This week, NCSHA submitted comments to HUD in response to the Department’s Advance Notice of Proposed Rulemaking (ANPR) on streamlining and enhancing its Affirmatively Furthering Fair Housing (AFFH) Final Rule. The comment letter underscores NCSHA’s support for meaningful, data-driven fair housing planning that is also mindful of HUD program participants’ capacity, available resources, and jurisdictional authority.
NCSHA urged HUD to continue to differentiate between state and local program participants as it works to design implementation systems for AFFH compliance and to ensure that AFFH planning requirements are not unreasonably costly for grantees. NCSHA also recommended that HUD recognize not only the importance of investment in high opportunity areas but also revitalization of under-served communities and not penalize program participants for their efforts to preserve existing affordable housing in areas in need of revitalization. NCSHA’s comments also respond to specific questions HUD posed in the ANPR related to community participation, use of data, reporting procedure, and HUD’s evaluation of program participants’ efforts to further fair housing.