This case study examines the strategies and process by which this group of cities and housing authorities in North Texas collaborated to conduct its joint AFH.
In 2015, HUD released an updated rule interpreting and implementing the “affirmatively furthering fair housing” (AFFH) requirements of the Fair Housing Act. The new rule required all jurisdictions receiving funding from the Department of Housing and Urban Development (HUD) to conduct and submit an Assessment of Fair Housing study every five years to identify barriers to fair housing in their communities, as well as disparities in housing needs and access to opportunity. (Read more about “Affirmatively Furthering Fair Housing.”) Federal funding was contingent on meeting the AFFH rule requirements. HUD guidance recommended jurisdictions conduct joint assessments or regional collaborations, but collaboration was not mandatory.
The AFFH requirement was suspended in 2018 and then removed in 2020. Despite these changes, the North Texas Region chose to continue its assessment of housing inequality. In doing so, they made clear their commitment to address fair housing concerns and learn about the spatial layout of segregation in the region.
- The collaborative process for developing a regional AFH was crucial for setting fair housing goals and priorities for the entire region. Without this broader lens, local goals and policies would likely have been inherently narrower in scope and less likely to be effective at addressing fair housing and access to opportunity.
- The data and research analysis helped create an informed and deeper understanding of the regional fair housing landscape that could have only been possible through a collaborative effort.
- Coordinating with multiple counties or cities may seem more expensive and time-intensive, but hiring consultants or outside experts may actually result in a more streamlined process. By hiring researchers from a local university, the region was also able to take advantage of relatively cheaper expertise, while increasing local knowledge.
- Conducting a regional AFH avoids duplication of efforts and improves knowledge sharing. (Source)
In November 2018, the North Texas Region published 21 Assessments of Fair Housing (AFH), one assessment for each participating city or public housing authority. The overarching North Texas Regional Housing Assessment (NTRHA) is a 392-page report that gives in-depth information on the current state of the region’s housing, highlights challenges and barriers to fair housing, and sets goals and strategies to affirmatively further fair housing in North Texas.
Figure 1: Participating jurisdictions
The AFH development process (described in more detail in “Process”) revealed seven preeminent fair housing issues:
- Geographic inequality: The nonwhite and low-income populations are concentrated in Dallas. Similarly, the rate of housing problems (e.g. lack of affordable, accessible housing and access to proficient schools or transit) remains greater in Dallas than throughout the region as a whole.
- Racial/ethnic inequities: Black and Latinx households in the region face housing problems and cost burden challenges at a higher rate and with greater geographic dispersion than do white households. The data suggest that nonwhite households have lower access to opportunity than white households.
- Proliferation of racially/ethnically concentrated areas of poverty (R/ECAP): The number of R/ECAPs in Dallas doubled over the last 26 years, with persistent patterns of poverty present in south and west Dallas. While some R/ECAPs dissipated over time, two-thirds of R/ECAPs identified in 1990 retain their designation.
- Growing segregation: The data shows an increasing level of nonwhite/white segregation characterized by clear spatial patterns.
- Source of income discrimination: The data suggests that the prerogative of landlords to refuse voucher holders affects the residential pattern of housing choice voucher families and the concentration of poverty.
- Growing affordability pressure: Home prices, apartment rents, and property taxes continue to rise rapidly and exceed the capacity of many residents to afford housing, especially households with income at or below 30% of the area median income (AMI), persons with disabilities, persons living on fixed incomes, and single-parent families with small children.
- Transportation/employment: Lower-income residents have limited access to affordable housing in proximity to good jobs with better wages. The lack of affordable, reliable transit options worsens this problem.
The AFH also introduced six substantive and procedural fair housing goals that are designed to address the identified issues, foster collaboration within the region, and affirmatively further fair housing (see “Outcomes”).
Process and timeline
In January 2016, the group of 21 Dallas-Fort Worth entities (see Figure 1 above for the full list) formed a working group to respond to HUD’s AFH requirement. While the working group had previously worked together on housing policy, this project was far more substantial and necessitated each entity’s active participation to fix the region’s shared challenges. By October each jurisdiction within the working group submitted a Memorandum of Understanding, confirming their participation in the regional AFH.
The regional working group identified the City of Dallas as the lead entity, a procedural requirement for regional AFHs. The North Texas Regional Housing Assessment (NTRHA) officially launched in January 2017 and was conducted in three phases: community outreach, data analysis, and the formulation of fair housing goals to address the issues identified (described in detail below). The NTRHA contracted the University of Texas at Arlington (UTA) to conduct the assessment due to its unique public policy and data analysis expertise and familiarity with the region’s housing market. The University led all facets of the AFH, including the research design, analysis, and reporting. University researchers also conducted the AFH’s community engagement activities, including additional surveys and interviews to supplement the tools and data provided by HUD. UTA also spearheaded the composition of the final AFH.
The cost of the NTRHA was split among the participating jurisdictions based on their respective CDBG allocations.
Figure 2: Timeline
Phase 1 – Community Outreach (February 2017)
The official community engagement process began with the launch of the NTRHA website in February 2017. The website, which was created with a plug-in that allowed it to be translated into over 100 languages, provided the general public with information on the AFH process, relevant presentations, and project updates, as well as updated times and locations of public meetings and focus groups.
UTA researchers facilitated the NTRHA’s community engagement and outreach activities, rather than city officials facilitating these efforts, so community members would feel more comfortable openly sharing firsthand experiences, knowledge, and criticism. The researchers engaged community members, stakeholders, and subject matter experts using a variety of strategies, including public meetings, focus groups, consultations, and surveys, even updating and creating tools throughout the process to respond to community needs.
Surveys opened in March and were available for over a year. There were three rounds of surveys, the first of which asked respondents to share their views, concerns, priorities, and level of satisfaction related to fair housing and quality of life issues, like health and transportation. The second round of surveys also included questions to capture socio-demographic information, tenure, and employment status. The final survey was further expanded to include questions about fair housing enforcement.
The survey was followed by focus groups, two rounds of public meetings (38 meetings for the City of Dallas alone), and individual consultations, which ran throughout the project. (See Figure 3 for a full list of tools used throughout the public participation process.) These various engagement strategies were used to gain insight into fair housing barriers existing in the city and region. The findings from these community engagement practices were then reviewed by a technical advisory board of experts and used to help formulate fair housing goals.
Figure 3: Strategy breakdown
Phase 2 – Data Analysis (September 2017)
As part of the requirements for final AFH submission, UTA conducted quantitative analyses of both HUD and locally-collected data describing patterns of segregation affecting groups with protected characteristics. They examined the intersection of poverty, transportation, segregation, and housing. Their study was informed by the stakeholder and expert knowledge collected in Phase 1, and also focused on racial and ethnic segregation, the concentration of poverty, and housing problems for families with children, seniors, and persons with disabilities and limited English proficiency, as well as other protected classes.
The data analysis process culminated in the region finding seven preeminent fair housing issues.
Phase 3 – Formulation of Fair Housing Goals (May 2018)
In this phase, UTA researchers collaborated with staff from participating entities to identify priorities for action based on the data analyses from both the HUD provided data and the data collected through the community outreach efforts. These action items then informed fair housing goals to address these issues (see “Outcomes” for more information).
The AFH revealed a stark geography of inequity unveiled by the AFH resulting from a growing racial ethnic and economic segregation, racial/ethnic inequities, affordability pressures, and systemic barriers to accessing opportunities. To respond to these challenges, the AFH introduced the following six fair housing goals to affirmatively further fair housing. These goals are meant to foster collaboration within the region, acknowledge and address geographic inequalities, and to be both substantive and procedural. The goals are to:
- Increase access to affordable housing in high opportunity areas
- Prevent loss of existing affordable housing stock and increase supply of new affordable housing, especially in higher opportunity areas
- Increase supply of accessible, affordable housing for persons with disabilities
- Make investments in targeted and segregated neighborhoods to increase opportunity while protecting residents from displacement
- Increase services for residents of publicly supported housing and maintain and improve the quality and management of publicly supported housing
- Increase access to information and resources on fair and affordable housing
The AFH process had a number of benefits beyond just producing a report. For example, the City of Dallas has started to work in a more collaborative way across department lines and the city formed cross-functional teams with representation from multiple departments to achieve goals and remove silos. The data collected from the AFH is also helping make more informed decisions. The AFH process pushed the city to continue to develop revitalization strategies for R/ECAP and blighted areas and to review Housing Policy to verify that the needs of lower-income residents were being met.
To advance its fair housing goals, the City of Dallas also established an Office of Equity in October 2018. While the report suggested that there might be promising initiatives such as the housing policy proposed by the Office of Equity and Human Rights, to date there is little publicly accessible information about these efforts. Although this report provided a path towards greater equity in the region, the future use of the process is uncertain due to the rollback of the AFH requirement by the Trump administration.
Working as a region made it possible to more deeply understand the region’s housing problems and develop six housing goals to address these issues and foster continued regional collaboration. The regionally collaborative approach of this AFH proved helpful in several ways for the North Texas Region. Firstly, housing policy often has regional implications. Research has shown that the most fragmented regions in the US have the greatest degree of regional and racial inequity. Similarly, across the country, segregation is increasing at the regional level and is less severe when examined at the city or local level. In order to address issues of segregation and fair housing at the regional level, cities and housing authorities must collaborate on a regional level.
Finally, although HUD no longer requires that jurisdictions submit extensive AFH plans, examples like this one may be useful in the future. The Biden administration has signaled its intention to reinstate the rule and just after taking office, President Biden signed an executive order, mandating HUD to examine the effects of the previous administration’s signature housing policy, “Preserving Community and Neighborhood Choice.” The lessons learned during the North Texas process can help inform refinements and revisions as the next iteration of the AFFH rule takes shape.
- Assessment of Fair Housing Tool for Local Governments [PDF]. (2017). PRRAC.
- North Texas Regional Housing Assessment [PDF]. (2018). City of Dallas.
- North Texas Regional Housing Assessment [PDF]. (2017). City of Plano.
- Executive Summary: North Texas Regional Housing Assessment [PDF]. (2018). City of Dallas.
- 2018 Analysis of Impediment: North Texas Regional Housing Assessment [PDF]. (2018). City of Frisco.
- U.S. Department of Housing and Urban Development. (2020, December 16). Data and tools for Fair Housing Planning. Retrieved April 12, 2021, from https://datacatalog.urban.org/dataset/data-and-tools-fair-housing-planning
- US Department of Housing and Urban Development. (n.d.). Fair Housing Planning. Retrieved April 12, 2021, from https://www.hudexchange.info/programs/fair-housing-planning/
- M. Igoufe (2018, November 9). Racial and economic segregation in Dallas is getting worse [Editorial]. Dallas News. Retrieved February 12, 2021, from https://www.dallasnews.com/opinion/commentary/2018/11/09/racial-and-economic-segregation-in-dallas-is-getting-worse/
- Briefing on the Regional Assessment of Fair Housing [PDF]. (October 2016). City of Dallas.