The NLIHC Tenant Leader Cohort submitted a comment letter to HUD’s Office of General Counsel, Regulation Division, on April 24 in response to a request for comments on FR–6250–P–01 Affirmatively Furthering Fair Housing, the proposed rule to implement the obligation to affirmatively further the purposes and policies of the “Fair Housing Act” (Title VIII of the “Civil Rights Act of 1968”).
In the letter, the Tenant Leader Cohort commended the Biden-Harris administration for its unprecedented interest in advancing tenant protections through the proposed Affirmatively Furthering Fair Housing (AFFH) rule. While the Tenant Leader Cohort acknowledged the vastly enhanced community engagement provisions in the proposed rule, it raised serious concerns regarding proposed changes to the ConPlan Citizen Participation Regulations and the PHA Plan Resident Participation Regulations.
In an effort to strengthen the Equity Plan, the Tenant Leader Cohort offered the following recommendations: (1) clarify the meaning of “affordable housing opportunities”; (2) strengthen accessibility guidelines; (3) access program participants’ environmental impacts on protected groups; (4) collect robust data for Public Housing and Housing Choice Voucher programs; (5) clearly explain public housing authority (PHA) controlled policies; (6) provide critical sub-regulatory guidance for both Public Housing and Housing Choice Voucher programs; (7) extend the timeframe for public review of the Equity Plan; (8) require program participants to submit revised Equity Plans to ensure AFFH principles are applied to planning associated with disaster-related funding; and (9) strengthen a number of key definitions.
“Housing justice and racial justice are inextricably linked,” reads the Tenant Leader Cohort letter. “As such, large-scale, sustained investments and anti-racist reforms are critical to ensure that people with the lowest incomes have quality homes that are accessible and affordable in communities of their choice.”
NLIHC’s Tenant Leader Cohort is comprised of tenant advocates and community leaders with lived experience of housing insecurity who work towards housing justice and racial equity in their neighborhoods and greater communities. NLIHC collaborates with the Tenant Leader Cohort to inform policy priorities so that these priorities best reflect the needs of low-income renters.
Read the letter here.