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)
Jurisdiction: United States (federal)
Effective Date: 2017-12-23
Original Source: https://www.courtlistener.com/opinion/7328080/open-cmtys-alliance-v-carson/ ↗

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The Suspension Memo identified two other concerns with respect to implementing the Rule. The first concern was *159that "several PHA industry groups have [expressed] concerns about the Small Area FMR final rule and the timeline for implementation" in response to a separate Federal Register notice on reducing regulatory burdens. Id. (citing Reducing Regulatory Burden; Enforcing the Regulatory Reform Agenda Under Executive Order 13777 , 82 Fed. Reg. 22,344 (May 15, 2017) ). The Suspension Memo recognized that "HUD has not yet completed its analysis of these public comments," but asserted that "[t]emporarily suspending the Small Area FMR designation until FY 2020 will allow HUD to be informed by the public comments on reducing regulatory burden for the HCV program as well as the Final Report ... before the use of Small Area FMRs is required." Id. The second concern was that developing and issuing "guidance and planning to provide technical assistance to assist PHAs that must implement" SAFMRs "without fully understanding and incorporating the lessons learned from the Demonstration will result in a product that does not adequately assist those PHAs that must make this [ ] transition." Id. at 8. Relatedly, HUD noted that "[i]mplementing comprehensive guidance that may become quickly outdated as the result of related regulatory burden reduction and reform efforts is likewise problematic." Id. G. The Plaintiffs

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