The Potential Costs to Public Engagement of HUD’s Assessment of Fair Housing Delay
In January 2018, the U.S. Department of Housing and Urban Development (HUD) announced that it would extend the deadlines by which local governments and public housing authorities receiving federal housing and urban development funds must submit Assessments of Fair Housing (AFHs), and allow jurisdictions to continue to file Analysis of Impediments (AIs) instead. HUD justified the delay by noting that of the first 49 AFH initial submissions, HUD initially did not accept 35% of the submissions. Many observers, however, believed that the initial submissions were superior to the AIs they replaced. To evaluate one important aspect of the AFH and AI processes, the NYU Furman Center compared the public engagement involved in the AIs and AFHs filed by 19 of the 28 jurisdictions who were first to file under the new AFH requirements. The authors find that the public engagement processes used under the AFH requirement were much more robust than the most recent AIs the jurisdictions had filed along five distinct dimensions: the number of opportunities for public engagement; the inclusiveness of those opportunities; the provision of data for assessing public engagement; documentation and consideration of the public input; and existence of cross-jurisdictional or cross-sector engagement.