Chasing a Paper Tiger: Evaluating Buffalo’s Analysis of Impediments to Fair Housing Choice

Abstract

This article focuses on a specific component of the US Department of Housing and Urban Development's (HUD's) strategy to implement fair housing policy, its requirement for local jurisdictions that receive community development block grant (CDBG) dollars to prepare an analysis of impediments to fair housing choice (AI) report. The article's analysis is based on an evaluation of the City of Buffalo's 2004 AI report. The evaluation was conducted by a local fair housing organization in collaboration with university-based researchers. The findings from the evaluation revealed that the City had made little progress in implementing the action plan from its AI report over an eight year period. This was an outgrowth of local funding constraints, limited staff capacity, ambiguous HUD rules for AI reporting, and a lack of political will to pursue fair housing in Buffalo. In light of these findings, we recommend that HUD: mandate timeframes for AI implementation, require AI updates at regular intervals, and more clearly specify the format and content of AI reports. We also recommend that HUD require jurisdictions to include evaluation plans in their AI reports and measure outcomes from the implementation of AI action plans. These reforms will enhance the ability of AI reports to serve as effective planning tools for the affirmative furthering of fair housing policy.

The Fairest of Them All: Analyzing Affirmatively Furthering Fair Housing Compliance

“…Accordingly, HUD in 1988 developed Fair Housing Review Criteria stating that, absent independent evidence to the contrary, if grantees conducted an Analysis of Impediments to Fair Housing Choice and took actions to address any identified impediments, HUD would presume that they had met their certification to affirmatively further fair housing (U.S. Department of Housing and Urban Development, 1996). But these AIs were rarely reviewed by HUD and were widely seen by grant recipients as irrelevant, leading many recipients to ignore their obligations to further fair housing (Gurian & Allen, 2009;Silverman, Patterson, & Lewis, 2013). A 2010 Government Accountability Office report found that nearly one out of every three AIs was out of date.…”