification Joint Annual PHA Plan for
that consortium agreement is in compliance with 24 CFR Part 943 pursuant to an Consortia: Agency
opinion of counsel on file and available for inspection. Identification and Annual
Mana2ement and Ooerations
form HUD-5007S-5A (04/3012003)
H?:>- l~
Attachment "B"
Section 8 Administrative Plan Text Amendment
i~ 3 - ( t
Insert Section VI B (3) as follows:
3. Disallowance of Earned Income for Persons with Disabilities
The annual income for aualified families may not be increased as a result of increases in
earned income of a family member who is a oerson with disabilities bellinninll on the date
on which the increase in earned income bellins and continuinll for a cumulative twelve-
month oeriod. After-the disabled familv member receives twelve cumulative months of
the full exclusion. annual income will include a Dbase-in of half the earned income
excluded from annual income. The ERA will aDDlv the regulation accordinll to 24 CFR
5.617: 982.201 (b)(3).
Insert new Section VI C (3), Allowable Deductions, as follows:
3. $400 household allowance for each elderly or disabled household
Renumber Section VI C (3) to VI C (4):
;A. Child care expenses: ...
Amend Section VII A (1) asfollows:
1. Verification of CitizenshiD/ElilZible Immiszration Status. To be eligible for assistance,
individuals must be u.S. citizens or eligible immigrants. Individuals who are neither may
elect not to contend their status. Eligible immigrants must fall into one of the categories
specified by the regulations and must have their status verified by the Immigration and
Naturalization Service (INS). Each Household member must declare their status once.
Assistance cannot be delayed, denied, or terminated while the verification of status is
pending except that assistance to the applicants may be delayed while the ERA hearing is
pending. The ERA will aDDlv the reszulation accordinll to 24 CFR 5.508. 5.510. 5.512.
5.514.
Amend Section XI C (2) as follows:
2. R-eBt FElase:aableaess sllall be EletermiBeEl by the inspeetefS, Based ea ar.ffilal Barley
eeBEkleted By the Heasiag :\atheFity market 8:Balyst. The S\:lrley shall Be k~t BY eeB51:1B
1faek in efEler te pFElVeftt higher Feat eeiag gF8ftteEl thea these '::hieft 8fe a~FBpriate fer a
eemp8:faBle aait ia the same BeiglHleraeed.Rent Reasonableness. The Duroose of the
Rent Reasonableness Test is to assure that a fair rent is Daid for units selected for
Darticillation in the. Rental Assistance Proszram and the DrolZram does not have the effect
of inflatinll rents in the community. Rent reasonableness determinations are made when
units are Dlaced under contract for the first time. before any increase in rent to the owner.
and if there is a 5% decrease in the Dublished Fair MarketRent. The ERA will determine
whether the rent to owner is a reasonable rent in comparison to rent for other comDarable
unassisted units. To make this.determination. the EHA will consider:
e The location. size. unit tvoe. auality. and aile of the unit.
e Anv amenities. housinll services. maintenance and utilities Drovided bv the owner
under the lease.
H3-15