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B-206888 1 (1982-04-13)

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B-20688


'APR 13J8


The Honorable Christopher J. Dodd
United States Senate

Dear Senator Dodd:


118150


     Your letter of March 19, 1982, requested our views on
S. 2171, 97th Congress, 2nd Session, a bill to stimulate the
development and rehabilitation cf affordable multifamily rental
housing entitled the Rental Housing Production and Rehabilita-
tion Act of 1982. The purpose of the bill is to increase the
Nation's stock of rental and cooperative housing and to reduce
the housing costs of the residents of such housing by encouraging
the construction and rehabilitation of multifamily rental housing
projects and cooperative housing projects for families and indi-
viduals without other reasonable and affordable housina alterna-
tives in the private market. Similar bills were introduced in
the House of Representatives as H.R. 5731 and H.R. 5750. In
introducing S. 2171 you indicated that the propoced prog.rem is
intended to serve as a replacement for the rehabilitation and
new construction ccr'-onents of the Section 8 Rental Assistance
Program.


     S. 2171 hcs a variety of advantages over past production and
rehabilitation programs. The bill incorporates several excellent
features, such as the recuirerFant for recapturing subsidies if
project owners breach Cont. act conditions or convert houJ.-na
developments to condo-Iini1rs during the term of assistance. The
bill also sets several exc.-lent zri ncipes f-ur the oro-rar , such
as its emphasis on cost-ef-e-tiveness and direction of subscie,
primarily to areas exper-senc~ng rental shortaces. We have a nu1-he:
of concerns however, whc' we f-el you shou1  consider reaar-inc
pr cra taraetino, cost:ro-4Es, an= Cvers  ht snd accountab]t.
Based on the Knowledge  ac     n cx   s-- Iv evaiuatina the F-c-
tion 3 _roaram and other F-feral housanc a... r i       r tha   -
tation- programs, we -re also sI:oesl.2nS  a .u.-er of r t
changes, includia  specific thre-Iolds, wh',-ch c believe wou 1
assure that thc trae inc  and -cst c-ntrcl     c      i
S. 2171 !re eFfec ti J                Thesn znecies make eX  12 t
the princiDles you outlined  (2r  i   es lec's>Iatic n.

     We believe the areatest t.otential for -reserving an ade u .te
     multfam~v r~t21hcur4c stocl: 4-S in   e aa c   !'brt
bilitation nd carefuy ---'oiied new c:-.truct:cn. Accord:r:c to
recent Adm.n:otr-j.ion esti::-a5 about 4.z 1__lion renter-occuued

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