This Toolkit does not reflect any decisions made in connection with HUD's February 9, 2023 notice of proposed rulemaking and only relates to voluntary fair housing planning conducted pursuant to HUD's June 10, 2021 Interim Final Rule and may be used to support a program participant's certification that they will affirmatively further fair housing.
Module 7
How to Set Fair Housing Goals and Ensure Meaningful Actions to AFFH
Fair Housing Planning ToolkitModule 7 Objectives:
- Learn HOW to Set Fair Housing Goals
- Learn HOW to Ensure Meaningful Actions to AFFH
Module 7 Content:
On This Page:
Key Players
- Fair Housing Plan Coordinator
- Relevant departments in the Program Participant’s organization, such as:
- planning commissions
- economic development agencies
- offices that implement HUD programs such as CDBG, HOME, ESG, etc.
- Direct Community Members with experience with relevant programs, policies, practices, and procedures
Key Definitions
A fair housing goal is a goal identified through the analysis in the Fair Housing Plan, to overcome fair housing issues. Program Participants are responsible for taking meaningful actions to achieve each of the fair housing goals identified in their Fair Housing Plan. Meaningful actions are significant actions that are designed and can be reasonably expected to achieve a material positive change that affirmatively furthers fair housing by, for example, increasing fair housing choice or decreasing disparities in access to opportunity.
Significant actions that are designed and can be reasonably expected to achieve a material positive change that affirmatively furthers fair housing by, for example, increasing fair housing choice or decreasing disparities in access to opportunity.
Measures of progress that are clear and not interpretable in different ways.
Milestones need to be meaningful in the sense that they represent improvements that are commensurate with the significance and severity of the fair housing issues that the goals are designed to overcome.
Suggests that goals be: Specific, Measurable, Action-Oriented, Realistic, Time-Bound, Evaluated, and Revised.
- Specific: Provide enough detail to establish what the Program Participant wants to accomplish. Specific goals are more easily measured than vague goals. Provide the necessary specificity either in the statement of the goal itself or in the metrics and milestones that Program Participants identify to measure achievement of the goal.
- Measurable: Develop one or more specific metric(s) and milestone(s) that can be used to measure success in achieving the goal. Metrics and milestones should be identified for each fair housing goal set.
- Action-oriented: Goals should describe measures to be taken, rather than simply express an aspiration for change. The goal may call for very specific actions or describe a broader objective that will subsequently be translated into specific action steps.
- Realistic: Understand and explain the limitations of the situation, including those set by available resources, capacity, and political will.
- Time-Bound: Establish a deadline and a specific timeframe for the achievement of each of the fair housing goals set.
- Evaluated: Ensure goals are evaluated. This is where we move beyond goal characteristics and into goal interaction. Evaluation is about reviewing and reflecting. What’s working, what’s not. What’s gone well, what hasn’t. What’s gotten in the way, and what’s been helpful along the way.
- Revised/Readjusted: Revision responds to evaluation, so these two stages go hand-in-hand. As Program Participants evaluate, determine whether goals should be revised. What should we change about upcoming goals and what should we keep the same? How can we ensure better results than last time? Are there different metrics we can track that better represent performance? Do other or additional people need to be included on these goals? If, for example, in pursuing a goal Program Participants continuously hit a brick wall, readjust the method and techniques.
Timeframes
We estimate that this Fair Housing Planning task should take approximately 15 business days.
The length of time Fair Housing Planning takes may vary based on the size of the Program Participant, the different types and amounts of resources available to them, or the number of barriers to fair housing choice that must be analyzed. The timeline provides information on how long an estimated planning task might take. The work that goes into Fair Housing Planning is scalable across Program Participants of various sizes, so while it can seem like a complex task, creating a Fair Housing Plan is a manageable task for Program Participants of all sizes and capacities.
- Goalsetting happens during the Fair Housing Planning process in response to fair housing data analysis.
- Taking meaningful actions based on the goalsetting in the Fair Housing Plan happens after the Fair Housing Plan is complete and during the Program Participant’s Consolidated Planning or PHA Planning cycle.
- Evaluation of goals happens throughout the Program Participant's Consolidated Planning or PHA Planning cycle and should happen prior to a Program Participant updating their Fair Housing Plan.
- The Fair Housing Plan, and related fair housing goals, should be updated every 3-5 years consistent with the Program Participant's Consolidated Planning or PHA Planning cycle.
Module 7.1: Introduction to How to Set Fair Housing Goals that Ensure Meaningful Actions
What goals will help a Program Participant comply with the duty to affirmatively further fair housing depends on local context and may require an array of strategies to address local, regional, and state-wide barriers to fair housing choice, patterns of segregation, and disparities in access to opportunity, as well as to ensure participation by a diverse group of community stakeholders. The key to successful implementation of these fair housing strategies is thoughtfully setting goals that will lead to meaningful actions. In order to successfully affirmatively further fair housing, actions need to be meaningful and achieve a material positive change.
Fair housing goals are designed to address and overcome fair housing barriers or issues in a community. The fair housing goals set in the Fair Housing Plan should be incorporated into subsequent planning processes, including those to create Consolidated Plans and PHA Plans, by including the strategies, actions, and any necessary funding to achieve those goals in other relevant planning documents. Fair housing goals should be measurable, tracked, and ultimately, should affirmatively further fair housing.
Because fair housing is a broad topic touching on many issues and protected characteristics, Program Participants will likely have several fair housing issues and a plethora of possible goals to pursue to achieve fair housing outcomes. As such, Program Participants may need to prioritize their goals. In deciding which goals to tackle first, Program Participants should give the most priority to goals that address fair housing issues that limit and/or deny fair housing choice or access to opportunity, perpetuates segregation, or impacts fair housing or civil rights compliance.
Goalsetting has been a key focus throughout this toolkit and is a common thread that bonds all elements of Fair Housing Planning. Program Participants have learned that a thorough, data-driven fair housing analysis in conjunction with robust Community Participation can inform goalsetting. This module will dive deeper and present information about how to set thoughtful goals that will lead to meaningful actions to increase housing choice and access to opportunity, and build more inclusive communities free from discrimination.
You’ll learn:
- How to be thoughtful about goalsetting in Fair Housing Planning, taking into consideration past actions as well as the current fair housing landscape
- What types of factors to consider when goalsetting in Fair Housing Planning and tailoring fair housing goals to community’s needs
- How to prioritize fair housing goals
- How to make fair housing goals SMART-er in order to set those goals into action
- How to identify common issues with goalsetting in Fair Housing Planning and best practices for more thoughtful goalsetting
- How and when to incorporate fair housing goals into other community fair housing-oriented planning processes
Module 7.2: Factsheet with Tips on Goalsetting and Common Issues
What is Goalsetting for Fair Housing Planning?
The process of setting fair housing goals is essential to Fair Housing Planning, as goals should lead to meaningful actions to affirmative further fair housing. Fair housing goals can lead to more inclusive communities, free from discrimination, and also allow Program Participants to meet their AFFH obligation. Fair housing goals should strive to overcome identified fair housing issues, such as patterns of segregation or disparities in access to opportunity. Goalsetting should also encourage a balanced approach to community planning and development, which means ensuring housing choice by pursuing not only place-based goals, but also people-based goals, and policy-driven goals. Goals identified in Fair Housing Planning should be incorporated into subsequent community planning processes, including the strategies, actions, and funding priorities established in the Consolidated Plan and PHA Plan.
Considering Past Goals and Actions, and Current Fair Housing Issues
In order to set current fair housing goals and priorities, Program Participants should consider past goals and actions in previous Fair Housing Plans, Consolidated Plans, or PHA Plans, in addition to the current fair housing analysis.
Program Participants should ask:
- Have past fair housing goals been achieved?
- Have these goals led to meaningful actions and positive fair housing outcomes? How has this success been measured? How can future fair housing goals build upon this success?
- For any unmet goals, how much progress has been made toward achieving past goals? Should any unmet goals be incorporated into the current Fair Housing Plan? Have past goals utilized a balanced approach to Fair Housing Planning?
- Have there been any changes to the Program Participant’s capacity to achieve past fair housing goals (e.g., resources, staffing, etc.) that would inform future goalsetting?
- Has a thorough analysis of the current fair housing landscape been conducted?
- Has this analysis identified fair housing issues for individuals with protected characteristics such as patterns of segregation, barriers in access to opportunity, or others?
- If the fair housing analysis is lacking, what resources, local knowledge, data, or expertise are needed to help improve the fair housing analysis?
- Do current goals address the identified fair housing issues?
- Have we thoughtfully considered the identified fair housing issues and used this analysis to set meaningful goals to overcome these fair housing issues?
- Are these current goals achievable? Will these goals lead to meaningful action and positive fair housing outcomes? How will we measure success? When do we expect these goals to be achieved?
Best Practices for Improved Goalsetting
Ideally, fair housing goals should lead to meaningful action. Therefore, goals should always include metrics, milestones, and timeframes for completion. It may be helpful to use the SMART-er framework when goalsetting:
- Specific: Detailed and crafted to explicitly address the stated goal.
- Measurable: Contains metrics and milestones to be used for measuring the success in achieving the identified goal.
- Action-Oriented: Describes measures to be undertaken, rather than simply express an aspiration for change.
- Realistic: Acknowledges the limitations and feasibility of the identified goal.
- Time-Bound: Includes a set deadline and specific timeframe for the achievement of the desired goal.
- Evaluated: Evaluation is about reviewing and reflecting and moving beyond goal characteristics and into goal action.
- Revised/Readjusted: As Program Participants evaluate in general, Program Participants need to evaluate whether goals should be revised.
In order to foster meaningful action, goals should consist of achievable activities that are designed to address real fair housing issues. Make sure to identify resources from local, state, Federal, non-profit, or other entities that are in a position to support fair housing goals and related activities. Identify individuals, groups, and organizations to be involved in each action and define their responsibilities. In addition, it may be necessary to prioritize goals to ensure that they are achievable and to maximize positive fair housing outcomes.
Common Issues with Goalsetting
It can be difficult to understand how to set effective goals in a Fair Housing Plan. The following list presents common issues that can render goals ineffective for Fair Housing Planning (please note that this list is not exhaustive):
- Goals that have no connection with and do not address the fair housing analysis and identified fair housing issues
- Goals that do not build upon past goals and actions or simply repeat past goals and actions
- Goals that list ongoing community activities rather than proactively addressing fair housing issues
- Goals that are not time-bound or where the measures of or milestones for success are not clear
- Goals that do not consider individuals with protected characteristics or only consider one protected characteristic at the expense of others
- Goals that do not consider feedback from the community and key stakeholders
- Goals that do not specify or consider what resources, staffing, or other considerations may be necessary to meet those goals
- Only setting goals that aim to end discriminatory practices and not addressing how to increase housing choice or access to opportunity
- Setting too many goals, without prioritization or any consideration of what can realistically be achieved in the Program Participant’s planning cycle
Additional Tips for Effective Goalsetting
- Prioritize goals and take into consideration the specific needs and concerns of the community, groups representing those with protected characteristics, and relevant policymakers
- Consider goals that take a balanced approach, which means ensuring housing choice by pursuing not only place-based goals, but also people-based goals and policy-driven goals. Consider goals that increase access to opportunity, such as transportation, education, healthcare, access to food, and the environment
- Use a data-driven analysis to assess fair housing issues, priorities, current policies, and current investments to inform fair housing goalsetting
- Solicit input from the community and key stakeholders through the Community Participation process; ensure that this input is considered when goalsetting
Module 7.3: Identifying SMART-er & Complementary Goals to Address Specific Fair Housing Issues
The Program Participant may find useful the following Goal Chart, which can be filled out to ensure goals are SMART-er and organized:
Goal (describe the goal that will lead to meaningful actions to address fair housing issues)
Fair Housing Issue(s) related to Goal
(what issues were found during the data analysis; during analysis of a jurisdiction’s programs, policies, and procedures; or during Community Participation)
Metrics
(how successful outcomes will be measured)
Milestones
(how will the jurisdiction track incremental progress of the goal)
Timeframe for completion
(when will the goal be achieved)
Lead Agency/Office
(who is the point of contact for the goal)
Program Participants may develop a variety of fair housing goals based on their fair housing data analysis and local context and should keep in mind a balanced approach to Fair Housing Planning.
- For example, a Program Participant may develop affordable housing that promotes integration in well-resourced areas of opportunity or preserve affordable housing in other areas as part of a place-based strategy to revitalize a racially or ethnically concentrated area of poverty.
- Program Participants may also remove barriers to the development of affordable housing in areas with low poverty and proficient schools by, for example, seeking the amendment of local zoning and land use laws or allocating funding for affordable housing through the HOME Program and/or through Low-Income Housing Tax Credits (LIHTC).
- Alternatively, Program Participants may overcome disparities in access to opportunity by revitalizing areas with existing affordable housing to improve services, schools, and other community assets, sidewalks, and other infrastructure.
Here are some examples of how the Goal Chart may be used, which shows metrics in WHAT should be achieved, milestones for the actions or steps along the way, and WHEN are the timeframes for completion.
Goal (describe the goal that will lead to meaningful actions to address fair housing issues)
Build 3 new affordable housing buildings in well-resourced areas of opportunity where there is a lack of affordable housing.
Fair Housing Issue(s) related to Goal
(what issues were found during the data analysis; during analysis of a jurisdiction’s programs, policies, and procedures; or during Community Participation)
Disparities in Access to Opportunity
Zoning and Land Use Ordinances
Metrics and Milestones
(how progress towards the goal will be tracked and how successful outcomes will be measured)
- Use data to identify well-resourced areas of opportunity and areas lacking affordable housing in the jurisdiction and region over the past 5 years to ensure affordable housing is provided in well-resourced areas of opportunity and throughout the region.
- Select 3 new sites for affordable housing development.
- Finalize funding for the development.
- Finalize development of 3 new affordable housing developments.
Timeframe for completion
(when will the goal be achieved)
- Year 1
- Year 2
- Year 2
- Year 5
Lead Agency/Office
(who is the point of contact for the goal)
City, including the Economic Development Office and the City’s Land Bank
Goal (describe the goal that will lead to meaningful actions to address fair housing issues?)
Addressing increase in LGBTQIA discrimination through increased education and testing.
Fair Housing Issue(s) related to Goal
(what issues were found during the data analysis; during analysis of a jurisdiction’s programs, policies, and procedures; or during Community Participation)
Fair Housing Enforcement Infrastructure
Discrimination
Metrics and Milestones
(how progress towards the goal will be tracked and how successful outcomes will be measured)
- Create education materials and presentations on fair housing rights for all members of community, and have an emphasis on discrimination based on sex, including training both housing providers and housing consumers.
- Promote greater outreach and partnerships with FHIPs and non-profits, housing providers, and community leaders, especially those who work specifically with the LGBTQIA populations to develop trainings and knowledge to educate the community about fair housing laws (including rights and responsibilities). This will be measured by completing 3 fair housing trainings with an outreach partner over the timeframe of one year.
- Increase the number of sexual orientation and gender identity tests the FHAP is undertaking annually from 0 to 20.
- Reduce number of filed fair housing complaints by 25 percent over the next 5 years related to sexual orientation and gender identity (based upon the increased education and outreach effort).
Timeframe for completion
(when will the goal be achieved)
- Year 1
- Year 1-5
- Year 1-5
- Year 1-5
Lead Agency/Office
(who is the point of contact for the goal)
FHAP
FHIP
Goal (describe the goal that will lead to meaningful actions to address fair housing issues?)
Provide greater language access to individuals who are LEP by translating vital documents and conducting targeted outreach.
Fair Housing Issue(s) related to Goal
(what issues were found during the data analysis; during analysis of a jurisdiction’s programs, policies, and procedures; or during Community Participation)
Patterns of segregation based on LEP disparities in access to opportunity for LEP persons based on national origin
Metrics and Milestones
(how progress towards the goal will be tracked and how successful outcomes will be measured)
- Examine whether the PHA is taking reasonable meaningful actions to ensure access for LEP individuals by completing a four-factor analysis.
- Completing a Language Assistance Plan (LAP).
- In conjunction with development of LAP overall, the PHA will complete translation of vital documents into languages other than English.
- Increase the number of connections to organizations working with LEP populations by conducting outreach.
Milestones
(how the jurisdiction will track progress towards the goal)
- Completion of the four-factor analysis
- Completion of the LAP
- Translation of all vital documents into languages as determined by the LAP.
- Number of connections to organizations working with LEP populations.
Timeframe for completion
(when will the goal be achieved)
- Year 1
- Year 1
- Year 1-5
- Year 1-5
Lead Agency/Office
(who is the point of contact for the goal)
PHA
Program Participants are responsible for taking meaningful actions directly related to each of the fair housing goals. For example, a goal to reduce segregation requires meaningful actions that are designed and can be reasonably expected to achieve a material positive change in reducing segregation. For instance, where segregation in a development or geographic area is determined to be a fair housing issue, the Fair Housing Plan might include one or more goals to reduce the segregation. The Program Participant should think strategically about realistic goals that will achieve strong fair housing outcomes. Because the fair housing goals established will shape future obligations, it is important to ensure the goals are designed to affirmatively further fair housing.
Checklist
- Have you established goals to remedy the fair housing issues identified?
- Do your goals follow a framework, such as SMART-er, to ensure goals are specific, measurable and able to be monitored, evaluated and revised as necessary to achieve meaningful actions to affirmatively further fair housing?
- Has a lead person/agency been assigned for each goal to ensure timely completion?
Resources
- HUD AFFH Rule Guidebook - 2015
- Fair Housing Planning Guide
- Welcome! | furthering fair housing (mit.edu)
- Assessments of Fair Housing by State | furthering fair housing (mit.edu)
Program Participants may leverage and align HUD funding with other Federal, state, or local resources to affirmatively further fair housing. Here are some Federal grant opportunities that could be used to implement fair housing goals:
Federal Source
Grant Opportunity
HUD
CPD
- Community Development Block Grants (CDBG)
- CDBG Disaster Recovery
- HOME Investments Partnership Program
- Emergency Shelter Grants (ESG)
- Continuum of Care (CoC) Grants and Recovery Housing Program (RHP)
- Housing for Persons with Aids (HOPWA)
- Neighborhood Stabilization Program (NSP)
- Section 108
PIH and Multi-family Housing
- Public Housing
- Rental Assistance Demonstration (RAD)
- Housing Choice Voucher
- Project Based Vouchers
- Section 202 Supportive Housing for the Elderly
- Section 811 Supportive Housing for Persons with Disabilities
FHEO
- Fair Housing Assistance Program (FHAP)
- Fair Housing Initiatives Program (FHIP)
OHC
- Housing Counseling
HHS
Administration for Community Living Discretionary Grants
EPA
- Air Grants and Funding: includes competitive grant funding announcements for projects and programs relating to air quality, transportation, climate change, indoor air and other related topics.
- Brownfields Grants and Funding: existing facilities where redevelopment is complicated by real or perceived contamination.
- Environmental Education Grants: projects to help the public make informed decisions that affect environmental quality.
- Environmental Information Exchange Network Grant Program: provides funding to develop an Internet-based, secure network that supports the electronic collection, exchange, and integration of high-quality data.
- Environmental Justice: provides financial assistance to support community-based organizations to collaborate and partner with other stakeholders (e.g., industry, government, academia, etc.) to develop and implement solutions that will significantly address environmental and/or public health issue(s) at the local level.
- Pollution Prevention Grant Program: provides matching funds to state and tribal programs to support pollution prevention and to develop state-based programs.
- Office of Land and Emergency Management (OLEM) Grants and Funding: includes competitive grant funding announcements for projects and programs relating to Brownfields, Federal Facilities Restoration and Reuse, Solid Waste management, resource conservation and recovery, Underground Storage Tanks and other related topics.
USDA
- Housing Assistance. USDA provides homeownership opportunities to low- and moderate-income rural Americans through several loan, grant, and loan guarantee programs. The programs also make funding available to individuals to finance vital improvements necessary to make their homes decent, safe, and sanitary. USDA Multi-Family Housing Programs offer Rural Rental Housing Loans to provide affordable multi-family rental housing for very low-, low-, and moderate-income families; the elderly; and persons with disabilities. In addition, rental assistance is available to eligible families.
- Rural Development Loan and Grant Assistance. USDA Rural Development forges partnerships with rural communities, funding projects that bring housing, community facilities, business guarantees, utilities and other services to rural America. USDA provides technical assistance and financial backing for rural businesses and cooperatives to create quality jobs in rural areas. Rural Development works with low-income individuals, state, local and Indian tribal governments, as well as private and non-profit organizations and user-owned cooperatives.
USDOT
- The Rebuilding American Infrastructure with Sustainability and Equity (RAISE) Discretionary Grant program.
- Strengthening Mobility and Revolutionizing Transpiration (SMART) Grants Program.
- Reconnecting Communities Pilot program
- Rural Opportunities to Use Transportation for Economic Success (ROUTES)
ED
- Personnel Development to Improve Services and Results for Children with Disabilities Discretionary Grant
- Office of Elementary and Secondary Education (OESE): Safe & Supportive Schools: Fostering Diverse Schools Demonstration Grants
- Office of Elementary and Secondary Education (OESE): School Choice & Improvement Programs: Magnet Schools Assistance Program
Closeout
- Have you identified Key Players?
- Have you reviewed Key Definitions?
- Have you familiarized yourself with the Timeframes?
- Have you completed Module 7.1: Introduction to How to Set Fair Housing Goals that Ensure Meaningful Actions?
- Have you completed Module 7.2: Factsheet with Tips on Goalsetting and Common Issues?
- Have you completed Module 7.3: Identifying SMART-er & Complementary Goals to Address Specific Fair Housing Issues?