Ask HUD to uphold gender protections at shelters

Let’s not add barriers to people needing shelters and housing services

The Department of Housing and Urban Development (HUD) has proposed a new rule that could decrease shelter access and increase the risk of homelessness for transgender and non-binary people in our communities. The proposed rule is now open to public comments, allowing people of faith, service providers, and concerned advocates the chance to offer their perspectives on the issue through September 22.

HUD’s proposed change would weaken existing protections under the 2016 issued ”Equal Access Rule,” allowing sex-segregated shelters to consider someone’s biological sex — rather than  their self-identification — in making placement choices and how they accommodate people seeking shelter. Currently, the unrevised Equal Access Rule requires housing and shelter facilities to ensure equal access to benefits, services and accommodation for individuals based on their gender identity without intrusive and harmful questioning or government ID requirements.

The proposed change comes at an already challenging time for those of us struggling with homelessness. According to the Alliance to End Homelessness (Alliance) and HUD Point-in-Time data, homelessness among gender minorities has been increasing rapidly in the last several years, and recent economic turbulence isn’t likely making the situation better. “Since 2016,” according to the Alliance report, “homelessness among transgender people increased 88% overall, with unsheltered homelessness among trans people increasing 113%.” Adding additional barriers to shelters and housing services could potentially worsen these trends, and wear on the tired hope and trust of individuals in the good faith of service providers.

The ELCA in numerous social teaching documents and statements has affirmed that denying services based on sexuality, gender or any other form of discrimination brings us far short of God’s vision and our own goals of living together as one just society.  The ELCA social statement Human Sexuality: Gift and Trust (2009) affirms that, “Hate crimes and violence against those who are regarded as sexually different sometimes have been perpetrated publicly in the name of Christ. Not only must such behaviors be denounced, but this church must work toward greater understanding of sexual orientation and gender identity.” In a press statement highlighting the rule, HUD cited religious beliefs as a driver of the proposed change, making it even more critical for Lutheran voices to speak against the discrimination of our LGBTQIA+ siblings, naming that denying safe shelter is not compatible with our faith.

Write and customize a unique public comment to HUD below by:

1. Enter your contact information to register your comment.
2. PERSONALIZE your public comment, and to tell HUD who you are, what you do, and why you’re writing. (DON’T submit your letter without making changes – at least 20% fresh content to be read!)
3. Submit your comment by September 22!


  • Department of Housing and Urban Development


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Proposed Rulemaking Docket No. FR6152P01, Revised Reqs Under Community Planning and Development Housing Programs

Dear [Decision Maker],

[Your Name]
[Your Address]
[City, State ZIP]