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What Does Project 2025 Say?

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On November 5, 2024, the United States Elected Donald J. Trump to a second term. The day after that, his allies gleefully admitted that Project 2025 was their – and his – agenda the entire time.

This is what we’re up against.

Section 3.6: Department of Housing and Urban Development

The following is a contextual analysis of Section 3.6 of Project 2025, which was written by Ben Carson, and encompasses pages 535 to 548 of the document.

Carson served in the Trump administration as the 17th United States Secretary of Housing and Urban Development from 2017 until 2021. Carson ran in the 2016 Republican primary, before eventually dropping out and endorsing Trump.

More About Ben Carson here.

Word Count: 2,218. Estimated average read time: 9 minutes.

Direct quotes from the Project 2025 document appear in large blue text.

“In addition, HUD programs tend to perpetuate the notion of bureaucratically provided housing as a basic life need and, whether intentionally or not, fail to acknowledge that these public benefits too often have led to intergenerational poverty traps, have implicitly penalized family formation in traditional two-parent marriages, and have discouraged work and income growth, thereby limiting upward mobility.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 535, paragraph 2.)

The argument that HUD (Department of Housing and Urban Development) programs have “implicitly penalized family formation in traditional two-parent marriages” likely refers to how certain public assistance programs, including housing benefits, use income thresholds to determine eligibility. In two-parent households, the combined income of both parents can push the family above the income limit for receiving assistance, effectively reducing or eliminating benefits.

He’s arguing that this discourages people from getting married, so they can stay on federal aid. I’d argue that if HUD programs are indeed leaving married couples with families behind, perhaps we need to revisit the way the programs are structured. I suspect Carson will argue for stripping unmarried people of benefits, rather than raising the income threshold for needy families.

Next, Carson argues that HUD offices should be mostly headed by political appointees by the administration, rather than career professionals. This is another argument for staffing the Federal Government with loyalists to the regime. He goes on for pages describing each office – this begins on page 536, paragraph 4 and is mandated specifically on page 540, paragraph 3:

“HUD political leadership should immediately assign all delegated powers to politically appointed PDAS, DAS, and other office leadership positions; change any current career leadership positions into political and non-career appointment positions; and use Senior Executive Service (SES) transfers to install motivated and aligned leadership.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 540, paragraph 3.)

“It is hoped that a future Congress under conservative leadership will enact legislative reforms of HUD programs. With or without congressional action, however, it is vital that a conservative Administration immediately institute guardrails across HUD programs to remove the administrative state’s bureaucratic overreach of Article I authorities, thereby ensuring formal execution of Article II process and personnel reforms of the sort outlined below.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 540, paragraph 1.)

This is an opinion that HUD has become too powerful or independent, making decisions that should be under the control of Congress or the president.

“The Secretary should initiate a HUD task force consisting of politically appointed personnel to identify and reverse all actions taken by the Biden Administration to advance progressive ideology.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 540, paragraph 5.)

Carson does not detail here what these policies are, so let’s investigate what he could possibly mean by “progressive ideology” as it pertains to affordable housing:

Biden’s administration revived a rule designed to combat housing discrimination1, which Trump derided as ‘Abolishing the Suburbs’. The goal of the rule was to promote integration and reduce racial discrimination for affordable housing.

HUD has promoted environmentally friendly policies in affordable housing2, such as energy-efficient building codes. I’m guessing this one isn’t what Carson means, since this plan was announced in September 2024, after this document was written. The new rules expanded options for safe, affordable, and energy-efficient manufactured homes.

Biden-Harris efforts to expand affordable housing, rental assistance, and homelessness initiatives3 might be viewed as progressive and targeted for rollback.

Biden’s administration has focused on addressing systemic inequities in housing access4 based on race, gender, and LGBTQ+ identity, which probably qualifies as “woke” according to the Heritage Foundation.

During the COVID-19 pandemic, the Biden administration supported eviction moratoriums and rental protections, which might also be perceived as a progressive stance in housing policy.

So we’ve come up with five concrete examples of Biden-era policies with regard to government housing assistance. Rolling these back would promote discrimination, racism, exacerbate climate change, and put people out on the street. Seems on-brand for Republicans.

“Immediately end the Biden Administration’s Property Appraisal and Valuation Equity (PAVE) policies and reverse any Biden Administration actions that threaten to undermine the integrity of real estate appraisals.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 540, paragraph 7.)

The PAVE task force5 is intended to tackle racial and ethnic biases in home valuations. This was after a report from the Federal Home Loan Mortgage Corporation which found that appraisals for home purchases in majority-Black and majority-Latino neighborhoods were roughly twice as likely to result in a valuation below the actual contract price compared to appraisals in predominantly white neighborhoods. In short, if you were a black family, appraisers were telling you that your house was worth less than a comparable house in a comparable neighborhood that was owned by a white family.

In practice, what these changes looked like were things like drafting guidance empowering consumers to take action against appraisal bias, increasing transparency, requiring VA (Veterans’ Affairs) appraisers to undergo appraisal bias training, et al. [Source]6

Carson is arguing here that guarding against racial discrimination “threatens” real estate appraisals, which is transparently ridiculous. I feel like I should point out that he, himself, is a Black person. It’s unclear what he thinks “reversing” these practices will do. Bring back that sweet racial discrimination?

“Repeal climate change initiatives and spending in the department’s budget request.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 540, paragraph 8.)

I was right about that one. Let’s make manufactured homes less efficient and less safe!

“Repeal the Affirmatively Furthering Fair Housing (AFFH) regulation reinstituted under the Biden Administration and any other uses of special-purpose credit authorities to further equity.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 541, paragraph 1.)

Right again.

“Eliminate the new Housing Supply Fund.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 541, paragraph 2.)

There’s one I didn’t think of. The New Housing Supply Fund is designed to increase the availability of affordable housing by providing funding to support the construction and development of new homes. There are a lot of philosophical reasons someone might argue for ending this – opposition to public housing in general, reducing government spending, et al. Carson may even believe that private home developers will step in and provide affordable housing if we reduce government intervention (I’ll leave it to you to decide how likely you believe that one is.) 

The bottom line, however, is that this would cause a reduction in the affordable housing supply, particularly for low-income households and vulnerable populations. This would lead directly to increased homelessness, higher housing costs, and higher rent. If we make it more difficult for people to find affordable housing, we’re widening the gap between the rich and the poor even further.

High housing costs can stifle local economies, because workers may not be able to afford to live in areas where jobs are available. Eliminating the New Housing Supply Fund could worsen the affordability crisis in such areas, making it harder for local businesses to attract and retain employees, which could hinder economic growth.

The housing supply fund also supports the construction industry, creating jobs for workers involved in building affordable housing in the first place. Eliminating the fund would reduce demand for construction jobs, particularly in regions dependent on affordable housing projects.

Without federal funding from the New Housing Supply Fund, local governments may be forced to address affordable housing needs on their own, potentially straining their budgets. Cities and states with fewer resources may struggle to meet housing demand, particularly as federal assistance decreases.

Affordable housing developments often come with access to critical social services (e.g., healthcare, employment assistance). The elimination of the fund may reduce the availability of these services for people who need them most.

And that’s just in the short term. Long-term, housing instability is closely linked to poor health outcomes, mental health issues, chronic diseases, and a shorter life expectancy. Children who grow up in unstable or inadequate housing have poorer developmental outcomes.9

“The Office of the Secretary should recommence proposed regulation put forward under the Trump Administration that would prohibit noncitizens, including all mixed-status families, from living in all federally assisted housing.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 541, paragraph 2.)

Mixed-status families would include American citizens who are married to an immigrant, and their children.

According to HUD’s OWN ANALYSIS7, this proposed rule would result in the eviction of 25,000 immigrant families, including 55,000 children eligible for housing assistance. In fact, two-thirds of people in mixed-status families are already U.S. citizens; the majority of them children.

That’s a lot of homeless families and children, who would be kicked out of their homes for no reason other than racism and xenophobia.

“The withdrawal of this extremely harmful proposed rule is a win for fair housing – and human decency.”

“Where admissible in regulatory action, HUD should implement reforms reducing the implicit anti-marriage bias in housing assistance programs, strengthen work and work-readiness requirements, implement maximum term limits for residents in PBRA and TBRA programs, and end Housing First policies so that the department prioritizes mental health and substance abuse issues before jumping to permanent interventions in homelessness.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 541, paragraph 4.)

So, in a nutshell, bring back racial discrimination practices in affordable housing and housing evaluations, make it more difficult for people to access affordable housing, implement term limits for the amount of time people can live in affordable housing (which will cause homelessness amongst the disabled community – they don’t magically become “abled” after a term limit), and end Housing First policies, which will exacerbate homelessness and addiction.

Housing First policies have been proven to be effective. What it is, is the principle that whatever else a person has going on – drug addiction, joblessness, chronic homelessness, trauma, mental health issues, or what-have-you – you can address those issues more effectively if you get them into stable housing and solve that problem first. It’s the idea that stable shelter is the foundation you can build a life upon, and without it, resolving your other issues becomes extremely difficult, if not impossible. The evidence was reviewed by HUD itself, which found:

“In findings much like those of similar U.S. studies, Housing First proved to be more effective than TAU at achieving housing stability: During the 2-year course of the study, Housing First participants spent 73 percent of their time stably housed, whereas the control group was stably housed only 32 percent of the time.” [Source]8

“Stories about the disproportionate and costly use of hospital systems by individuals experiencing chronic homelessness were further reinforced by media reports, especially Malcolm Gladwell’s New Yorker story “Million Dollar Murray.” A 2010 report from the U.S. Department of Health and Human Services (HHS) found similarly that “the top 5 percent of hospital users — overwhelmingly poor and housing insecure — are estimated to consume 50 percent of health care costs.”

Even the Bush administration couldn’t argue with the results:

“The George W. Bush administration embraced Housing First principles, which contributed to a 30 percent reduction in homelessness rates in the United States between 2005 and 2007.”

Here’s the part Carson is offended by, and it’s 100% spite:

“In December 2022, the Biden-Harris administration released All In: The Federal Strategic Plan to Prevent and End Homelessness. The plan aims to decrease overall homelessness in the United States by 25 percent by January 2025.”

Ben Carson: Purposely making homelessness worse to own the libs.

“Statutorily restricting eligibility for first-time homebuyers and abandoning the affirmative obligation authorities erected for the single-family housing programs across federal agencies and government-sponsored enterprises.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 542, paragraph 5.)

This is a specific recommendation Carson is making. Translated into human-speak, it means creating laws that limit who can be classified as a “first-time home buyer”. Currently, there are various government programs (such as FHA loans), that offer benefits like lower down payments or special mortgage rates to first-time home buyers to make home ownership more accessible. So, Carson wants to reduce how many people qualify for this, creating barriers to home ownership (and resulting in an inevitable market slowdown if fewer people can buy homes.)

This is in direct opposition to the upward mobility opportunities Carson claims to want for Americans. Furthermore, “affirmative obligation” refers to the dute that federal agencies like Fannie Mae and Freddie Mac have to actively promote and ensure access to housing opportunities, particularly for underserved communities or individuals. Abandoning these obligations means that the government would no longer be responsible for ensuring fair housing opportunities or supporting affordable home ownership programs. It would also increase housing discrimination.

“Longer-term reforms of HUD rental assistance programs should encourage choice and competition for renters, encourage participation by landlords where appropriate, and encourage all non-elderly, able-bodied adults to move toward self-sufficiency.” (Project 2025, Section 3.6: Department of Housing and Urban Development, Ben Carson, page 543, paragraph 2.)

Oh good, because more competition and landlord participation won’t drive rents much, much higher than they already are. /sarcasm

Sources Cited:

  1. Capps, Kriston (January 19, 2023), Biden Revives Housing Rule That Trump Derided as ‘Abolishing the Suburbs’, Bloomberg.
  2. HUD Public Affairs (September 11, 2024), HUD Updates Regulations to Lower Housing Costs and Build Safe and Affordable Manuactured Homes, U.S. Department of Housing and Urban Development.
  3. HUD Public Affairs (May 7, 2024), Biden-Harris Administration Announces $5.5 Billion in Grants for Affordable Housing, Community Development, and Homeless Assistance to Drive Economic Growth, U.S. Department of Housing and Urban Development.
  4. February 21, 2023, President Biden Signs Executive Order to Advance Racial Equity and Support for Underserved Communities through the Federal Government, National Low Income Housing Coalition.
  5. USDA (April 10, 2023), Biden-Harris Administration Tackles Racial and Ethnic Bias in Home Valuations, U.S. Department of Agriculture / Rural Development.
  6. March 23, 2023, FACT SHEET: Biden-Harris Administration Tackles Racial and Ethnic Bias in Home Valuations, The White House.
  7. April 5, 2021, HUD Withdraws Proposed Mixed Status Rule, National Low Income Housing Coalition.
  8. Evidence Matters (Spring/Summer 2023), Housing First: A Review of the Evidence, Office of Policy Development and Research (PD&R).
  9. Gaylord, Abigail L.; Cowell, Whitney J.; Hoepner, Lori A.; Perera, Frederica P.; Rauh, Virginia A.; Herbstman, Julie B. (September 15, 2024), Impact of Housing Instability on Child Behavior at age 7, National Library of Medicine, National Center for Biotechnology Information..