NCSHA Comments to HUD on Second State Fair Housing Assessment Tool Comments

NCSHA commended HUD for adopting many of the recommendations NCSHA made in our comments on the first iteration of the state assessment tool. These changes make the tool more responsive to state level implementation needs, clarify to some extent what is expected of states, and reduce some of the burden on state agencies. In particular, NCSHA applauded HUD for committing to work with us and HFAs as it develops the state AFFH data and mapping tool (AFFH-T), which state will need to use in conjunction with the assessment tool to develop their Assessments of Fair Housing (AFH), and for providing a separate comment period on the AFFH-T.

However, despite the positive steps HUD has taken thus far, NCSHA still believes the AFH process will remain unreasonably time- and cost-burdensome unless HUD makes further modifications to the tool. Specifically NCSHA urged HUD to:

• Modify the contributing factors discussion requirement to clarify that states do not need to conduct analyses showing a causal connection between contributing factors and fair housing issues;
• Clarify the course of action when a local program participant’s findings in its analysis differ from the findings of the state agency in its analysis;
• Not require states to undertake analyses beyond their borders;
• Make optional any analysis requiring longitudinal study of demographic trends;
• Clarify what is expected of state agencies under the Disparities in Access to Opportunities section of the assessment tool;
• Make optional questions in the Disability and Access Analysis section of the assessment tool that require states to conduct analyses based on type of disability;
• Clarify that states and local program participants can coordinate their community participation process, even if they are not undertaking a joint AFH;
• And ensure language uniformity throughout the state assessment tool, consistent with the changes HUD has made to make the tool more applicable to state-level jurisdictions.