Repositioning Frequently Asked Questions

Q: What does HUD mean by “repositioning public housing”?

A: Repositioning public housing means moving public housing units to a more stable funding and flexible management model rather than the more traditional public housing model. Through repositioning, public housing agencies (PHAs) and their partners are able to access financing to repair and preserve units to provide better homes to thousands of families and more flexibly manage their affordable housing to better meet local needs. PHAs and local communities can voluntarily choose to reposition their units by converting their current public housing subsidies to project-based rental subsidies or to tenant-based vouchers.

Q: Why is there a need for public housing repositioning?

A: Federal funding does not and will not meet growing public housing rehabilitation needs. The nation’s approximately 1 million public housing units have unmet capital needs that were conservatively estimated at almost $26B in 2010, and this figure grows by $3.5B every year. As more and more units fall into disrepair, fewer families will have access to livable units. The Department encourages local communities to evaluate their public housing assets to determine if repositioning their public housing units could better meet their affordable housing needs.

Q: What are other examples of similar efforts undertaken by HUD?

A: HUD has offered PHAs the opportunity to revitalize, improve, and replace their public housing units through RAD, Choice Neighborhoods, demolition and disposition, HOPE VI Grants, mixed-finance public housing development, the Operating and Capital Fund Financing Programs, and Energy Performance Contracts. These have all been attempts to make changes to a 50+ year old model that has left many public housing units severely underfunded and overregulated. Our repositioning efforts are intended to ensure that public housing units remain affordable and in good physical condition for decades to come through a mix of federal, local, and private funding.

Q: What strategies can PHAs use to reposition their public housing units?

A: In addition to the strategies listed above, the Department is encouraging PHAs to consider repositioning their units through the Rental Assistance Demonstration (RAD), voluntary conversion, disposition or demolition through Section 18, or the retention of public housing assets after a Declaration of Trust release.

Q: Will there still be public housing?

A: Yes. Just like previous repositioning efforts did not signal the end of the Public Housing program, neither does this effort. Many PHAs provide and will continue to provide safe, financially stable, and affordable homes to families across the country.

This effort helps PHAs that are struggling with a complex web of public housing rules and limited funding by providing them with other options to better maintain and manage their units, allowing them to provide better homes for thousands of families.

Q: What is RAD?

A: The Rental Assistance Demonstration (RAD) was enacted by Congress in 2011 and enables PHAs and owners to convert certain properties from their original sources of HUD financing to project-based Section 8 rental assistance contracts, either through the Project-Based Rental Assistance (PBRA) or Project-Based Voucher (PBV) program. The current public housing unit conversion cap for RAD is 455,000 units. Over 120,000 public housing units have been converted through RAD in transactions that leveraged over $7.0B in private financing for modernization and rehabilitation.

Q: What is Section 18 demolition or disposition?

A: Section 18 refers to Section 18 of the U.S. Housing Act of 1937. This section authorizes a PHA to demolish and/or dispose of public housing with HUD approval if the units meet the criteria of current guidance. PHAs may choose to exercise this option for a variety of reasons, such as poor physical condition (obsolescence) of the units, unsuitable location (health or safety risks to residents), unsustainable scattered-site units, very small PHAs (50 units and under), or combining Section 18 disposition with a RAD transaction. Families residing in units that receive Section 18 approval are protected with comparable housing resources (generally Section 8 assistance though an award of Tenant Protection Vouchers). See PIH Notice 2018-04 for more details.  

Q: What are voluntary conversions?

A: This refers to PHAs’ ability to voluntarily decide to remove their public housing units from a public housing Annual Contributions Contract (ACC), authorized under Section 22 of the U.S. Housing Act of 1937. Families residing in these units receive tenant-based vouchers. Generally, PHAs must demonstrate that it is more cost-effective to issue tenant-based assistance than to continue to operate the project as public housing. The Department recently published the Streamlined Voluntary Conversion PIH Notice 2019-05 that waives the cost-test requirement and makes it simpler for PHAs operating 250 or less public housing units to undergo this process.

Q: What is a Declaration of Trust (DOT) release?

A: A Declaration of Trust (DOT) is legal instrument that grants HUD a formal interest in a public housing property. A DOT is recorded in the local county records. Releasing a property from a DOT is a required step if a PHA wishes to sell the property. The Department generally only grants a DOT release for non-dwelling property. However, if the PHA demonstrates that the property is longer needed as public housing the Department may grant a PHA a DOT release for a dwelling property with public housing units. See PIH Notice 2016-20 for more details.  

Q: What is HUD doing to directly help PHAs with repositioning efforts?

A: In recent years, through RAD and new flexibilities in demolition, disposition, and voluntary conversion, HUD is offering PHAs the additional strategies to reposition their public housing units. Staff have also been reaching out to PHAs to help think through repositioning options that could benefit their communities. We’re also providing more training and technical assistance to PHAs, like assistance with submitting successful Section 18 applications and providing individual technical assistance to small PHAs weighing their repositioning options.

Q: What is the resident impact?

A: Public housing families will continue to have access to units that are affordable to them. All of these repositioning strategies require resident consultation and communication and protect residents by requiring PHAs to offer residents comparable housing. These units might not be public housing but may be assisted through a Housing Choice Voucher or a resident could live at a property funded through a long-term rental assistance contract with HUD. PHAs should keep residents updated and engaged while developing their repositioning plans, including any potential need for relocation.

Q: How will PHAs keep the public aware of their repositioning plans?

A: PHAs’ repositioning plans are subject to public notification and comment through the PHA planning process. Public Housing Field Offices will continue to monitor and approve PHA plans to ensure that notification and other residents rights are protected.