CLPHA, Reno & Cavanaugh Submit Comments Opposing HUD’s Transphobic Proposed Changes to the Equal Access Rule

Date Published: 
September 24th, 2020

On September 22, CLPHA and our counsel Reno & Cavanaugh submitted comments to HUD strongly opposing the agency’s transphobic proposed modifications to the Equal Access Rule. The changes would reverse the 2016 portion of the rule that requires homeless service providers to accommodate individuals seeking shelter according to their gender identity, not limited by their biological sex. 

While our work is dedicated primarily to PHAs and those seeking affordable long-term housing, we feel a kinship with organizations providing safe accommodations to those in need, and a responsibility to ensure fair housing choice to all seeking refuge. It is out of this sense of solidarity with all those seeking and providing housing that we submitted these comments urging HUD to withdraw this proposed rule.

As we state in our comments, the proposed changes “give lip service to HUD’s moral and legal responsibilities to the transgender population while stripping legal protections and rubber-stamping discrimination towards this vulnerable population.” 

Upon HUD’s announcement of this proposal, CLPHA Executive Director Sunia Zaterman released a statement condemning the agency’s plan to essentially sanction transphobia in same-sex homeless shelters:

“The significant impact of the Administration’s pernicious, discriminatory proposal aimed against transgender individuals, one of the most vulnerable and marginalized communities in America, cannot be overstated. One in three transgender Americans has been homeless at some point in their lives. Shelter is the most basic of human needs. To deny it at the most vulnerable moment in the life of a transgender individual denies trans people their human dignity.”

For questions about our comments, please contact Research & Policy Manager Emily Warren at


Read Our Comments

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