The Chicago Department of Housing Announces New Racial Equity Focus for Affordable Housing Resources
The country’s first Racial Impact Assessment on a Qualified Allocation Plan will ensure that developments supported by Low-Income Housing Tax Credits are equitably allocated to address the needs of communities of color and working-class families
CHICAGO – The Chicago Department of Housing (DOH) today released the country’s first Racial Equity Impact Assessment (REIA) on a Qualified Allocation Plan (QAP) for Low-Income Housing Tax Credits (LIHTC). Racial Equity Impact Assessments are used to examine how different racial and ethnic groups are or will be affected by existing or proposed programs, policies, or decisions. This REIA will inform how, where and to whom the department allocates tax credits, and how DOH incorporates a racial equity lens to garner opportunities for community wealth building.
In addition to the draft REIA-QAP report, DOH is also releasing the 2021 Draft Qualified Allocation Plan (QAP) and the draft Architectural Standards (ATS) Manual for a 30-day public comment period.
"Racial equity must be at the core our efforts to mend and move forward from our city's history of housing discrimination and displacement of residents of color," said Mayor Lori E. Lightfoot. "With this REIA, we will be able to course correct housing strategies to ensure these residents will still have access to affordable housing resources and any other community benefits well after projects are completed. Helping our residents from underrepresented backgrounds live comfortably and build wealth is not only our responsibility as city officials, but key to Chicago's ability to prosper and thrive well into the future."
In August 2019, DOH released a revised QAP process that included unprecedented transparency to guide developers applying for credits based on priority locations, building types and uses, and affordability levels. The credits, recently issued by the City every two years, represent approximately two-thirds of Chicago’s affordable housing resources. The REIA is the department’s own evaluation of its tax credits over the past 20 years, as well as a structure for ongoing examination and accountability through a racial equity lens of itself and those involved in the development, construction and management of LIHTC units.
“With Chicago’s long history of institutionalized racism and segregation, we are very aware of the need to examine our work and be accountable for our outcomes,” said DOH Commissioner Marisa Novara. “We commit to examining the results of our work by race, and based on what we learn, adjusting accordingly. Repeatedly. Given the long role that government has played in creating and maintaining segregation and inequities by race, this is our work to do.
Examples of findings from the REIA include that since 2000, the majority of Chicago’s LIHTC developments have been new construction located in high-poverty, majority Black areas, with a quarter located in higher-income “opportunity” areas. In addition to analyzing data, discussions with impacted groups revealed barriers to BIPOC developers in participating in LIHTC projects and areas for improvement in project characteristics and management. The 2021 QAP incorporates these and other improvements and recommendations that were revealed through the REIA process.
Racial Equity Impact Assessments are public examinations of how different racial and ethnic groups are affected by proposed or existing programs, policies, or decisions. REIAs are used to minimize unanticipated adverse consequences including proposed policies, institutional practices, programs, plans and budgetary decisions. For organizations looking to address and prevent institutional racism, an REIA is a vital tool for identifying new ways of remedying long-standing inequities.
“This is a powerful step in institutionalizing equity into how we do business as a City. REIAs is one tool that a growing number of government departments and agencies are using to guide equitable policy development and decision-making,” said Candace Moore, Chicago’s Chief Equity Officer. “I am excited the Department of Housing is paving the way for the City of Chicago.”
DOH’s newly formed Office of Community Engagement, Racial Equity and Strategic Initiatives (CERESI) hosted a series of in-person and virtual meetings in the fall of 2020 as part of the REIA process. More than 130 residents, developers, housing advocates, funders and policy makers participated in the workshops. DOH partnered with national housing nonprofit Enterprise Community Partners on research, engagement, analysis and writing, and worked with Katanya Raby, a Chicago United for Equity 2020 Fellow, on project design and management.
“The QAP REIA is truly a collective effort that involved an array of voices, especially the voices of the residents living in LIHTC units, in order to better understand systemic racism and meaningfully begin to undo those harms,” said Sendy Soto, DOH Managing Deputy Commissioner. “We could not have done it without the support of residents, community groups and the Multi-family Bureau at DOH that manages the program.”
Informed by community participation and existing data, DOH and Enterprise identified eight themes that will inform the 2021 QAP Application and future processes to ensure racial equity is driving the program:
- Ensure Black, Indigenous, people of color (BIPOC) developer/service providers benefit from LIHTC
- Prioritize investments in data infrastructure and reporting so that it can prioritize LIHTC developments serving residents that are most in need
- Prioritize access to affordable housing opportunities by ensuring that marginalized residents are not unfairly screened out of the process due to arrest/conviction records, evictions, or low/no credit scores
- Ensure residents have choices about where they can live affordably by ensuring that affordable developments are built in highly resourced, amenity-rich areas
- Increase the inclusion, power, and self-determination that LIHTC residents have over their living environments and improve their health, wealth, and opportunities in life
- Improve outcomes and wealth building opportunities for residents by incentivizing applications that offer or provide access to programs like homeownership support and workforce development programs
- Ensure residents with disabilities and diverse language needs can find and live in LIHTC units that accommodate their needs
- Support incentives for partnerships and wrap-around services that create or provide access to health and wellness spaces and activities.
“With the REIA, Chicago is taking real steps to ensure that the millions of dollars it commits to affordable housing help to dismantle the systems that have denied BIPOC developers and residents the opportunity to create communities that are places of pride, power and belonging,” said Andy Geer, VP and Chicago Market Leader, Enterprise. "Working through the process with the city, residents, developers and community stakeholders, we commend the intentional and comprehensive effort to advance racial equity.
A draft of the 2021 QAP Application, which will allocate over $61 million for 2022 and 2023 developments, the Architectural Technical Services (ATS) manual and the REIA-QAP are all available for public comment and can be found by visiting www.chicago.gov/qap. Public comment on the QAP, the REIA-QPA and the ATS will be accepted through April 15, 2021 at DOH@cityofchicago.org.
Enterprise is a national nonprofit on a mission to make home and community places of pride, power and belonging for all. To make that possible, we operate the only organization designed to address America’s affordable housing crisis from every angle: we develop and deploy programs and support community organizations on the ground; we advocate for policy on a nonpartisan basis at every level of government; we invest capital to build and preserve rental homes people can afford; and we own, operate and provide resident services for affordable communities. All so that people not only make rent, they build futures. With this end-to-end approach, 40 years of experience and thousands of local partners, Enterprise has built and preserved 793,000 affordable homes, invested $61 billion in communities and changed millions of lives. Join us at www.enterprisecommunity.org.