“As leading fair housing and community development organizations in New Jersey, we support the implementation of the AFFH rule and a “both and” approach to providing fair housing choice in areas that historically have not had opportunities for many low-income people, people of color, people with disabilities, and other protected classes, and to addressing issues of gentrification and revitalization in neighborhoods that have racially concentrated areas of poverty,”
Wrote the three organizations.
The joint comments focused on the Community Participation Process portion of the Tool and the lack of a requirement that participants address concrete actions in response to the Assessment.
Highlighting with excerpts from the comments, “The tool does not require sufficient participant disclosure or self-evaluation” and
“There must be a place in the Tool that requires applicants state the concrete steps that are needed and that they intend to take, the responsible entity or agency and timelines and milestones for such steps, to move from the recognition of the impact of a determinant, to the removal of barriers and the affirmative creation of fair housing and community integration.”
The National Low Income Housing Coalition (NLIHC) included a variety of resources regarding the AFFH Assessment Tool in its recent Memo to Members. The Assessment Tool will be almost as important as the final affirmatively furthering fair housing (AFFH) regulation, which is expected sometime in 2015.
The Assessment Tool is the document that jurisdictions’ staff will use to develop the AFH, which will replace the Analysis of Impediments (AI) to fair housing choice. The Assessment Tool is the document that advocates will have in hand and it is the document with which residents will be most familiar. Therefore, ensuring that the Assessment Tool has balanced and complete guidance is critical.