{"id":259011,"date":"2025-08-06T10:00:05","date_gmt":"2025-08-06T14:00:05","guid":{"rendered":"https:\/\/ncrc.org\/?p=259011"},"modified":"2025-08-06T17:36:52","modified_gmt":"2025-08-06T21:36:52","slug":"how-municipalities-can-better-leverage-affhs-community-engagement-requirement","status":"publish","type":"post","link":"https:\/\/ncrc.org\/how-municipalities-can-better-leverage-affhs-community-engagement-requirement\/","title":{"rendered":"How Municipalities Can Better Leverage AFFH\u2019s Community Engagement Requirement"},"content":{"rendered":"

All Americans deserve to live in inclusive communities where everyone has access to the resources that their communities desperately need. But a federal program designed to make that happen is going underused by local officials who often aren\u2019t aware of its existence. If properly utilized, the program\u2019s provisions towards creating more equitable housing outcomes would give neighborhoods a vital boost in uncertain economic times.\u00a0<\/span><\/p>\n

The program is called <\/span>Affirmatively Furthering Fair Housing (AFFH)<\/span><\/a>. AFFH was created a decade ago during the Obama Administration when, in 2015, then-HUD Secretary Juli\u00e1n Castro implemented AFFH as a regulation. The underlying concept of AFFH was based on the Fair Housing Act, which was<\/span> Title VIII of the Civil Rights Act of 1968<\/span><\/a> but has gone largely<\/span> unenforced for decades<\/span><\/a>.<\/span><\/p>\n

AFFH is a regulation that <\/span>requires<\/span><\/a> states, counties and municipalities to demonstrate how they use federal funds to address patterns of racial segregation and unequal access to housing, and how they\u2019re helping racially or ethnically concentrated areas of poverty transform into <\/span>areas of opportunity<\/span><\/a>. If implemented properly, AFFH has the potential to challenge housing discrimination that limits housing choice due to <\/span>protected characteristics<\/span><\/a>, such as race, national origin, disability and other attributes.\u00a0<\/span><\/p>\n

AFFH also has the potential to expand access to critical community resources. For example, it could help ensure that all communities have access to decent, safe and affordable housing during a growing affordable housing crisis. AFFH could help communities obtain additional resources, such as<\/span> affordable housing near public transportation<\/span><\/a>,<\/span> higher performing <\/span>public schools<\/span><\/a> and legal representation for<\/span> low-income tenants facing eviction<\/span><\/a>.\u00a0<\/span><\/p>\n

Since it first implemented AFFH in 2015, the US Department of Housing and Urban Development (HUD) has issued multiple iterations of the regulation, usually with the intent of strengthening the rule. However, after the Biden Administration failed to finalize the 2023 AFFH Interim Final Rule (IFR), the current administration replaced the previous rule with a new AFFH IFR published this year.<\/span><\/p>\n

Unfortunately, the current AFFH IFR fails to adhere to the spirit of the 2021 AFFH IFR in several important ways. The 2025 IFR strips AFFH of several critical provisions, such as requiring municipalities to provide detailed plans for how they will affirmatively further fair housing. Instead, municipalities only have to <\/span>certify in writing<\/span><\/a> that they will affirmatively further fair housing without providing supporting evidence that such initiatives are actually taking place.\u00a0<\/span><\/p>\n

Essentially, the 2025 rule relies on local leaders and their developer partners to operate in good faith. We should not expect that to happen on its own, given <\/span>the history of vociferous opposition to fair housing<\/span><\/a> efforts. The <\/span>2025 AFFH IFR<\/span><\/a> also does not mention whether HUD will give municipalities technical assistance, data collection, mapping or assessment tools to diagnose their fair housing issues. This support is vital to help them take the necessary steps to affirmatively further fair housing in their communities.\u00a0<\/span><\/p>\n

Most concerning, the 2025 rule omits the community engagement process entirely. One of the core elements of AFFH is <\/span>its community engagement requirement<\/span><\/a>. As part of their AFFH plans, municipalities are required to conduct robust community engagement efforts, including at community meetings and through surveys. That mandated outreach allows community members to call attention to the barriers they have encountered in having true housing choice and ensures local advocates can highlight current gaps in neighborhood reinvestment.<\/span><\/p>\n

These community engagement efforts are important because they allow residents to advocate for local reinvestment in their communities via a transparent process. Well-executed AFFH plans incorporate concerns that residents identify during the community engagement process and develop initiatives to address those concerns.<\/span><\/p>\n

Boston provides an example. The city ultimately amended its zoning code to prevent further exclusion of vulnerable residents, after local activists <\/span>turned out around 500 residents to speak up<\/span><\/a> at the meetings about historic exclusionary practices. <\/span>The Boston Tenant Coalition (BTC)<\/span><\/a>, an NCRC member, provided critical resources to help remove obstacles to some residents\u2019 participation in community meetings, such as providing meals<\/span> and childcare<\/span><\/a> to community members during in-person listening sessions.<\/span><\/p>\n

Additionally, <\/span>clear<\/span><\/a> and accessible language helped<\/span> residents understand and accurately complete fair housing surveys that the BTC and the Boston Housing Authority (BHA) distributed to community meeting attendees and<\/span> public housing residents<\/span><\/a>. As a result, approximately<\/span> 2,500 Boston residents replied to both surveys<\/span><\/a>, with their answers helping to inform the<\/span> City\u2019s 2022 Assessment of Fair Housing<\/span><\/a> study.<\/span><\/p>\n

Boston residents\u2019 activism helped the city pass the fair housing amendment to its zoning code<\/span> in<\/span><\/a> 2020<\/span><\/a>. <\/span>Residents\u2019 concerns around gentrification, displacement, ensuring equitable accommodations for people with disabilities and affordable housing informed the amendment.\u00a0 <\/span>The amendment<\/span> requires<\/span><\/a> developers to take meaningful actions to<\/span> address displacement, provide equitable access to housing<\/span><\/a> and consider their project\u2019s<\/span> impact on residents of areas that endured historical discrimination<\/span><\/a>. These efforts underscore the importance of community engagement throughout the AFFH process to help residents advocate for resources or policies they need to help them thrive in and remain in their communities.<\/span><\/p>\n

Boston\u2019s experience demonstrates how the AFFH community engagement process, if employed correctly, would give everyday Americans the mechanism to advocate for fair housing choice and obtain much-needed housing resources for their communities. The current AFFH rule deprives Americans of a significant mechanism to achieve equal access to housing and more sustainable community and economic development programs. HUD should reinstate the 2021 AFFH IFR and re-empower local communities to name and confront the fair housing challenges occurring in their own communities, and know they had a say in the path their leaders ultimately take.<\/span><\/p>\n

 <\/p>\n

Nichole Nelson is a Senior Policy Advisor with NCRC’s Policy & Government Affairs team.<\/em><\/p>\n

Photo credit: Qusai Akoud via Upsplash.<\/span><\/em><\/p>\n

\u00a0<\/span><\/p>\n

\u00a0<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

All Americans deserve to live in inclusive communities where everyone has access to the resources that their communities desperately need. But a federal program designed to make that happen is going underused by local officials who often aren\u2019t aware of its existence. If properly utilized, the program\u2019s provisions towards creating more equitable housing outcomes would 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But a federal program designed to make that happen is going underused by local officials who often aren\u2019t aware of its existence. 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