Request to Formally Manage the AFFH 2016 Budget for the Assessment of Fair Housing (AFH) Submission
The following is a script presented to the Douglas County, CO, Board of Commissioners requesting formal management of the AFFH budget by Board of Commissioners
February 16, 2016
Request to Formally Manage Budget for 2016 AFFH Assessment of Fair Housing (AFH)
Douglas County Board of Commissioners
Evelyn Zur, Presenter
Thank You, to you on the Board for the work you’ve already begun addressing the problem and seeking clarification of HUD’s AFFH rule and tool, a plan with an agenda we believe is designed to transform our suburban communities into “Cities without Suburbs”.
Today, Smith Young and I are here to make 3 requests. We are asking the board:
- A motion to issue a stop work order on any work and use of resources that may have begun on the 2016 AFH submission until such time that the board can assess the budget impact of the new AFH submission.
- A motion to formally require Board approval of a budget for the 2016 AFH submission to HUD due 10/5/2016
- A motion to establish an AFFH legal defense fund (to be presented by Smith Young)
HUD’s NEW AFFH Rule goes into pitfalls of uncharted waters with regard to accruing unexpected administrative costs.
You our Douglas County Commissioners are responsible for the budget and we are asking you to be proactive on this supersized undertaking with regard to planning for a manageable budget. HUD”s “OLD-OUTDATED” estimate of 240 hours at $47.00 per hour required to complete the application based on the old Analysis of Impediments (AI), e.g., for CDBG grants is simply ridiculous for the new AFH submission. The job is massive based on applying the “NEWER” Tool guidelines consisting of hundreds and hundreds of pages of instructions published by HUD 12-31-2015. Together, Smith Young and I have reviewed the HUD supplied tools together with endless instructions in guidelines and it should be clear to anyone that the scope of work can easily, if not definitely, creep out of control.
In summary, HUD’s AFFH rule and tool is as gut wrenching plan to transform our communities as Obamacare is intended to transforming Health Care. Other HUD targeted communities that accept these HUD grants are also opening a Pandora’s box of unanticipated expenses by stepping into an unbudgeted process, like quicksand, not assessing the cost associated with the benefits they are signing up (literally) to receive. We have the benefit of their mistakes to be proactive with our own planning. We are asking the Board to take immediate action.
Evelyn Zur, Parker, CO