In 2017, MDHA released the Joint Assessment of Fair Housing (AFH) for the Metropolitan Government of Nashville and Davidson County (Metro) and the Metropolitan Development and Housing Agency (MDHA). The AFH was prepared in accordance with the Local Government Assessment Tool and regulations for Affirmatively Furthering Fair Housing (AFFH) in effect at that time and with extensive public input and data analysis. Following a public comment period and approval by the MDHA Board of Commissioners and the Metro Council, the AFH was submitted to HUD in September 2017. While still under review, HUD withdrew the requirements to use the Local Government Assessment Tool and required that program participants instead conduct an Analysis of Impediment to Fair Housing Choice (AI) using HUD’s Fair Housing Planning Guide to demonstrate commitment to AFFH.
Joint Assessment of Fair Housing 2017
Housing Options Free from Discrimination – Access to Opportunities
The Metropolitan Development and Housing Agency (MDHA) has prepared a joint Assessment of Fair Housing (AFH) on behalf of Metro Nashville and MDHA. The U.S. Department of Housing and Urban Development (HUD) requires cities and public housing authorities that receive federal funds for housing and community development to Affirmatively Further Fair Housing (AFFH). To fulfill this requirement as recipients of these funds, MDHA and Metro Nashville must conduct an AFH which includes an analysis of fair housing data, an assessment of fair housing issues and contributing factors, and an identification of fair housing priorities and goals. The purposes of the AFH is to assess whether individuals and families have the information, opportunity, and options to live where they choose without unlawful discrimination related to race, color, religion, sex, familial status, national origin, or disability and assess whether housing options are realistically available in integrated areas and areas with access to opportunity.
During the public comment period, the draft AFH was edited for final copy. Please note that Appendices E., F., and G. were added to the final document.
- I. Cover Sheet
- II. Executive Summary
- III. Community Participation Process
- IV. Assessment of Past Goals
- V. Fair Housing Analysis
- A. Demographic Summary
- B. General Issues
- C. Publicly Supported Housing Analysis
- D. Disability and Access Analysis
- E. Fair Housing Enforcement, Outreach Capacity, and Resources Analysis
- VI. Fair Housing Goals and Priorities
- VII. Appendices
- A. Summary of Comments from Kickoff Public Hearing
- B. Summary of Comments from Stakeholder Consultations
- C. Summary of Comments from Community Meetings
- D. Summary of Comments from Public Housing Residents
- E. Summary of Comments Received during Public Comment Period on the Draft AFH
- F. Copies of Public Notices
- G. Social Media Analytics
AFH Development Phase
The AFH was developed using the HUD-provided local government assessment tool. In addition, HUD provided data and maps to be used in the analysis. Local data and local knowledge were used to supplement the HUD-provided data. Early in the planning process, MDHA held a public hearing on March 14, 2017, to discuss the AFH planning process and timeline, review the AFH planning tools, and explain the citizen participation process.
Local Data
HUD defines local data as metrics, statistics, and other quantified information, subject to a determination of statistical validity by HUD, that are relevant to Metro’s/MDHA’s geographic area of analysis, can be found through a reasonable amount of searching, are readily available at little or no cost, and are necessary for the completion of the AFH using the local government assessment tool. For the purpose of completing the AFH, MDHA utilized local and state data that meet HUD’s criteria, which may have been prepared by public agencies, universities, etc.
Local Knowledge
HUD defines local knowledge as information that relates to the Metro’s/MDHA’s geographic area of analysis and that is relevant to the AFH, is known or becomes known to MDHA, and is necessary for the completion of the AFH using the local government assessment tool. Essentially, local knowledge is public input, and MDHA obtained community input during the development of the AFH through stakeholder consultations and community/resident engagement. In addition to the meetings outlined below, MDHA accepted input throughout the preparation of the AFH through meetings by appointment, written comments, etc.
Stakeholder Meetings
In preparing the AFH, MDHA staff consulted with public and private agencies that provide assisted housing, health services, and social services (including those focused on services to children, elderly persons, persons with disabilities, persons with HIV/AIDS and their families, homeless persons), community-based and regionally based organizations that represent protected class members, and organizations that enforce fair housing laws. MDHA accomplished this through a series of stakeholder meetings.
Community Meetings
In preparing the AFH, MDHA staff will held at least 5 community input sessions at different locations throughout the county and at times that are convenient for most citizens (such as Saturdays or evenings). Community meetings were publicized in accordance with the Public Notice procedure described in the Citizen Participation Plan.
Public Housing Resident Consultations:
In preparing the AFH, MDHA consulted with the MDHA Resident Advisory Board/Council of Presidents and held consultations at with resident associations of every MDHA public housing property.
Local knowledge/community input is critical to developing an AFH that reflects the needs and experiences of the citizens of Nashville. Everyone is encouraged to participate.
HUD-provided data and resources
AFH Draft Review and Comment Period
MDHA published the draft AFH for review and comment for 45 days. During the public comment period, MDHA held 6 public hearings. One of the public hearings was held before the MDHA Board of Commissioners, while 5 public hearings were held at different locations throughout the county and at times that were convenient for most citizens (such as a Saturday or evenings). A summary of the comments received during this period, including an explanation of why some comments/views were not accepted, are provided in Appendix E in the final AFH.
With the conclusion of the public comment period, the final AFH has been submitted to the MDHA Board of Commissioners and to the Metropolitan Council for approval. Upon receiving all local approvals, the final AFH was submitted to HUD by the due date of September 1, 2017.
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