DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)

Citation
Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)
Parent Document
Open Cmtys. Alliance v. Carson, 286 F. Supp. 3d 148 (2017)
Effective Date
2017-12-23
Original Source
https://www.courtlistener.com/opinion/7328080/open-cmtys-alliance-v-carson/ ↗

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Specifically, the Interim Report found that SAFMRs in the pilot PHAs make "the availability of units [ ] much more evenly distributed across different types of neighborhoods, leading to increased availability in high-rent ZIP Codes and reduced availability in low-rent ZIP Codes." Interim Report at vii; see also id . at viii ("Because SAFMRs increase access to high-rent ZIP Codes and reduce access to low-rent ZIP Codes, we found not unexpectedly that the transition to SAFMRs led to an increase in units potentially available to HCV holders in higher-opportunity areas under SAFMRs compared with FMRs and fewer units in lower opportunity areas."). As a result, "[f]ollowing the implementation of SAFMRs, HCV holders in the demonstration sites are slightly more likely to live in high-rent ZIP Codes than they were prior to the demonstration," while no such change was observed in "comparison PHAs." id. at viii. Further, "[t]he slight changes in rents among the SAFMR PHAs also translate into slight changes in opportunity." id. ; see also id. at ix (finding that "[a]cross all evaluation PHAs ... changes in rents are also reflected in changes in access to opportunity."). Moreover, Housing Assistance Payment ("HAP") costs, which "are the subsidy costs that PHAs incur on behalf of HCV holders for rent and utilities," "declined in real terms per unit between 2010 and 2015 in SAFMR PHAs," while "[r]ents paid to landlords remained nearly flat in real terms between 2010 and 2015 but varied by rent category." id. at x. The report states, "[i]n summary, it appears that Small Area Fair Market Rents are working as intended-increasing access to units in higher-opportunity areas and decreasing access in lower-opportunity areas." id. at 61.