NLIHC has prepared a sample comment letter for advocates who have not studied the proposed Affirmatively Furthering Fair Housing (AFFH) rule to use in submitting comments regarding the rule. NLIHC and other advocacy organizations are generally pleased with the proposed rule and will register their support, while also providing recommendations for improvements to the rule’s final version. NLIHC encourages all advocates to voice their support for the proposed AFFH rule. Comments are due by 11:59 pm ET on April 10.
The sample comment letter highlights six very favorable features of the proposed rule:
- Enhanced community engagement.
- Greater public transparency.
- A public complaint process.
- A stronger link between the AFFH Equity Plan’s fair housing goals and Consolidated Plan and PHA Plan implementation.
- An annual evaluation of progress toward achieving fair housing goals.
- Clarification of and emphasis on the need for a balanced approach to AFFH (using both place-based and mobility strategies and actions).
The sample comment letter also offers suggestions for improving the proposed rule relating to community engagement, public transparency, and annual progress evaluation. There are also recommendations for speeding up the timeline for required revisions to an Equity Plan after a Presidentially Declared Disaster and for improving the definition of “affordable housing opportunities.”
NLIHC’s sample AFFH comment letter can be found at: https://bit.ly/3Kkkscp
NLIHC has released step-by-step instructions for submitting comment letters via Regulations.gov at: https://bit.ly/42RRzeQ
Read NLIHC’s “Overview of Key AFFH Definitions” at: https://bit.ly/3JQkFSY
Read NLIHC’s “Revised Overview of AFFH Community Engagement and Complaint Processes” at: https://bit.ly/3zie6E0
Read NLIHC’s “Overview of the AFFH Equity Plan” at: https://bit.ly/3K4QN5v
Read NLIHC’s “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 easy-to-read 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