FR-6518-P-01 Equal Access to Housing in HUD Programs Revisions

The New York Legal Assistance Group (NYLAG) opposes the proposed rule, arguing that it is unlawful, arbitrary, and capricious because it lacks a reasoned justification for reversing existing non-discrimination protections. They contend that the rule will harm LGBTQ+ individuals and domestic violence survivors by creating barriers to shelter access and increasing the risk of street homelessness.

The Citizens’ Housing and Planning Association (CHAPA), a Massachusetts non-profit advocacy organization, opposes the Proposed Rule because it removes protections for LGBT individuals in HUD-funded housing. They argue that the rule lacks factual support for its safety and privacy claims, ignores evidence of high LGBT homelessness rates, and creates an enforcement vacuum that will exacerbate discrimination against the trans community.

The League of United Latin American Citizens (LULAC) opposes the proposed rule, arguing that it could create barriers for vulnerable populations, particularly transgender individuals and Latino families. They express concern that the rule lacks sufficient evidence regarding its impact on shelter utilization, creates administrative burdens for those without identification, and removes explicit nondiscrimination protections.

The National Center on Homelessness submitted an informational fact sheet regarding the link between housing instability and suicide risk among Veterans. The document provides research data and clinical recommendations but does not express a specific position of support or opposition toward the proposed HUD revisions.

Lambda Legal Defense and Education Fund, Inc. opposes the proposed rule, arguing that it would discriminate against LGBTQ+ individuals and increase risks of violence, trafficking, and homelessness. They contend the rule exceeds HUD's authority, contradicts its mission, and violates existing laws like the Fair Housing Act.

Southern Legal Counsel, Inc.’s Transgender Rights Initiative opposes the proposed rule, arguing that it removes essential non-discrimination protections for transgender and gender non-conforming individuals in HUD-funded housing and shelters. The organization contends that the revisions would exacerbate housing disparities, increase risks of violence and harassment, and violate established legal protections under the Fair Housing Act.

Texas Appleseed, a nonpartisan nonprofit, opposes the proposed rule, arguing it would cause severe harm to homeless youth and LGBTQ+ individuals by removing nondiscrimination protections. They contend the rule is unsupported by evidence, encourages discrimination against survivors of gender-based violence, and creates significant compliance burdens and legal uncertainty for housing providers.

Maryland Legal Aid, a nonprofit law firm, strongly opposes the proposed rule because it would rescind protections for LGBTQ+ individuals and families in HUD-assisted housing and shelters. They argue the proposal is based on stereotypes rather than evidence, violates federal and state civil rights laws, and would increase discrimination and homelessness for transgender people.

Southern Arizona Legal Aid, a legal services organization, opposes the proposed rule because it rescinds protections for LGBTQ+ individuals and families in HUD-funded housing and shelters. They argue the rule will lead to discrimination, physical violence, and exclusion for transgender people while potentially violating the federal Fair Housing Act.

Americans United for Separation of Church and State opposes the Proposed Rule, arguing that it would remove critical protections against discrimination for LGBTQ+ individuals and lead to serious harms for vulnerable populations. They contend that the current rule does not unconstitutionally burden religious freedom and that the proposed changes would allow for discriminatory practices under the guise of religious accommodation.