What Does MCAH Think? | AFFH Rule Comment

AFFH Rule Comment

FFH HUD Open Comment Period April 24, 2023

Michigan Coalition Against Homelessness  (MCAH) applauds HUD for reissuing the Affirmatively Furthering Fair Housing rule that is directed toward HUD program participants (including PHAs) and is designed to eliminate patterns of housing segregation and discrimination.

Requiring assessments of fair housing, planning and dissemination of equity plans will permit transparency, public review of the plans and facilitate holding the program participants accountable for its implementation.

Five-year requirements for the equity plan timeframe may be too long between submissions, as the landscape in a community or across the state could potentially change significantly in five years. HUD may want to consider 3-year time frames and reduce the amount of data and questions that comprise the equity plan, so it is not so onerous to complete in a shorter timeframe.

We support and are in favor of the suggestion to collaborate with other entities in the same jurisdiction in the analysis, planning and goal setting for the plan. The requirement for community engagement, outreach and transparency built into the requirements is to be commended and is certainly a best practice.

The community participation process requirement is valuable and could lead to meaningful dialogue and collaboration. It would be helpful to provide examples of best practices from around the country for guidance to low resourced entities.

The mapping tool and data element looks to be useful, however when tested the data is not currently available. MCAH recommends this feature be live and useable when the AFFH final rule is published to facilitate monitoring by the public, as well as to disseminate useful data.

Other helpful links:

https://www.hud.gov/sites/dfiles/FHEO/documents/AFFH%20Fact%20Sheet.pdf

AFHF Open Comment period ends April 24, 2023:
https://www.hud.gov/AFFH