Table 1.

Table Assessing Costs and Benefits of Possible HUD Approaches to Smoking in Public Housing

Courses of Action	Costs	Benefits	Comment
HUD takes no regulatory action: PHAs regulate smoking policies on their own.	Long-term continued tobacco smoke exposure in most public housing settings for the foreseeable future.	Encourages more local control and fewer households with smokes would be at-risk for displacement.	The status quo will likely continue to result in more households below or near the poverty level suffering effects of tobacco smoke exposure than higher SES households due to lack of market forces in public housing.
HUD interprets existing air quality requirements to include tobacco smoke.	Without a clear directive to make programs non-smoking, many PHAs would likely maintain status quo resulting in continued exposure and resulting harm to residents. PHAs that take action may be forced to evict non-complying tenants.	Some PHAs may act on regulatory interpretation by prohibiting smoking and would be forced to respond to residents’ complaints concerning air quality problems caused by tobacco smoke.	This intermediate step falls short of directing PHA policy but could lead to an increase in smoke-free public housing without the need for changes in HUD’s granting requirements.
By conditioning full funding, HUD effectively requires all federally-funded public housing to phase-in 100% smoke-free policies.	HUD action would be controversial. Enforcement could require PHAs and Section 8 private landlords to evict non-complying tenants.	Would likely result in dramatic reduction of tobacco smoke exposure and resulting harm for a vulnerable population.	By conditioning full funding on policy compliance by PHAs, HUD is in a unique position to eliminate a major preventable cause of disease from the home where market forces have retarded adoption of such policies.