As a condition of receiving Community Development Block Grant (CDBG) funds, the Village must certify that it will take actions to affirmatively further fair housing.
In 2015, HUD published a new rule on affirmatively furthering fair housing that requires CDBG entitlement communities and public housing authorities to produce an Assessment of Fair Housing (AFH). The AFH is to include an assessment of the following:
- Patterns of integration and segregation;
- Racially or ethnically concentrated areas of poverty;
- Disparities in access to opportunity; and
- Disproportionate housing needs.
Program participants are then required to set goals to overcome fair housing issues and related contributing factors. Those goals must inform subsequent housing and community development planning processes.
HUD encourages local entities to collaborate on a regional AFH. Collaboration allows entitlements and public housing authorities (PHAs) to work more efficiently and effectively by producing a joint AFH.
Cook County includes 21 different entitlement communities and PHAs that are now required to produce an AFH. A proposed collaboration has been developed that would include entitlement communities, PHAs, civic organizations and the Chicago Metropolitan Agency for Planning (CMAP) for the purpose of producing a County-wide AFH that would satisfy the regulatory requirements for all of the participating entities. The due date for the regional AFH is January 5, 2020 which is the same date that a separate Arlington Heights AFH will be due to HUD if the Village does not participate in the regional AFH.
At this time, the following other communities and PHAs have indicated that they are interested in voluntarily participating in the regional AFH: Chicago, Cook County, Berwyn, Cicero, Des Plaines, Evanston, Hoffman Estates, Mount Prospect, Oak Lawn, Oak Park, Palatine, Schaumburg, Skokie, the Chicago Housing Authority, Housing Authority of Cook County, Cicero Housing Authority, Maywood Housing Authority, Oak Park Housing Authority and Park Forest Housing Authority. Other civic organizations will also be involved.
If the Village of Arlington Heights chooses to participate in the regional AFH process, the Village will be responsible for providing local data, holding public hearings as required by federal regulations, reviewing key recommendations prior to the final drafting of the plan, and formally approving the plan. All of these steps, and more, would be required if the Village produces its own AFH.
The cost to the Village of Arlington Heights to participate in the regional AFH process is $1,000 with $500 due in December 2017 and $500 due in December 2018. This expense is a CDBG-eligible administrative cost. After entering into the required agreements to join the collaboration, the Village may withdraw from the process upon providing 30 days’ notice. However, the $1,000 financial obligation would remain.
Cook County has agreed to be the lead entity that would submit the AFH to HUD. CMAP would provide extensive technical assistance, including coordination among the participating entities.
CMAP has reserved the right to withdraw from its role in the project if the core four organizations (City of Chicago, Chicago Housing Authority, Housing Authority of Cook County and Cook County) are unable to get the needed authority to participate by November 1.
Completing an AFH on its own could require 100+ Village staff hours, which would be a far greater expenditure of resources than the Village’s $1,000 share of the cost of the regional AFH.
RECOMMENDATION
It is recommended that the Village Board approve the Resolution Approving an Intergovernmental Memorandum of Understanding and an Intergovernmental Agreement and authorize the Village Manager to sign all documents with respect to the Village’s participation in the regional Assessment of Fair Housing collaboration being led by Cook County and the Chicago Metropolitan Agency for Planning.