Better Coordination 

of Transportation 

and Housing Programs

to Promote Affordable Housing Near Transit 

DEPARTMENTOF TRANSPORTATION

UNI T ED S TAT E S OF A M E RICA

A Report to Congress 

from the

U.S. Department 

of Transportation 

Federal Transit 

Administration

and the

U.S. Department 

of Housing and Urban 

Development
www.fta.dot.gov

Visit PD&R’s Web Site

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FTA-HUD Affordable Housing-Transit Plan August 2008

Better Coordination 

of Transportation 

and Housing Programs

to Promote Affordable Housing Near Transit 

A Report to Congress 

from the

U.S. Department of Transportation 

Federal Transit Administration

and the

U.S. Department of Housing and Urban Development
Federal 

Administration 

Aflordable 

Tramit. 

fiuther 

kJf Simpson + 

U.S. Department 

Of Transportation 

Transit 

Administration 

September 9,2008 

The Honorable John W. Olver 

Chairman, Subcommittee on Transportation, Housing 

and Urban Development, and Related Agencies 

Committee on Appropriations 

U.S. House of Representatives 

Washington, DC 205 15 

Dear Mr. Chairman: 

The Federal Transit (FTA) and the Department of Housing and Urban 

Development (HUD) are pleased to submit a joint report entitled Better Coordination of 

Transportation and Housing Programs to Promote Housing Near Transit to the 

House and Senate Committees on Appropriations. This report is in response to the directive in 

the Joint Explanatory Statement accompanying the Fiscal Year (FY) 2008 Consolidated 

Appropriations Act (Pub. L. 110-161). 

The report outlines strategies developed by FTA and HUD to continue and expand 

coordination in the area of mixed-income and affordable housing near transit over a 3-year 

period (FY 2008 -FY 20 10). The report is a follow-up to recommendations made in the April 

2007 joint FTA and HUD study entitled Realizing the Potential: Expanding Housing 

Opportunities Near 

Please do not hesitate to contact us if we can be of assistance. 

Sincerely, 

es S. 

Administrator Secretary 

Federal Transit Administration Department of Housing and 

Urban Development 

Enclosure 
FTA-HUD Affordable Housing-Transit Plan August 2008



This report responds to the Joint Explanatory Statement 

issued by the House-Senate Conference Committee with the 

FY 2008 Consolidated Appropriations Act. Congress has 

directed FTA and HUD to continue expanding their work in 

the area of mixed-income and affordable housing and transit 

as follows: 

 The conferees direct FTA and HUD [to] develop a best 

practices manual which will serve to assist communities 

as they seek to establish mixed-income transit-oriented 

development. FTA and HUD should also jointly 

report back to the House and Senate Committees on 

Appropriations within six months of enactment, on new 

ways FTA and HUD can better coordinate transportation 

and housing programs to promote affordable housing near 

transit.2

This report outlines strategies developed by FTA and HUD for 

the planning and implementation of this task over three years 

(FY 2008 – FY 2010). 

2 FY 2008 Consolidated Appropriations Act, Publ. L. 

110-161, Joint Explanatory Statement, December 26, 2007.

Introduction

Transit-oriented development (TOD) is increasingly 

recognized as having the potential to improve the quality 

of life for American households, by creating vibrant, livable 

communities in proximity to transit. Improved access to 

transit can reduce transportation costs for working families 

and mitigate the negative impacts of automobile travel on the 

environment and the economy. 

The need for a mix of housing types that is affordable to 

a range of family incomes in proximity to transit is an 

important policy concern at all levels of government, including 

the federal government. Through its policies and investments, 

the federal government can help shape opportunities at the 

regional and local level to meet the growing demand for 

affordable housing near transit. 

Congress has directed the Department of Housing and Urban 

Development (HUD) and the Federal Transit Administration 

(FTA) to address this issue. The House Committee on 

Appropriations, in its Fiscal Year (FY) 2008 Committee 

Report, stated that “the Committee strongly believes that 

transportation, housing, and energy can no longer be 

viewed as completely separate spheres with little or no 

coordination throughout the different levels of government,” 

and has directed FTA and HUD to “better coordinate public 

transportation and housing policies and programs. Better 

planning and coordination on the federal, state and local 

levels can ensure that affordable housing is located closer 

to public transportation and employment centers.”1 The 

Committee also indicated that “the preservation of affordable 

housing should become an integral part of transit-oriented 

development policies.”

1 House Report 110-238 to the “Departments of Transportation, and Housing 

and Urban Development, and Related Agencies Appropriations Bill, 2008,” 

July 18, 2007.
FTA-HUD Affordable Housing-Transit Plan August 2008



Background

On average, Americans spend 52 percent of their incomes 

on housing and transportation. The average American 

household spends approximately 18 percent of its annual 

income on transportation – and lower-income families spend 

as much as 33 percent. For lower-income families, rising 

transportation costs present a particular burden, with oil 

prices surpassing $100 per barrel and gasoline prices exceeding 

$4 per gallon. In some metropolitan areas, households spend 

nearly as much on transportation as on housing. 

One approach to lowering the combined cost of housing and 

transportation is to expand housing opportunities adjacent 

to transit. TOD presents unique opportunities to create 

housing in proximity to public transportation, and to address 

zoning, land use and financing issues that affordable housing 

developers typically encounter when developing mixedincome housing projects. 

Transportation and Housing

A 2004 study commissioned by FTA estimates that the 

demand for housing near transit will increase to 14.6 million 

households by the year 2030, more than double the six million 

households that currently reside within a half mile of transit.4 

There are several examples of linkages between housing and 

transit aimed at capturing this demand. An early example 

is the BART Fruitvale Station in Oakland, California, 

where a HUD-funded senior housing project anchored 

the entire development. San Francisco’s Metropolitan 

Transportation Commission’s Housing Incentive Program 

provides additional funds to transit agencies as an incentive 

to build housing within a quarter of a mile from the transit 

station, using Federal Congestion Mitigation and Air 

Quality (CMAQ) program funds. California includes 

points for TOD in its allocation of Low Income Housing 

Tax Credits. In addition, cities that are developing new fixed 

guideway (rail and bus rapid transit) systems or extensions, 

such as Denver, Colorado, Portland, Oregon, and Phoenix, 

Arizona, encourage development around their new stations. 

Particular emphasis is placed on providing a broad mix of 

3 Realizing the Potential: Expanding Housing Opportunities Near Transit, 

Center for Transit Oriented Development, April 2007.

4 Hidden in Plain Sight: Capturing the Demand for Housing Near Transit, 

Center for Transit Oriented Development, September 2004.
FTA-HUD Affordable Housing Plan August 2008

commercial, residential and retail uses, pedestrian-scale 

approaches to stations, and station-area development plans 

coordinated with existing neighborhoods. Also, Atlanta’s 

Livable Communities Initiative is an innovative example of 

regional action to stimulate housing development adjacent 

to transit.

Although not as easy to accomplish as with a fixed guideway 

rail or bus system, joint development can also jumpstart 

TOD along non-fixed guideway bus routes.5 The Linden 

Transit Center in Columbus, Ohio, is an example of a 

partnership between the Central Ohio Transit Authority and 

community development groups to establish a multi-purpose 

transit center that serves as the catalyst for the revitalization 

of the South Linden neighborhood. This neighborhood 

redevelopment project, in addition to providing affordable 

housing, has helped retain a local factory, thereby preserving 

jobs within the community as well. 

A 2004 Transportation Research Board study found, 

“The state of practice with TOD in the United States is 

generally a healthy one.”6 Local governments, redevelopment 

authorities, regional planning organizations, and even 

public transit agencies have, over time, accumulated an 

arsenal of tools and techniques to get the job done. However, 

many challenges still remain, including how to achieve the 

appropriate mix of uses, the density required to achieve the 

locational and transportation benefits, and the level or type of 

transit service necessary to serve TOD.

The focus of this report is on how TOD can address the 

need for housing that serves an array of incomes. More 

specifically, how can the increased property and land values 

generated by public investment in transit be captured to assist 

in the provision of critically-needed mixed-income housing? 

Developing mixed-income housing near transit presents 

several significant challenges. Primary among these is 

typically the high land cost that results from the market 

demand for housing, office space, and amenities within 

walking distance of transit. This means that attracting 

or supporting mixed-income housing as a significant 

component of TOD will require incentives or policy tools 

that ensure that housing is available for all income groups. 

Other challenges include: zoning and other regulatory 

5 FTA Livable Communities Paper, 1997.

6 Transit Cooperative Research Program Report 102, Transit-Oriented 

Development in the United States: Examples, Challenges, and Prospects, 

Transportation Research Board, 2004.
FTA-HUD Affordable Housing-Transit Plan August 2008

Previous Interagency Efforts

Over the past five years, HUD and FTA have explored 

opportunities to coordinate housing and transportation 

planning and investment decision-making. A June 2003

roundtable hosted by the National Academy of Sciences 

focused on possible data sharing and development of 

geographical information systems (GIS) by the two agencies. 

Following the roundtable, HUD and FTA entered into a June 

2005 Interagency Agreement (IAA) to help communities 

realize the potential demand for transit-oriented housing. 

The IAA was aimed at closing the gap between the projected 

demand for housing near transit in particular metropolitan 

regions, and realizing the development of that housing in 

proximity to new or existing transit corridors in these regions. 

The IAA provided support for a study completed in April 

2007 entitled Realizing the Potential: Expanding Housing 

Opportunities Near Transit8. Conducted by Reconnecting 

America’s Center for Transit Oriented Development, the 

study included case studies of transit corridors in five 

cities: Charlotte, North Carolina; Minneapolis-St. Paul, 

Minnesota; Portland, Oregon; Boston, Massachusetts; and 

Denver, Colorado. Underutilized land that was potentially 

suitable for development was mapped in these locales. The 

study included a number of recommendations for improved 

coordination between FTA and HUD, as well as strategies at 

the State, regional, and local levels. 

8 Reconnecting America, Realizing the Potential: Expanding Housing Opportunities Near Transit, April 2007. Available at www.reconnectingamerica.org. 

barriers to affordable housing; the added complexity of joint 

development projects involving transit agencies, private 

investors, and other public authorities; and the preservation 

of existing affordable housing in the face of upward pressure 

on housing prices.

The actions described in this report are intended to address 

three separate but related facets of the housing challenges 

near transit: 

1. Expand mixed-income and affordable housing 

choices in the immediate proximity of new and 

existing transit stations. With a growing number of 

transit stations funded through FTA’s capital programs, 

there is a need to develop new approaches to financing 

affordable housing within a walkable, half-mile range 

of transit stations, including state and local targeting 

of housing subsidies such as Low Income Housing 

Tax Credits, state bond financing proceeds, and rental 

assistance, as well as the potential use of innovative 

mortgage finance techniques, such as location-efficient 

mortgages. 

2. Develop a more comprehensive approach to 

address household expenditures on housing 

and transportation. It is becoming increasingly 

apparent that housing location choices affect household 

transportation expenditures. Increasingly, families have 

found that while affordable housing could be found 

further out in suburban or exurban locations, often 

without good access to transit, this housing comes at the 

expense of higher transportation costs. A more flexible 

approach to financing and underwriting housing that 

recognizes the associated cost of transportation may be 

needed.

3. Preserve existing affordable housing. A recent 

study showed that there are a significant number 

of HUD-assisted properties that have expiring use 

mortgages in close proximity to transit.7 The preservation 

of these and other federally-subsidized housing units 

within walking distance of transit stations are an 

important element of a mixed-income, transit-oriented 

housing strategy. 

7 National Housing Trust and Reconnecting America, Preserving Opportunities: Saving Affordable Homes Near Transit, 2007, documented 100,000 expiring use units in proximity to transit in eight cities, including 23,000 Section 202 

senior housing units. 
FTA-HUD Affordable Housing-Transit Plan August 2008

Proposed Actions

Building on previous efforts, and in response to Congress’ 

direction, the following strategies are new ways that FTA 

and HUD can better coordinate transportation and housing 

planning and programs to promote affordable housing 

near transit: 

Federal Interagency Working Group

1. Implement Joint FTA/HUD Working Group. 

As directed by Congress, FTA and HUD have established 

an Interagency Working Group to coordinate activities 

between the two agencies. The Working Group meets 

quarterly to coordinate FY 2009 and subsequent research 

activities; monitor development of a TransportationHousing Affordability Index and its possible application 

to specific projects, programs, or policies; identify 

outreach opportunities for coordination of programs or 

housing and transportation planning; develop ongoing 

action plans; and provide input into joint products.

 The Working Group was initially convened in October 

2007 by members of both HUD and FTA headquarters 

offices. Membership includes representatives of the 

following HUD offices: the Office of Community 

Planning and Development, which oversees HUD’s 

consolidated planning requirements; the Office of 

Policy Development and Research, which has sponsored 

previous joint research with FTA on housing and TOD; 

and the Office of Public and Indian Housing and the 

Office of Housing, both of which manage or finance 

a significant volume of mixed-income or affordable 

housing. FTA is represented by: the Office of Planning 

and Environment, which oversees FTA’s transportation 

planning requirements; the Office of Budget and Policy, 

which has sponsored previous joint research with HUD 

on housing and TOD; the Office of Program Management, which oversees FTA’s grants programs; and the 

Office of Chief Counsel, which provides legal advice on 

TOD. HUD field and FTA regional office representatives 

will be included in the Working Group in the future. 

Best Practices Manual

2. Develop a Best Practices Manual for mixedincome housing near transit. As directed by 

Congress, HUD and FTA will prepare a best practices 

manual on mixed-income housing and TOD. The manual 

will provide guidance for local officials on successful 

strategies for implementing mixed-income housing 

near transit. The manual will communicate promising 

initiatives, practical methods for overcoming common 

regulatory barriers, and successful tools for joint or 

coordinated housing and transit planning. Case studies 

of successful mixed-income housing near transit, lessons 

learned, and a compilation of principles and strategies 

used will be included to motivate and guide local 

communities in developing their own projects. 

The manual will be completed and published in FY 2009. 

Outreach and Capacity Building

3. Identify opportunities for joint outreach to 

housing and transit providers and stakeholders. 

HUD and FTA will develop an outreach plan that 

identifies opportunities for engaging stakeholder groups, 

as well as venues, for advancing the joint program 

to both housing and transit providers. The plan will 

outline conferences, symposiums, and workshops where 

joint presentations can be made to diverse transportation 

and housing audiences. These sessions will present best 

practices, resources available for technical assistance and 

project development, projects that can be easily replicated, 

and other tools that can be utilized to better coordinate 

transportation and housing programs and projects. 

 The outreach plan will also identify training opportunities 

that can provide insight into the relationship between 

transportation, land use, economic development, and 

affordable housing, through webcasts, National Transit 

Institute curricula and other options. The HUD-FTA 

Working Group will collaborate with industry partners 

to promote these outreach and training opportunities 

through a variety of media. 
FTA-HUD Affordable Housing Plan August 2008

4. Conduct briefings and workshops for FTA and 

HUD staff. HUD has 82 field offices and FTA has 10 

regional and five metropolitan offices responsible for 

implementation of programs and services across the 

Nation. HUD and FTA will convene teleconferences with 

their field and regional staff to facilitate coordination of 

FTA and HUD activities at the local level. The purpose 

of these sessions will be to expand awareness of regional 

FTA and HUD staff of their respective programs and 

activities, and to improve coordination and delivery of 

joint projects and services. 

5. Enhance capacity building program(s). FTA will 

include mixed-income housing development near transit 

as a specific focus of the joint FTA/Federal Highway 

Administration Transportation Planning Capacity 

Building program, as part of its continuing technical 

assistance to transit providers, public officials, and other 

stakeholders. HUD provides technical assistance through 

the HOME Investment Partnerships or Community 

Development Block Grant (CDBG) programs. The two 

agencies will explore opportunities for utilizing these 

programs in integrating Federal transportation and 

housing planning and program requirements.

To support these activities, HUD and FTA will share 

information and links on their respective websites to provide 

a clearinghouse of resources and information for promoting 

mixed-income housing near transit. The websites would 

provide links to pertinent documents and resource agencies, 

as well as contain materials developed by the two agencies 

(e.g., workshop presentations, guidance).

Regulatory Barriers

6. Identify regulatory barriers to housing near 

transit. HUD and FTA will identify regulatory barriers 

to the coordination of HUD and FTA investments in 

projects adjacent to or near transit. This will be done 

on two levels: first, barriers that might exist in HUD 

and FTA’s own regulations; and, second, state and local 

regulatory barriers to joint development and TOD. 

 At the Federal level, barriers might include inconsistent 

planning requirements between HUD’s Consolidated 

Plan and the Department of Transportation’s (DOT) 

metropolitan and statewide planning requirements, 

or concerning possible restrictions on FHA mortgage 
FTA-HUD Affordable Housing-Transit Plan August 2008

insurance for mixed-use development. Examples 

of barriers at the state and local levels may include: 

zoning codes that are overly restrictive, restrictions on 

density allowances, parking requirements, burdensome 

permitting requirements, complex or duplicative 

planning processes, or outdated rules covering real 

property disposition. 

 FTA and HUD will first invite experts from both the 

housing and transportation industries, along with 

stakeholders, to participate in a roundtable panel 

discussion to identify common barriers. This will be 

followed by an FTA-HUD sponsored white paper on 

barriers to improved coordination, as well as possible 

public policy solutions. Finally, topics for future research 

will be identified that contribute to the knowledge base on 

overcoming barriers to improved land use, housing, and 

transportation planning at all levels of government.

 These efforts to identify and review State and local 

regulations are supportive of HUD’s priority of reducing 

barriers to affordable housing through HUD’s Affordable 

Communities Initiative, as well as of FTA’s broader 

community development goals.

Joint Regional/Metropolitan Planning 

7. Improve coordination of housing and 

transportation planning through HUD’s 

Consolidated Plan and DOT’s Transportation 

Planning requirements, and other mechanisms. 

Both HUD and FTA require local communities to 

prepare long- and short-range plans as a requirement for 

receiving Federal housing and transportation funds. 

• HUD requires states, cities and counties to prepare a 

five-year Consolidated Plan and a one-year Action Plan 

that together identify long-range housing needs, as well 

as short-term funding priorities for HUD’s formula 

grant programs.9 Guidance provided to grantees 

on metropolitan/regional connections includes the 

following:

Clear connections should be established between 

communities, neighborhoods, and the larger 

metropolitan region. Does the jurisdiction’s strategic 

or comprehensive plan connect its actions to the 

9 Community Development Block Grant (CDBG), HOME Investment Partnership programs, and Emergency Shelter Grants (ESG).

larger economic strategies for the metropolitan 

region? Does the plan reference the plans of other 

agencies that have responsibilities for metropolitan 

economic development, transportation, and workforce 

investment?

 In addition to the Consolidated Plan, public housing 

authorities (PHAs) prepare a PHA Plan that could 

also address transportation. The PHA Plan is a 

comprehensive guide to PHA policies, programs, 

operations, and strategies for meeting local housing needs 

and goals. There are two parts to the PHA Plan: the 

Five-Year Plan, which each PHA submits to HUD once 

every fifth PHA fiscal year, and the Annual Plan, which is 

submitted to HUD every year. 

• DOT requires metropolitan areas to develop a 20-year 

Metropolitan Transportation Plan and a four-year 

Transportation Improvement Program (TIP); states 

are required to develop a Long-Range Statewide 

Transportation Plan and a four-year Statewide 

Transportation Improvement Program (STIP). 

Together, these documents identify transportation 

projects proposed for development over both long 

and short time frames. Metropolitan planning 

organizations (MPOs) also are required to prepare, 

over a one- or two-year period, a Unified Planning 

Work Program that describes the planning activities 

for undertaking that work. Preparation of these plans 

and programs is required to be collaborative and 

coordinated with state and local land use, growth, and 

economic development plans.

Coordination between the plans required by HUD and 

DOT could result in improved leveraging of housing 

and transportation funds, and in more effective 

strategies for addressing metropolitan area housing 

and transportation needs. These include preservation 

of expiring-use multifamily properties near transit, 

and prioritizing funding for affordable housing near 

transit facilities. Similarly, in preparing transportation 

plans and programs, state and local officials could 

assign a higher funding priority to transit investments 

that serve mixed-income communities with affordable 

housing. At the same time, different jurisdictions and 

time frames for submission of the Consolidated Plan, 

of metropolitan area TIPs, and of state STIPs present a 

significant challenge to enhanced coordination. 
FTA-HUD Affordable Housing Plan August 2008

10

 Actions to be explored by HUD and FTA may include: 

(1) encouraging collaboration of MPOs or regional 

councils of government with local transit providers 

and housing and community development agencies, 

(2) identifying demonstration projects, and (3) providing better guidance on coordinated housing and 

transportation investments for Consolidated Plan, TIP, 

and STIP submissions. In addition, HUD and FTA 

plan to support the development of a model regional 

housing-transit plan that can provide a template for other 

jurisdictions. 

Policy Analysis, Research and 

Development

8. Identify opportunities for joint research and 

development and policy analysis. HUD and FTA 

will annually identify possible topics for joint research, 

including but not limited to the following: 

• Land use and place-based analysis to link housing 

and transportation planning (including TOD), 

aligning the consolidated planning and metropolitan 

transportation planning processes, and developing 

demonstration projects.

• Development of alternative tools, techniques, and 

methods for addressing housing and transportation 

(e.g., an affordable housing-transportation index that 

reflects combined household expenditures on housing 

and transportation).

• Bridging the gap between local and regional 

scales in data collection, analysis, and information 

dissemination, including the development of userfriendly analytic tools and capacity building for 

the development of local area cadastral databases 

(computerized maps of property boundaries).

• Improving the use of geographical information systems 

(GIS) to support mixed-income housing near transit, 

including refining techniques for identifying and 

mapping underutilized parcels that may be suitable 

for housing development, and/or ongoing mapping 

of expiring use properties within close proximity to 

transit. 
FTA-HUD Affordable Housing-Transit Plan August 2008

11

• Joint research into the relationship between household 

expenditures on housing and transportation, to better 

understand the inverse relationship that can exist 

between affordable housing and transportation costs as 

a share of household expenditures.

• Monitoring and assessing the effectiveness of policies 

and tools that have been deployed to promote or retain 

mixed-income housing in key transit corridors.

• Assessing the role of mortgage financing tools such as 

location-efficient mortgages, which take into account 

the location of properties near transit and include 

transportation cost savings in the underwriting of such 

loans. 

• Identifying how HUD and FTA can improve policy 

coordination and provide incentives through new and/

or existing programs to further promote affordable 

housing near transit corridors, and to include the 

preservation of affordable housing as an integral part of 

TOD policies.

Legislative Research and 

Recommendations

9. Address affordable housing and mixed-income 

housing needs in new legislative initiatives. 

Based upon the recommendations of the HUDFTA Interagency Working Group, FTA will identify 

legislative initiatives for the next surface transportation 

authorization bill and other legislation to increase the 

opportunities, and reduce the challenges, to affordable 

housing near transit. This would improve the alignment 

of FTA and HUD programs.

Performance Measurement

10. Assess the effectiveness of the HUD-FTA Action 

Plan. The Working Group will develop performance 

measures and an associated management information 

system for assessing the effectiveness of the results of joint 

actions taken by the two agencies. Elements may include 

an inventory of affordable housing developments near 

transit, federal funding sources deployed, incremental 

impacts on transit ridership from such developments, 

changes in zoning ordinances that promote affordable 

housing near transit, and other performance indicators. 

A baseline will be established from which annual progress 

would be measured.

Incentives 

11. Identify financial incentives for funding 

affordable housing near transit. There are 

currently no direct incentives through HUD- and FTAfunded programs for locating affordable housing near 

transit. HUD funding for housing is provided in several 

ways: through competitive and formula grants, mortgage 

insurance (for both single family homes and multifamily 

rental housing), and tenant- and project-based rental 

assistance. FTA funding for transit is provided through 

various discretionary and formula grants. FTA’s 

major formula grant program, known as Section 5307 

Urbanized Area Formula grants, provides public agencies 

and bodies with planning, capital, and in certain cases, 

operating assistance to expand transit services on routes, 

communities, and corridors of their choosing. 

 HUD and FTA will assess the feasibility of encouraging 

and/or providing targeted incentives for financing 

affordable housing near transit through these and other 

programs. These might include set-asides of a portion of 

grant funds for jointly funded projects that address both 

housing and transportation, or awards of bonus points in 

rating applications for competitive grant awards through 

such housing programs as HOPE VI or Section 202

Supportive Housing for the Elderly. Consideration could 

also be given to using set-aside funding for the HOPE VI 

program to award bonus funds for projects located near 

transit. For those programs that require a non-Federal 

match, a reduced match or more flexibility in allowing 

non-cash contributions could be considered. However, 

specific statutory authorization from Congress is required 

to support such incentives.

 At the state and local levels, incentives to be considered 

might include density bonuses or establishing faster 

approval and permitting procedures for TODs that 

contain mixed-income housing. Housing authorities 

could also consider incentives for locating Section 8 

project-based developments, and of Replacement Housing 

Factor (RHF) Fund units near transit.10

10 HUD’s Capital Fund Formula rule at 24 CFR 905.10(i) provides that a 

PHA may receive grants to replace units that are demolished or sold. PHAs 

must submit an RHF plan containing a description of the proposed replacement 

housing.