Why RAD worked
By David A. Smith
4 min read
RAD’s birth a little over three years ago could scarcely have been less heralded: tucked obscurely into an appropriations extender, it offered no new money (not a bug, a feature; if RAD had had scoring cost, it could never have emerged from the sausage factory); outside the public housing realm it was greeted with indifference; and within public housing circles it was generally treated with at best hostile vigilance. How then could this unassuming program blow through its original optimistic cap, tripling in size to over 180,000 apartments (nearly 15% of the entire public housing inventory) with no signs of slowing down?
The following 10 reasons, visible with the perceptivity that hindsight affords, can serve as a checklist for stealth reformers seeking to make constructive change in our otherwise sclerotic government:
1. RAD was voluntary. No housing authority is compelled to participate. Aside from eliminating all sorts of legislative hurdles and nasty political trench-warfare opposition, it lets the enterprising and optimistic discreetly separate themselves from the larger observant herd.
2. RAD was long, long overdue. Back in 2006, I wrote three gloomily prescient articles about public housing, starting with The Ghost of Christmas Yet to Come, that prophesied doom unless we did something, and charted a course to a more hopeful future. Six years and a couple of false starts later, RAD was born – and not before time.
3. RAD was (and is) the only game in town. With HOPE VI in a funding coma, housing authorities with inventory reaching physical breakdown, faced two choices: sit and stew while the properties declined by every metric imaginable, or jump into the unknown RAD queue. Even the initially skittish decided they should dabble. Once dabbling, they became absorbed, then enthusiastic.
4. RAD properties had ‘embedded lift potential’ from removal of administrative ballast. Public housing’s governance, a legacy of the Roosevelt Administration (I kid you not), consigns properties to a world of obsolete procedural and administrative burdens that add compliance cost for minimal impact benefit. Simply dumping that ballast created NOI lift, and that NOI lift did wonders to counteract the absence of higher rents.
5. HUD wanted RAD to work. As a small demonstration, RAD could be and was staffed by a few HUD specialists, including some drawn into Federal service explicitly for this purpose, who wanted it to work. With regulatory white space into which to write rules, knowledgeable program practitioners could and did create practical, encouraging guidance. These individuals did the country a great service.
6. RAD offered low-cost, low-risk intake. Knowing that RAD was being greeted skeptically, the program designers wrote their rules for easy entry and no-risk exploration; with only a modicum of documentation, one could toss in an initial application that one could withdraw at any time. We at Recap supplemented that approach by offering a quick feasibility assessment, free to any housing authority that requested one. The combination of easy entry and instant exit encouraged the curious and disarmed the fearful.
7. Early adopters showed the way. Voluntary application meant the first submissions were doubly self-selected: good and entrepreneurial housing authorities (many from the West and Pacific Northwest) and good properties. These early adopters showed that RAD was possible and how to do it; the observant herd could then mimic and modify the pioneers’ paradigms.
8. As a demonstration, RAD could evolve quickly. Being framed only out of appropriations provisos, RAD was governed by HUD administrative notices; these in turn were informed by the early-adopters’ suggestions (Recap alone submitted 15 pages of technical comments) and initial properties. Learning by doing is speedy; rule-writing by practitioners who are domain experts beats hollow the clanking machinery of full-blown program rollout.
9. Liberated RAD properties could attract new resources. Not only is legacy public housing encumbered with anachronistic regulatory chains, it is precluded from tapping every post-Roosevelt revitalization resource: allocated LIHTC, volume-cap bonds, HOME and CDBG and state/ local trust funds. Shedding the legacy public housing covenant made these RAD properties not only eligible for new money but also, because of their location, age, deeply impacted tenancy, capital backlog, and sponsorship, high-scoring QAP candidates.
10. RAD tiptoed into existence without being ‘authorized’. Although most legislation follows a classical sequence – authorize in law first, then appropriate to fund – through a quirk in the legislative process a program can be piloted via appropriations, which outflanks the scrums of hearings, testimony, symbolic posturing, and Capitol Hill lobbying. Because RAD was so overlooked in its gestation, nobody bothered to oppose it or to hang their own personalized agendas onto it. Born remarkably free of extraneous clutter, RAD could grow as made sense.
Affordable housing visionaries take note: not all revolutions must be announced. Some of them triumph before anyone notices.
