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OPENING PARAGRAPHS: Texas Appleseed appreciates the opportunity to comment on the Draft Housing Guidelines for Hurricane Harvey CDBG-DR programs. We are submitting an initial set of comments highlighting the most critical issues we have identified, and will submit supplemental comprehensive comments. The publication of draft housing guidelines that create standardized housing programs across the disaster-affected region reflects best practices and lessons learned from the State’s previous experience with Hurricanes Rita, Ike, and Dolly, and ensures that Texans will not be treated differently in disaster recovery programs based solely on where they live. We also appreciate the continued emphasis on the State’s committment and its Subrecipients’ obligations to affirmatively further fair housing (AFFH) and ensure that disaster recovery does not leave some families and communities out, or lock them into flood hazard areas. We would strongly encourage GLO to clarify the definition of AFFH and to provide training and technical assistance to Subrecipients. This was a frequent request from Subrecipients in the wake of Hurricane Ike.