On Thursday, October 27, the City of Philadelphia and the Philadelphia Housing Authority released a draft of their “Assessment of Fair Housing.” The doorstopper of a document is the result of a federal rule issued in 2015 to bolster the long-unfulfilled promise of the 1968 Fair Housing Act to eliminate housing discrimination and segregation. Previously jurisdictions were required to simply explain the impediments to fair housing, but now they must spell out the goals that will—in a bureaucratic tongue twister— “affirmatively further fair housing” (AFFH).
The late October release kicked off a 45-day public comment period for feedback on the report, which will be incorporated into a final version submitted to the U.S. Department of Housing and Urban Development (HUD). Federal funding could be imperiled if the federal housing agency finds the document wanting. Regardless of possible punitive measures, local advocates see the document as a means to shape how resources are allocated in an intensely segregated city where almost a third of residents qualify for housing assistance.
After the report dropped ten days ago, PlanPhilly’s initial calls for comment on the result were met with mirthless laughter. No one except Paul Chrystie, press representative for the city’s Division of Housing and Community Development (DHCD), would immediately comment on the 750-page tome (500 pages are appendices).
Chrystie emphasized that critics of the initial engagement process, which raised concerns among housing advocates (especially Hispanic and Asian groups), were already being consulted about how final report could be updated.
“I don’t think there’s anything that’s particularly surprising here,” says Chrystie. “We face a variety of challenges and the resources to meet those challenges are fairly low. At the same time we have assets. We have neighborhoods people like, we have good transit access. Both residents and stakeholders want us to invest in struggling neighborhoods as a part of a balanced approach to housing and opportunity.”
Now almost two weeks after the report’s release, housing and community development advocates have actually finished digesting the report. Criticisms of the AFFH process are still common, if more muted than they were during the engagement process. But pretty much everyone PlanPhilly spoke with agreed that the sheer volume of research and the report’s maps were very impressive.
The fair housing report meticulously documents conditions facing the city’s vulnerable populations, including grim employment numbers (all non-white racial groups in the city face double digit unemployment) and the ironclad persistence of segregation. Some housing challenges are included that have received too little public attention, like the silent eviction crisis that chiefly tears at the city’s black population. Other more well-known threats, such as the ever-falling federal support for deteriorating public housing, receive their due as well.
There are some noticeable omissions though. For example, there are only passing mentions of the unique challenges facing domestic violence survivors. The phrase “lead paint” is only mentioned once. For Sarah Yeung, director of planning for the Philadelphia Chinatown Development Corporation, there still isn’t enough emphasis placed on the distinct challenges facing different Asian communities.
“Asians are a community of contrasts and the city can’t rely on a group like PCDC to speak for the whole race,” says Yeung, who cites recent findings that 65 percent of Cambodians in Philadelphia are low-income as compared with 27 percent of Indians. “Aggregate whole groups under one umbrella and you mask the needs that are there. It’s incredibly important to get as much local knowledge and community engagement as possible in this 45-day response period.”
There are 32 goals sketched at the conclusion of the fair housing report, under the broad aegis of categories like “Develop new affordable rental housing” or “Preserve existing affordable homeownership housing.” Each entry is organized in an eight-celled table, with text in a very small font.
“I think the City and PHA have probably done the best job they could with the time and resources they had,” says Rasheedah Phillips, managing attorney of Community Legal Services’ housing unit. “The data is pretty good and the maps are excellent but that is sort of where it ends when it comes to positives. It’s kind of confusing. Compare the report with New Orleans, which turned out very well. It’s clearer and easier to read.”
New Orleans released their report about a month before Philly and it looks downright sleek at a cool 246 pages. The table sketching out the goals in the conclusion of the Big Easy’s document is easier to read, with each entry laid out in larger cells with larger font sizes. New Orleans’ plan is more detailed, noting which issues arise in specific neighborhoods and ranking the city’s fair housing priorities.
Phillips also finds fault with Philly’s fair housing report for underplaying the diversity of challenges, which she blames on a limited community outreach effort that didn’t try to reach the poorest residents outside of PHA’s own tenants. She notes that none of the thousands of clients CLS serves have been aware of the process or filled out the surveys the city circulated to solicit community feedback.
Barriers for seniors and African-Americans are central to the report, Phillips says, but more specific groups are sidelined (like veterans and mothers who are often at greater risk of eviction because of their children). The strategies listed include policies that are already being pursued, like letting the private market shore up public housing through the RAD program or bolstering the home repair funding programs Darrell Clarke’s proposed $100 million bond would cover.
The goals, in Phillips’ reading, largely hew to what the city already does. But more radical strategies are included too, like helping Section 8 voucher holders settle in high opportunity suburbs or building affordable housing in stable, higher-income neighborhoods.
These opportunities have not often pursued been because of community opposition and toothless regional planning. But other advocates see the potential for significant changes to the status quo in these elements of the fair housing report.
For Beth McConnell, policy director of the Philadelphia Association of Community Development Corporations, repeated references to building new affordable housing in high opportunity areas could mark a substantial change in direction.* Such an effort would promote integration, but nonprofits building low-income housing fear a mandate to build in more expensive neighborhoods could mean creating fewer total units in the end.
“Some strategies we see in the assessment of fair housing are new strategies that the city hasn’t invested in before,” says McConnell. “[Our members] use rental housing development as a way to revitalize entire neighborhoods and leverage other investment to improve quality of life for all residents. There is tremendous value in developing affordable homes in good quality neighborhoods, but without more resources we might have to do less of one to do more of the other.”
Then there’s the older question of representation of Latinos and Asians in the Philadelphia Housing Authority’s rolls. From the beginning of the AFFH process, critics like Latino advocacy group Ceiba have highlighted the small numbers of Latino and Asian families both in PHA’s programs and on its lengthy waiting lists.
Among impoverished households in Philadelphia, 23 percent are Latino, but only about 5 percent of public housing residents are Latino. The housing authority doesn’t have data on the languages public housing residents speak at home, according to the Public Interest Law Center, but that information exists for housing choice voucher recipients. Only 18 of close to 19,000 voucher holders spoke Spanish at home (none spoke Chinese or Vietnamese). Only 8 percent of the current waitlist for housing vouchers and project-based public housing identify as Latino.
“I would look at his as two separate reports pushed together, one from PHA and one from the city government,” says Dan Urevick-Ackelsberg, a lawyer with the Public Interest Law Center who focuses on housing. “The city side has the bones of a good report, although they need more outreach and to connect the problems they’ve identified with more concrete goals. But the PHA side is wholly unacceptable.”
The issue of underrepresentation is discussed in the AFFH study, where it is noted that race-based preferences are illegal. As a result, the report concludes that dramatic changes to the ethnic composition of PHA’s waitlist will be dependent on the rate of vacancies or the availability of new vouchers. Addressing underrepresentation of Asians and Latinos is not listed as one of the goals at the end of the report.
“In 5 years they could set a goal that the wait list will reflect Philadelphia, or they could increase by X percent in historically underrepresented communities and then do aggressive outreach,” says Urevick-Ackelsberg. “Instead they just wash their hands of it and say the only answer is more production or turnover. That’s just not an acceptable fair housing response.”
PHA president and CEO Kelvin Jeremiah argued that the only way to adjust the wait list would be to build more housing or get more funding for vouchers. He highlighted his organization’ work in partnership with community groups like Esperanza and Philadelphia Chinatown Development Corporation, and says that 300 units of new affordable housing have come from such collaborations. Jeremiah told PlanPhilly that the authority is considering opening the wait list for vouchers, which is currently closed because there are close to 100,000 people on it, as a way to potentially diversify it.
“The wait list is only reduced when we remove people from it,” says Jeremiah. One thing we can do is open it up to admit additional families and that’s something we are considering. But that in and of itself does not go to the heart of the issue. The only way to reduce the numbers on our waitlist is to increase the availability and supply.”
To advance outreach among the vocal but underrepresented Asian and Latino communities, Chrystie says the city is already in talks with stakeholders about holding additional Spanish- and Chinese-language meetings.
The next stage in Philadelphia’s fair housing process will be a series of public meetings on November 17, first one held by the housing authority from 11:00 am -1:00 pm and then one by the city from 4:00- 7:00 pm.
The report will be amended to incorporate public feedback, sent to the PHA board for adoption, and submitted to HUD by the end of the year. There will be 60 days for the federal agency to review it and offer recommendations for improvements.
*DISCLAIMER: Beth McConnell sits on PlanPhilly’s advisory committee.