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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Crochet v. Housing Authority, 37 F.3d 607 (1994)

Citation
Crochet v. Housing Authority, 37 F.3d 607 (1994)
Parent Document
Crochet v. Housing Authority, 37 F.3d 607 (1994)
Effective Date
1994-11-04

Other Sections in This Document (37)

Full Text

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While we might agree that cost-effectiveness and uniformity, standing alone, are insufficient to justify THA’s actions, we do not believe that these are the only justifications supporting the conversion. In promulgating the individual metering regulations, HUD authorized the use of both checkmetering and retail service. HUD stated no preference for one method over the other, but left that choice for the PHAs. Since security deposits and arrearage provisions were common when the individual metering regulations were originally promulgated, this indicates that HUD did not consider such provisions inconsistent with the purposes of the Act. Moreover, forbidding a PHA to convert from cheekmetering to retail service could impinge *612on the Act’s stated purpose of vesting in local PHAs “the maximum amount of responsibility in the administration of their housing programs.” 42 U.S.C. § 1487.