Dear Marcia Fudge
Secretary of Housing and Urban Development
Housing discrimination exists today. It slides
under the radar in high cost, market scarcity, natural disaster, and racial
disparity. Housing is the American Dream.
The
disparate-impact standard endorsed by “Inclusive Communities” case applies to the
Fair Housing Act. Inclusive Communities held that claims based on third-party
policies limiting a defendant’s discretion and should be dismissed. HUD’s
disparate-impact regulation should parallel The Supreme Court precedent recodifying
the 2013 Rule is inconsistent with Inclusive Communities ruling. Granting funds
to developers to build low-income housing resulted in increasing “ghettos.”
Residential segregation and a racially
segmented housing markets hold back African Americans’ economic mobility. Housing
provides a method to pull out of poverty.
Segregation, disparate access to credit and
homeownership, and the consistent devaluation of homes in black neighborhoods6 combine to constrict the ability of African
Americans to build equity and accumulate wealth through homeownership.
Allow me to suggest the following:
1.
Local jurisdictions are responsible for
planning to achieve fair housing.
Furthering Fair Housing (AFFH) rule should be fully reinstated. Cities and
counties are directly on the line with needs and services of their communities.
2.
Empower
federal, state, and local governments and nonprofits to enforce the Fair
Housing Act. Marcia Fudge I ask you to
boost the U.S. Department of Housing and Urban Development’s (HUD) Office of
Fair Housing and Equal Opportunity (FHEO).
3.
HUD goal to the end racial steering by Real Estate agents,
Property Management companies, and rental agencies. Some Real Estate agents still
steer African Americans. Real estate agents are loosely organized by the
National Association of Realtors. NAR to maintain a public website registry of clients
by race, sex, national origin, age… to track discrimination. Revealing trends discourages
behaviors. Rental property agencies, websites, and aggregators to pay into a pool
of resources for this tracking.
4.
According to the Urban Institute’s 2012 audit study Housing
providers often do not advertise available units. There are no for rent signs
or online listings of many homes for rent or for sale. Social media and online
housing aggregators such as Zillow allow discriminatory digital marketing.50 A 2016 ProPublica investigation51 reveals Facebook’s practice of allowing its
advertisers to exclude Facebook users from seeing housing ads based on their
race and ethnicity. Those companies who profit from advertising real estate
should provide a portion low-income housing, i.e.: taxation.
5.
HUD to provide structures to build low-cost housing. After
the Covid pandemic Americans may not return to city or suburban homes and require
access to internet to work remote. USDA to offer a loan program that includes
$30000 towards the addition of: internet towers, roofing, or solar systems at
zero interest rate.
6.
Natural disasters: flood, tornado, hurricane, fire,
earthquakes… offer opportunities to rebuild safer, stronger, lower cost housing
alternatives. HUD in coordination with FEMA to reinvent methods for funds to
fairly disperse to people. Road Home Project’s disparate
distribution of grants ultimately failed Black Americans. How many
thousand Black Americans left New Orleans after Katrina for rural Mississippi,
Texas, other places ~ never to return to New Orleans? Now years later, be
great. Offer zero
interest loans to low-income families who were displaced by Hurricane Katrina
in the Lower Ninth Ward. Fast track permits for foundations which are eight
feet above ground level and allow for two- and three-story housing structures. Covid pandemic adds
to the list of dead malls. HUD and our
Federal Government can lead guidance as to the reuse of this land. Rehabilitate
dying retail malls into condominiums and low-cost housing in: Syracuse NY, Rochester
NY, Rockford IL, Peoria IL, Philadelphia PA, Erie PA, Los Angeles CA, San
Francisco CA, Portland OR, New Orleans LA, Detroit Areas IL, Chicago IL, Houston
TX… Review recent rehab mall projects: Medley/Irondequoit/Skyview
Mall Rochester NY was changed to community center. Is it being used? Should the city have knocked
down a couple of the larger retail structures and created five story senior low-income
condos, or built on the parking lot?
7. Provide available safe units for families who are homeless,
Veterans struggling on the streets, and the most vulnerable.
Divide housing programs into units for: a) elderly, b) homeless with mental disability, c) those who require drug rehabilitation, d) and low-income individuals who recently became homeless.
Housing should be dispersed into all neighborhoods and not restricted to traditional badlands thus becoming ghetto areas.
Density to be not concentrated in one block. Repurpose vacant housing.
The cost to retrofit plumbing for condo/housing from
retail is largest cost is plumbing. New plumbing retrofit to residential is about
$23000 for a two-bedroom one bath unit. With $190000 I can build a single-family
house of 1200 square feet not including lot or utility tie ins.
8.
Come up with plans to encourage the dot.com companies who gentrified
neighborhoods which displaced long term residents to build affordable housing
in those same backyards.
Housing product is needed. Be bold. Think
diverse. Ask for our help.
Caroline Gerardo Barbeau
San Juan Capistrano, California
https://www.americanprogress.org/issues/economy/reports/2019/07/15/469838/racial-disparities-home-appreciation/