HPD is the nation’s largest municipal housing preservation and development agency. Its mission is to promote quality housing and diverse, thriving neighborhoods for New Yorkers through loan and development programs for new affordable housing, preservation of the affordability of the existing housing stock, enforcement of housing quality standards, and educational programs for tenants and building owners. HPD is tasked with fulfilling Mayor de Blasio’s Housing New York Plan to create and preserve a total of 300,000 homes by 2026.

Like many housing agencies throughout the country, HPD began updating its fair housing planning process to adapt to the guidance and instructions laid out in the Assessment of Fair Housing (AFH) tool, including a robust community engagement process, in an effort to meet our statutory obligation to Affirmatively Further Fair Housing (AFFH). While we understand that this updated process requires resources that not all localities have at the ready, we found the guidance between the final AFFH rule, the AFFH Guidebook, and the AFH tool to be helpful when compared to previous guidance, and as a result, we began shifting agency operations to adapt to these updated rules and guidance. Changing this process and delaying implementation removes the public benefit that comes with clearer fair housing guidance and goals.

HUD’s notice cites the difficulties local governments face as they complete their AFH as the reason for the delay, and mentions the need for improved technical assistance, mapping tools, and user interface. Improved assistance and tools, as well as disseminating best practices from the experiences, challenges, and advice of local governments who have begun the AFH process are important as we move forward. As such, an alternative to delaying implementation could be to establish a national network of jurisdictions that share best practices. This would allow jurisdictions to adapt to the new rule, create consistency in best practices for submissions, and would promote HUD’s mission of creating inclusive communities and affordable homes for all Americans.

In order to address segregation and inequality throughout the country, HPD recommends HUD reverse the decision to delay deadlines for grantees’ AFH. HUD must quickly move to provide the improved tools and technical assistance mentioned in the notice.

The City appreciates the opportunity to share these comments with HUD and hopes we will continue to have a strong federal partner in affirmatively furthering fair housing.