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table should be created considering contributing factors in an urban, suburban and rural context as defined by the U.S Census Bureau. The table should include metrics that define each contributing factor, providing grantees and housing authorities clear guidelines of what it means to successfully affirmatively further fair housing. Once this tool has been revised, we request a full 60 -day cor n ent period in order for staff to conduct a thorough review of the tool This tool represents significant impacts to our programs and our community and we need to ensure that we understand HUD's intent and the required steps to move forward. Organizations such as NACo, NAHRO, NACCED, and NCDA submitted concerns during the initial 60 -day comment period (ending November 25, 2014) that went largely unaddressed For example, see NACo's response letter dated Novernber 25, 2014, commenting on the proposed Assessment Tool. NACo urged HUD not to mandate use of the Tool Douglas County wholeheartedly supports the comments previously offered by these organizations We strongly encourage HUD to take seriously the responses from these organizations, as well as responses from the grantees and housing authorities that wiil be required to implement the Tool. Approving the Tool as is will negate the County's rights and seriously hamper our ability to effectively respond, manage local affairs, and affirmatively furtherfair housing, The definition of Affirmatively Furthering Fair Housing must be refined The definition is shown below with the red text indicating unclear phraseology: "Taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communitrefree fiom barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful action that, taken together, address significant disparities in housing heeds and in access to opportunity, replacing segregated living patterns with tru'yintegroted and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas 6f opportunity, and fostering and maintaining corn pl;ance with civil rights and fair housing laws. The duty to affirmatively further fair housing extends to all of a program participant's activities and programs relating to housing and urban development." NACo raised concerns about how these terms are defined in their original response letter. Essentially, how will we know when we have taken meaningful actions? How can we overcome patterns of segregation? How will we know which opportunities are important enough to provide access, when each 2 /92 - Z J