On January 19, 2021, HUD issued PIH Notice 2021-07 on the Demolition and Disposition of Public Housing under Section 18 of the U.S. Housing Act of 1937. This Notice supersedes and replaces Notice PIH 2018-04. This Notice describes examples of expanded eligibility for projects to "blend" project-based voucher ("PBV") assistance through a Rental Assistance Demonstration ("RAD") conversion with assistance from tenant protection vouchers ("TPVs") that are awarded through a Section 18 disposition approval, even if those units would not otherwise qualify for disposition. This Notice replaces the 75%/25% blend under PIH Notice 2018-04 to allow units in a project to qualify for Section 18 on a graduated scale based on the percentage of Housing Construction Costs ("HCC") that is met as part of the RAD conversion. Generally, if HCC exceeds 90% then up to 60% of the units may be disposed of through Section 18 (or up to 80% of the units in a high cost area); if HCC exceeds 60% then up to 40% of the units may be disposed of through Section 18; or if HCC exceeds 30% then up to 20% of the units may be disposed of through Section 18.
- View The 2020 HCC Limits
- HUD has also developed an Excel tool available on the RAD Resource Desk that PHAs can use to assess whether the scope of work meets any of the thresholds for the Construction Blends and whether the site is in a high-cost area.
In addition, the aggregate number of replacement units (RAD and PBV) must meet the RAD "substantial conversion of assistance" requirements, the replacement units must be either new construction or substantially rehabilitated, and the project may not utilize 9% low-income housing tax credits. The Notice also provides a new RAD/Section 18 blending option for small PHAs with 250 or fewer public housing units under which up to 80% of the PHA's units in a RAD converting project may be disposed of under Section 18, provided that the PHA must submit a repositioning plan to HUD for removal of its remaining units from the public housing program. The new RAD/S18 blends will assist PHAs with preserving public housing assets, as all units removed under Section 18 must be used as Project-Based Voucher (PBV) housing.
RAD/Section 18 Blend Webinar. On February 17, 2021, HUD held a webinar on the RAD/Section 18 blends. View slides and video.