On April 16, Texas Housers submitted comments alongside Texas Appleseed on Houston’s Analysis of Impediments to Fair Housing Choice. Every five years, the Department of Housing and Urban Development requires all governments receiving federal housing dollars to perform an Analysis of Impediment, also known as an AI, to ensure that all of its residents are protected by the Fair Housing Act and not subject to housing discrimination because of their race, color, sex, religion, familial status, national origin, or disability status. The AI process was created by HUD to strengthen the federal government’s efforts to force cities and states to confront generations of public and private discrimination against people of color and other protected classes.
We evaluated Houston’s AI through the framework of the Four Rights. Although the city recognizes many of its fair housing problems, it refuses to commit to meaningful action steps that will right past wrongs. Recognition without action does not fulfill the purpose of the Fair Housing Act’s mandate. In our comment, we make a list of action steps Houston should take to honor its commitment to the Fair Housing Act and ensure that every resident lives out the four rights. A few of these recommendations follow.
- To ensure that every Houstonian has the right to choose, Houston must commit to building 1,000 truly affordable housing units for low-income families in high opportunity areas. These units must be close to good jobs, well-resourced and high-performing schools, and away from environmental hazards. Houston is one of the most racially segregated cities in America and, according to HUD data, it’s getting worse. For years, rich, majority white neighborhoods have fought tooth and nail to keep affordable housing out, shunning Houstonians of limited means. This opposition is rooted in racism, fearful of being neighbors with low-income Houstonians who are disproportionately people of color. Houston must no longer allow its policies to be dictated by malice and commit to inclusivity.
- To ensure that every Houstonian has the right to stay, Houston must commit to protecting vulnerable renters and homeowners from displacement in gentrifying neighborhoods. To protect renters, Houston must provide funding for emergency rental assistance, protect tenants from retaliation, and guarantee tenants the right to organize. In properties which the city funds, they must ensure that citizens have a right to cure late rent before eviction can begin. To protect homeowners, the city should assist low-income homeowners to hold clear titles to their homes and obtain homestead exemptions. It must also preserve affordable housing units in gentrifying neighborhoods by identifying and conserving affordable housing in danger of being lost and supporting community land trusts.
- To ensure that every Houstonian has the right to equal treatment, Houston must commit $1 billion dollars of public funds to the Complete Communities Initiative over the next five years to begin the process of reparations for past housing injustice and systemic racism. For years, neighborhoods have color have suffered from discrimination and neglect at the hands of government and private enterprise. Houston’s neighborhoods of color have lower performing schools, higher rates of poverty, less access to jobs, fewer banks and credit unions, and greater exposure to environmental health hazards. In 2019, Texas Housers found in its own analysis that 0% of Houston’s superfunds sites were located in richer, whiter, high opportunity areas while 50% of superfund sites were in historically minority neighborhoods. Further, 89% of municipal solid waste facilities and 79% of Brownfields were located outside of the high opportunity zone. We also found that 71% of schools in historically minority neighborhoods had Student Achievement Scores below 20. The city itself found that 80% of substandard open ditch drainage was located in Black and brown neighborhoods, almost half of which did not function. The City of Houston must make substantial investments and efforts in these neighborhoods to right these wrongs. This must begin now.
- To ensure that every Houstonian has the right to have a say, Houston must create a Community Development Advisory board to monitor the spending of community development dollars and oversee the implementation of the AI and other plans related to equitable development. At least one-third of the board must be residents of low-income census tracts and be directly elected by residents. The Board must meet quarterly with the mayor and city council to provide insight and oversight of city policies through a fair housing lens.
Read Texas Housers and Texas Appleseed’s comments on the Houston Analysis of Impediments below:
Texas-Housers_Texas-Appleseed_2020-AI-Comment
