This US Department of Housing and Urban Development Letter proves HUD is intentionally attempting to decisive Rhode Island Citizens
Read this letter from HUD to the Foster RI Town Planner who made inquiries about the new AFFH "clarification" and then read this analysis and proof the agency is telling half-truths about what will happen if the Property Rights Alliance of Rhode Island fails and HUD achieves its goals:
The major flaws of the attached HUD letter to Foster are as follows:
1) The letter leaves out the most critical piece being that there is not only a requirement to have an "Analysis of Impediments (AI)" document completed, but there is also a required second document being the local plan created on how to overcome the identified impediments contained in the AI. Failure to have a comprehensive working plan to address the impediments was the primary basis for the Westchester lawsuit. This second requirement is spelled out in HUD's Fair Housing Planning Guide (see e.g. page 1-2), and Federal Reg 24 CFR 570.487(b)). See, respectively:
The letter leaves out this critical requirement of any "grantee" who accepts CDBG funds.
2) The letter makes a big deal about HUD not forcing changes on a community. HUD is not the problem. The central issue is whether an advocacy group, or a developer, can bring a lawsuit in federal court based on AFFH compliance (i.e. those who take CDBG). Westchester County originally tried to claim in court that advocacy groups did not have standing to bring a claim into federal court. But Judge Denise Cote held that they did have standing (see attached OPINION and ORDER).
The letter fails to make this point, instead making it appear that there are zero risks to a local community when taking CDBG (try telling that to Westchester residents who are getting their local zoning deconstructed because of HUD).