***THE HOUSING AUTHORITY OF THE***

***COUNTY OF SCOT**TS BLUFF, NEBRASKA***

***89A WOODLEY PARK ROAD***

***GERING, NEBRASKA 69341***

*[PHONE #: ]{.underline}*[(308)]{.underline}***[
]{.underline}*[632-0473]{.underline}**[ ]{.underline}*[FAX #:
]{.underline}****[(308) ]{.underline}*[632-0476]{.underline}**

October 8, 2008

Regulations Division

Office of General Counsel

Department of Housing and Urban Development

451 Seventh Street, SW., Room 10276,

Washington, DC 20410-0500

Docket Number: HUD-2008-0087

Title: FR-5094-P-01

Dear Sirs,

Thank you for accepting my comments on HUD-2008-0087, Title
FR-5094-P-01-

"Public Housing Evaluation and Oversight: Changes to the PHAS and
Determining and Remedying Substantial Default"

There are some positive changes in this regulation:

1.  No resident survey (although we have always received the 9 or 10
    points on

tis indicator) I created much confusion with our residents and we had to

Really educate on the importance of completing and returning the survey.

1.  Basing financial sub-indicators on public housing financial data,
    rather than

Entity wide is also a good move.

However, I believe there are other changes that may not produce an
accurate

Assessment of the housing authority:

1.  Definitely some reasonable accommodation needs to be made for the
    lack of

100% funding of operating subsidy and Capitol funds. Particularly when
the

Funding shortfall is not a temporary occurrence, but has continued for
years.

2\) Not providing a three year hiatus in the physical inspection when a
property

scores well as is done in multifamily is certainly a costly and
unnecessary burden

for both HUD and the Housing Authority

3\) The establishment of more stringent standards for several
sub-indicators, such as

requiring a 98% occupancy rate, turning tenant-generated work orders
around in 3

days, and completing vacancy turnaround in 15 days, to get an "A" in
these respective

sub-indicators will definitely hurt the majority of Housing Authorities,
mine included!

We operate in several small, rural communities that have less than 300
people, limited

business development, usually no grocery store and definitely no doctors
or hospitals.

One of the developments is near a cattle feedyard with thousands of head
of cattle

being fattened for slaughter. Although some people say, "It smells like
money,"

others do not appreciate the smell of cattle manure that infiltrates
their entire commun-

ity. So lease-up of 98% is unrealistic and unattainable for many rural
housing

authorities, no matter how much they market and advertise! Reducing
vacancy turn-

around to 15 days will penalize the Housing Authorities even more! And
though you

will not designate individual projects as troubled....the rating on your
housing

authorities will significantly decline as has our funding. So in
reality, HUD will be

producing it's own future of declining housing authorities. Housing
Authorities that

are well managed and taking care of good units, will not be reflected on
as such.

4\) Increasing the value of the sub-indicator alone to 16 points will
cause lower cores in

the majority of Housing Authorities. One has to wonder if HUD wants
Housing

Authorities to fail by these unrealistic regulations at a time with
failing banks,

foreclosures on homes and a poor economy, families will be turning to
housing

authorities for more assistance. With poor ratings, Congress will be
less likely to

provide full funding and the finger will again be pointing at HUD as to
where it went

wrong.

5\) Nevertheless, another point of concern is the elimination of the
Board of Review

process for appeals of either PHAS scores or troubled designations.

6\) The cost of the on-site physical inspections, which HUD Field
Offices say they have

neither the staff nor the travel monies to fund, could better be spent
investing in the

Housing Authorities rather than building another level of HUD, similar
to the REAC

Program.

I appreciate your efforts to develop better regulations and hope that
these comments will

Be taken in the vain of constructive comments to build better housing
authorities for people in need of safe, decent housing. Recently, our
housing authority participated in

The What a Home Means to Me" poster contest. I am submitting some of the
entries for

The elementary and middle school division....I think it is always
helpful to remember WHY we are in the business and WHO we impact the
most.

Sincerely,

Nancy

Nancy J. Bentley, Executive Director

Scotts Bluff County Housing Authority