The City of Miami Beach is a U.S. Department of Housing and Urban Development (HUD)-designated entitlement community, as determined by the decennial census information on population growth, age of housing stock, and poverty. The City has been a CDBG entitlement community since 1975. The HOME Program was started in 1992 to provide funding specifically for affordable housing. HUD allocates these funds to strengthen public/private partnerships and expand the supply of affordable housing that is decent, safe and sanitary.

As an entitlement community, the City qualifies for annual allocations under HUD’s grant programs. HUD requires each entitlement community to submit an annual One-Year Action Plan describing how it will utilize funding and resources to address priority needs identified in the City’s Five-Year Consolidated Plan. The City’s current One-Year Action Plan follows the strategies included in its 2013-2017 Five-Year Consolidated Plan. CDBG funds have been primarily used to provide vital public services, housing activities, and improvements to public facilities while HOME funds have been primarily used for affordable rental housing activities.

Affirmatively Furthering Fair Housing (AFFH) has been a law since 1968; however, meaningful regulations providing program participants with guidance on how to comply have not existed. CDBG recipients and HOME recipients have had to pledge that they will affirmatively further fair housing. That meant completing an Analysis of Impediments (AI) to fair housing choice, taking some actions to overcome the effects of those impediments, and keeping records of those actions. It was widely recognized that HUD’s existing method of implementing AFFH was not effective. Therefore, HUD published a Final Rule regarding AFFH which includes the replacement of the AI with a required Assessment of Fair Housing (AFH), and provided a new definition of AFFH…”Affirmatively Furthering Fair Housing means taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.”

The fair housing goals and priorities that are set in the AFH must be incorporated into the Consolidated Plan (or the PHA Plan that is required from the Housing Authority). Both the City and the Housing Authority must complete and submit an AFH, and HUD encourages jurisdictions to collaborate to submit a joint AFH or regional AFH. Public participation is required and the AFH must include a summary to document the public participation process and the efforts to broaden participation in the development of the AFH.

Since the Housing Authority will need to engage the same agencies, organizations, citizens, business persons, and housing professionals to assess the same geographic jurisdiction as the City, an agreement to collaborate jointly to create the AFH will benefit both parties by combining resources and avoiding duplication of efforts.