HUD: Stop Attacking Trans People During the Public Health Crisis

Over 40 Organizations Sign on to NCTE's Letter to Housing & Urban Development Urging to Pause this Rulemaking Process

To: Department of Housing and Urban Development

Re: Suspending Rulemaking: Revised Requirements Under Community Planning and Development Housing Programs (FR-6152), RIN 2506-AC53
 
Dear Secretary Carson and Acting Director Vought,
 
In light of the current novel coronavirus (COVID-19) pandemic and the recently declared national emergency, the undersigned organizations that serve and advocate for individuals and families experiencing and at risk of homelessness urge you to suspend the rulemaking process for the proposed regulations implementing the Revised Requirements Under Community Planning and Development Housing Programs (FR-6152) , RIN 2506-AC53 (“proposed rule”). We urge that the Department of Housing and Urban Development (HUD) and the Office of Management and Budget (OMB) suspend this rulemaking process until at least 30 days after the national emergency declared on March 13, 2020 has ended, in order to allow shelters, other critical direct service providers, and other stakeholders to return to their normal operations.
 
Since the rapid spread of the COVID-19, people with housing insecurities have been in dire need of emergency assistance, especially shelter and housing programs. At this time, the United States is the worldwide epicenter of the pandemic, which as of this writing has killed over 6,600 Americans and continues to spread in every state. With physical distancing recommendations in place nationwide and mandatory for most Americans, hospitals in many areas reaching capacity, and local communities racing to move individuals and families from crowded shelters to hotels, motels, RVs, or other safe housing, now is not the time to consider any non-emergency rule changes, let alone changes that will create new barriers for vulnerable individuals.  
 
At this time, service providers and other key stakeholders are doing all they can to prevent spread of the virus while providing safe shelter and meeting basic needs. School, child care, and workplace closures; urgent needs for public education, outreach, and direct services; and individuals becoming ill or taking care of loved ones who are ill are all diverting and resources away from both individual and organizational stakeholders’ ability to review and comment on any proposed rule. Under these circumstances, meaningful public notice and comment is practically impossible, especially for rules focused on sectors such as emergency shelter and homeless services that are on the front lines of response to the pandemic.
 
Furthermore, since there is a lack of institutional resources for key stakeholders, including direct service programs and individual members of the public, to review and implement new rule changes, it is essential to suspend all non-emergency rulemaking, including this proposal.  
 
Non-emergency rulemaking at this time will create additional complicated, and unnecessary challenges to an already overwhelmed system. Consistent with the direction of Acting OMB Director Vought in his March 17 memo heads of departments and agencies, HUD should “prioritize all resources to slow the transmission of COVID-19.”
 
Moreover, the effects of this rule change could compound the dangers of the pandemic by causing confusion, fear, and delays and barriers to accessing shelter for vulnerable individuals and families. Now is hardly the time to push forward with this fundamentally flawed rule, particularly when providers of emergency shelter and homeless services urgently require HUD’s assistance to prevent spread of the virus and meet basic human needs.
 
In conclusion, we urge HUD and OMB to suspend the rulemaking process until at least 30 days after the national emergency for COVID-19 has come to an end and critical services for those experiencing homelessness are able to return to normal operations. For questions please contact Harper Jean Tobin ([email protected]) and Debbie Ojeda-Leitner ([email protected]) at the National Center for Transgender Equality.  
 
Sincerely,  
 

• American Atheists
• American Humanist Association
• Americans United for Separation of Church and State
• Athlete Ally
• California LGBTQ Health and Human Services Network
• Center for American Progress
• Center for Disability Rights
• CenterLink: The Community of LGBT Centers
• Chicago House and Social Service Agency
• Consortium for Individuals with Disabilities Housing Task Force
• Fairness West Virginia
• Family Equality
• Funders Together to End Homelessness
• GLMA: Health Professionals Advancing LGBTQ Equality
• GLSEN
• Homeless Services Network
• Housing Choice Partners Housing Equality & Advocacy Resource Team
• Human Rights Campaign
• Legal Aid Chicago Legal Voice
• Louisiana Fair Housing Action Center
• Louisiana Trans Advocates
• Mazzoni Center
• Movement Advancement Project
• NAACP
• National Alliance for Safe Housing National CAPACD
• National Center for Lesbian Rights
• National Center for Transgender Equality
• National Law Center on Homelessness & Poverty
• National LGBTQ Task Force
• National Low Income Housing Coalition
• National Organization for Women
• National Resource Center on Domestic Violence
• National Women's Law Center
• One Colorado
• PFLAG National
• Prosperity Now
• Public Justice Center
• Secular Coalition for America
• Secular Policy Institute
• Southern Legal Counsel
• The Arc of the United States
• The Jewish Federations of North America
• Transgender Legal Defense and Education Fund
• True Colors United