AFFH FAQ
Q

What is a balanced approach to fair housing?

Date Published: September 2016

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What is needed for a balanced approach is specific to local context, including the actions a program participant has taken in the past. A balanced approach may include, but is not limited to, both place-based and mobility strategies. Both place-based and mobility strategies must be designed to achieve fair housing outcomes such as reducing segregation and increasing integration throughout the jurisdiction, reducing disproportionate housing needs, transforming Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) by addressing the combined effects of segregation coupled with poverty, and decreasing disparities in access to opportunity, such as to high performing schools, transportation, and jobs.

Place-based strategies may include but are not limited to:

  • Making investments in segregated, high poverty neighborhoods that improve conditions and eliminate disparities in access to opportunity between residents of those neighborhoods and the rest of the jurisdiction and region.
  • Maintaining and preserving existing affordable rental housing stock, including HUD assisted housing, to reduce disproportionate housing needs.

Mobility strategies may include but are not limited to:

  • Developing affordable housing in areas of opportunity to combat segregation and promote integration.
  • Providing greater access to existing affordable housing in areas of opportunity, for instance through mobility counseling for Section 8 Housing Choice Voucher recipients.
  • Creating housing mobility programs that effectively connect low income residents of segregated areas to affordable housing in integrated areas, providing greater access to opportunity.

It is important to note that place-based and mobility strategies are not mutually exclusive. For instance, a program participant could conclude that to combat segregation and overcome disparities in access to opportunity, additional affordable housing is needed in higher opportunity areas where few racial or ethnic minorities live. In that case, new construction of affordable housing could be undertaken, and the use of vouchers could be incentivized for those high opportunity areas. At the same time, while such efforts are being implemented, preserving the existing affordable rental stock that serves racial and ethnic minorities and persons with disabilities, while decreasing disparities in access to opportunity for residents of that housing by revitalizing the areas where it is located can also be a priority based on the fair housing issues identified in the Assessment of Fair Housing (AFH).

To achieve a balanced approach, the strategies and actions a program participant plans to take should be viewed in connection with those actions a program participant has previously taken. For example, strategies that rely solely on investment in areas with high racial or ethnic concentrations of low-income residents, to the exclusion of providing access to affordable housing outside of those areas, may be problematic from the Affirmatively Furthering Fair Housing (AFFH) perspective. Similarly, in areas with a history of segregation, if a program participant has the ability to create opportunities outside of the segregated, low-income areas but declines to do so in favor of place-based strategies, there could be a legitimate claim that the program participant was acting to preclude a choice of neighborhoods to historically segregated groups and failing to affirmatively further fair housing. Similarly, a mobility strategy would likely not affirmatively further fair housing if voucher holders were encouraged to consider moving to other neighborhoods, but a jurisdiction or region did not have affordable housing in low poverty areas with access to opportunity, such as proficient schools, reliable transportation, and employment opportunities.

For discussion on a balanced approach to affirmatively furthering fair housing in the federal register publication of the AFFH Rule (see 80 FR 422279). Additionally, refer to Sections 2 and 2.1 of the AFFH Rule Guidebook.


Tags: AFFH Implementing the AFFH Rule

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FAQ ID:

3016