Texas Department of Housing & Community Affairs - Building Homes and Strengthening Communities

State of Texas Analysis of Impediments (AI) to Fair Housing Choice


The Analysis of Impediments (AI) to Fair Housing Choice is a process that recipients of grant funds from the U.S. Department of Housing and Urban Development (HUD), such as states, local governments, and public housing agencies, undertake as part of their obligation to affirmatively further fair housing (AFFH) under the Fair Housing Act.

At the state level, the Texas General Land Office (GLO), Texas Department of State Health Services (DSHS), Texas Department of Agriculture (TDA), and Texas Department of Housing and Community Affairs (TDHCA) are responsible for carrying out the work of the AI because these agencies receive and disburse HUD funds for the Community Development Block Grant (CDBG), CDBG Disaster Recovery, Housing Opportunities for Persons With AIDS (HOPWA), HOME, National Housing Trust Fund (NHTF), and Emergency Solutions Grants (ESG) programs.

AI Process

Prior to beginning the five-year Consolidated Plan for 2020-2024, all state agencies that receive Community Planning and Developments funds are required by HUD to undertake fair housing planning.

  • The AI is part of the fair housing planning process and will help the state analyze challenges to fair housing choice.
  • The state has sought input and feedback regarding fair housing issues particularly issues affecting protected classes under the Fair Housing Act: race, color, religion, national origin, sex, disability, and familial status; and the ability of those persons to exercise housing choice.
  • A significant degree of public consultation and engagement is required by HUD prior to an initial draft of the AI being presented to the Board, and made available for public comment.
  • In the development of the AI, the State will follow the Citizen/Community Participation Plan (Minor amendment to the 2017 One Year Action Plan, updating the Citizen Participation Plan) as required by 24 CFR §91.115.
  • A schedule of AI Outreach activities and public hearings is included as Fair Housing Listings in TDHCA’s online Calendar.
  • At the Board meeting of TDHCA scheduled for March 21, 2019, the Board will consider approval of a draft AI to then be released for public comment from March 25 through May 6, 2019. A copy of the draft AI is available at https://www.tdhca.state.tx.us/board/meetings.htm.

Data used in the AI:

Public Comment Details

Following Board action staff expects to release the draft AI for public comment. A formal public comment period will be open from Monday, March 25, 2019, through Monday, May 6, 2019, and 13 public hearings, one in each TDHCA State Service Region, will be held during the public comment period. Comments received after 5:00 p.m. Austin local time on May 6, 2019, will not be accepted.

Public hearing details will be provided here and in TDHCA’s online Calendar as “Fair Housing Listings.”

AI Archive

The State of Texas AIs from 2003 forward are listed below (the most recent AI is listed first):

HUD Guidance on Affirmatively Furthering Fair Housing Choice

See below for additional HUD Guidance on Affirmatively Furthering Fair Housing Choice (hud.gov):

  • The Analysis of Impediments Memorandum (PDF)
  • The CDBG Memorandum (PDF)
  • The Fair Housing Planning Guide (PDF)
  • HUD's Final Rule on Affirmatively Furthering Fair Housing