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Monday, June 1, 2015

Getting a Handle on the Analysis of Impediments to Fair Housing

HUD requires each entitlement jurisdiction to update its Analysis of Impediments (AI) to fair housing every five years, concurrent with the update of the Consolidated Plan. Unlike the Consolidated Plan, the AI is not submitted through IDIS to HUD, but is kept on file at the jurisdiction. Five years is a long time, so here's a refresher (or introduction) on how to approach the AI.

 I recommend you review HUD's Fair Housing Planning Guide to make sure you are addressing all of the relevant topics. The AI can be organized in five general sections:

  1. Goals and Process- definition of Fair Housing Impediments, AI goals, and process, including description of entities consulted (government agencies, housing authority, lenders, real estate agents, landlords, legal services, services for disabled persons, advocacy groups, etc.);
  2. Background Data- demographics (population, race, ethnicity, household characteristics), household income, employment, transportation, and housing (type, rents, vacancies, condition). 
  3. Potential Public Impediments
  4. Potential Private Impediments
  5. Summary of Impediments and Plan to Address Them
While all of the sections are essential, most of the effort should be focused on the potential Impediments (Sections 3 and 4). In researching potential Impediments, here are some of the key questions to consider with respect to the Public Sector:

Are building and zoning codes in compliance with State and Federal Law with regard to fair housing?

Do building or zoning codes make it more difficult for protected fair housing classes to access housing than other populations?

Are low-income or racial minority populations concentrated in particular neighborhoods? Do these neighborhoods have good access to transportation, amenities, public services and employment? Are there public policies that intentionally or unintentionally lead to low-income or racial minority population concentrations?

Do zoning or building codes present impediments to building affordable housing throughout the jurisdiction or in particular communities (e.g. minimum lot sizes, excessive parking requirements, lengthy review processes)? Are there policies that treat affordable housing different than market rate housing?

Are financial resources made available for affordable housing?

Do planning and zoning boards reflect the community's diversity? Is the board member selection process open, transparent and fair?

Are Section 8 voucher holders concentrated in particular neighborhoods, or are they broadly distributed throughout the jurisdiction? If concentrated, what are the conditions in these neighborhoods? Is the Housing Authority making efforts to open access to new neighborhoods?

Does the Housing Authority provide implement reasonable accommodation procedures, pursue tenant access to a variety of neighborhoods, empower residents to help shape their communities, and provide opportunities for tenants to move to homeownership?

Good data sources for the Background Data section include:
I hope this helps you get started. Give me a call if you need further assistance. Good luck with your AI!