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.

Draft AI for Public Comment

To garner input on the draft AI, a public comment period will be open from March 25 through 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.

Anyone may submit comments on the draft AI in written form or oral testimony at the public hearings. In addition, written comments concerning the draft AI may be submitted by mail to the Texas Department of Housing and Community Affairs, Attn: Cate Tracz, P.O. Box 13941, Austin, TX 78711-3941, by email to cate.tracz@tdhca.state.tx.us, or by fax to (512) 475-3935 anytime during the comment period. Those making public comment are encouraged to reference the specific section of the AI related to their comment. For information on the public comment process, visit TDHCA’s Public Comment Web page at: http://www.tdhca.state.tx.us/public-comment.htm.

Public Hearing Schedule

Date and Time


Public Hearing Location

April 10, 2019


San Antonio

Haven for Hope Volunteer Center

1 Haven for Hope Way, San Antonio, TX, 78207

April 11, 2019



City Hall Council Chambers

101 N. College Street Killeen, TX 76541

April 12, 2019



Texas Health and Human Services

909 West 45th Street, Room 164, Austin, TX 78751

April 15, 2019


El Paso

City of El Paso Council Chambers

300 N. Campbell El Paso, Texas 79901

April 16, 2019



MLK Center

2300 East Butternut Lane, Midland, TX 79701

April 16, 2019



City of Lubbock Council Chambers

1625 13th Street, Lubbock, TX 79401

April 17, 2019


Wichita Falls

Nortex Regional Planning Commission

4309 Old Jacksboro Hwy, Suite 200, Wichita Falls, TX 76302 (North side of the Galaxy Building)

April 18, 2019



J. Erik Jonsson Central Library, Stone Room (7th floor)

1515 Young Street, Dallas, TX 75201

April 18, 2019



Maude Cobb Convention & Activity Center

100 Grand Blvd, Longview, TX 75604

April 30, 2019



Hidalgo County Commissioners Courtroom

Administration Building Annex III

100 East Cano Street, Edinburg, TX 78539

May 01, 2019



City of Victoria Council Chambers

107 W. Juan Linn Street, Victoria, Texas 77901

May 01, 2019



BakerRipley, Education Center

3838 Aberdeen Way, Houston, TX 77025

May 02, 2019



R.C. Miller Memorial Library

1605 Dowlen Road, Beaumont, TX 77706

Individuals who require auxiliary aids or services at the public hearings should contact Ms. Cate Tracz, ADA responsible employee, at (512) 936-7803 or Relay Texas at 1-800-735-2989 at least three (3) days before the meeting so that appropriate arrangements can be made.

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 on March 21, 2019, the Board approved of a draft AI to be released for public comment from March 25 through May 6, 2019.

Data used in the AI:

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