NLIHC has prepared “Preliminary Overview of Key AFFH Definitions,” the latest in a series of briefs providing initial overviews of the proposed Affirmatively Furthering Fair Housing (AFFH) regulation. In addition, NLIHC has revised its previous brief, “Preliminary Overview of AFFH Community Engagement and Complaint Process” (see Memo, 2/21). Key AFFH definitions in the first brief include “affirmatively furthering fair housing,” “affordable housing opportunities,” “balanced approach,” “fair housing issues,” “fair housing goals,” “geographic area of analysis,” “meaningful actions,” and “underserved communities.” Each brief includes suggestions for improvements while also voicing concerns about certain provisions. HUD will accept comments until April 10. NLIHC will offer sample comment letters that advocates should consider using.
The revised overview of the community engagement process modifies comments made regarding the proposed rule’s option allowing a program participant to combine the community engagement requirements of the proposed AFFH rule with the public participation requirements of the Consolidated Plan (ConPlan) or PHA Plan requirements. Due to the wording of the proposed changes, which do not seem to effectively support the proposed AFFH rule’s intent to have robust community engagement, NLIHC is urging HUD to remove all provisions allowing such combinations. The AFFH community engagement requirements must be separate from and in addition to the required ConPlan or PHA Plan public participation requirements. In addition, NLHC is urging the final AFFH rule to require four distinct community engagement stages: identifying fair housing issues, prioritizing fair housing issues, setting fair housing goals, and commenting on a draft Equity Plan before it is submitted to HUD for review.
Read “Revised Overview of AFFH Community Engagement and Complaint Processes” at: https://bit.ly/3yAi22p
Read the expanded “Preliminary Overview of the AFFH Equity Plan” at: https://bit.ly/3ZhQzhP
Read “Preliminary Overview of AFFH Equity Plan Submission and HUD Review and Compliance Procedures” at: https://bit.ly/3ZB2Spm
Read NLIHC’s “Preliminary Highlights of Five Positive Overarching Features of the Proposed AFFH Rule,” first provided in Memo, 2/13.
Read NLIHC’s “Key Provisions of the 2023 Proposed AFFH Rule: Based on the Executive Summary and Background Sections of the Preamble,” first provided in Memo, 1/23.
More information about Affirmatively Furthering Fair Housing is on page 8-12 of NLIHC’s newly released 2023 Advocates’ Guide and on NLIHC’s Racial Equity and Fair Housing website of the Affirmatively Furthering Fair Housing webpages.
Find HUD’s preview version of the proposed AFFH rule at: https://bit.ly/3wWsRLH
Find the Federal Register version of the proposed AFFH rule at: https://bit.ly/3RIYfa1