Currently, an Entitlement is required to only complete
an Analysis of Impediments to fair housing choice. This document, generally, is completed in conjunction with the 3/5 Year Consolidated Plan, but is not required to be submitted with the Plan. Therefore, when it is required to review the Analysis of Impediments, most often, it must be obtained from the Grantee.
My suggestion is a Community Planning Development update of Regulation to require this document to be submitted in conjunction with the 3/5 Consolidated Plan, which is a more efficient and effective mode of operation.