In 2018, the California Legislature passed Assembly Bill 686, which took aim at housing discrimination and also sought to turn HUD’s Affirmatively Furthering Fair Housing rule at the time into concrete policies and programs to remediate major disparities between racial groups as a result of systemic racism in housing policy. One part of the bill required municipalities in the state to add a Fair Housing Assessment as part of their Housing Element updates. The text reads:
“(9) (A) Affirmatively further fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2. The program shall include an assessment of fair housing in the jurisdiction that shall include all of the following components:
(i) A summary of fair housing issues in the jurisdiction and an assessment of the jurisdiction’s fair housing enforcement and fair housing outreach capacity.
(ii) An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs within the jurisdiction, including displacement risk.
(iii) An assessment of the contributing factors for the fair housing issues identified under clause (ii).
(iv) An identification of the jurisdiction’s fair housing priorities and goals, giving highest priority to those factors identified in clause (iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance, and identifying the metrics and milestones for determining what fair housing results will be achieved.
(v) Strategies and actions to implement those priorities and goals, which may include, but are not limited to, enhancing mobility strategies and encouraging development of new affordable housing in areas of opportunity, as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing, and protecting existing residents from displacement.”
– California Government Code Sec 2. Section 65583[1]
The second requirement, an analysis of data to identify segregation, poverty concentration, access to opportunity, and displacement risk, is a particularly tricky requirement. Since Housing Elements are reviewed by the state; municipalities will need to ensure that their assessments pass muster with the state.
To this end, the state has offered a shortcut of sorts. They have pointed agencies and local governments to the TCAC/HCD Opportunity Area Maps[2] as a way to start the analysis. In this post, I will lay out a critique of the maps, and provide general feedback on how these maps could be better improved to meet local needs as localities go about updating their Housing Element.
Let us start with a brief overview of the opportunity map. The map classifies either a census tract (In urban areas) or a block group (in rural areas) as either having the Highest Resource, High Resource, Moderate Resource (Rapidly Changing), Moderate Resource, Low Resource, or High Segregation & Poverty. These classifications are done using an calculated index score for the census tract or block group that compares its performance on 21 indicators among three domains (Economic, Environment, and Education) to other tracts and block groups in its region. For rural blockgroups, they are compared not to the region they fall into but to other rural blockgroups. The top 20% of tracts/blockgroups are categorized as having the Highest Resource, while the next 20% of tracts/blockgroups are high resource, and so on. Areas are noted as having more than 30% of the population below the federal poverty line and having more people of color relative to their region are labeled as areas of ‘High Segregation & Poverty’[3].
The final map, while extremely comprehensive and well presented, falls into the trap that many opportunity maps do of simply mapping wealth and race. As Ed Goetz notes, these opportunity maps do not necessarily frame policy well:
“The message that these maps convey is that communities of color and lower-income neighborhoods lack value, an idea we should have left behind years ago. This type of “opportunity mapping” is simply old-fashioned demographic mapping that tells us little about where opportunity resides. It is a way to make a map about race without calling it a map of race, and it is no innovation at all.”[4]
In looking at the map, we can see areas of high opportunity almost universally correlated with areas of wealth. In the Bay Area, we see Marin County, the Peninsula, and the wealthy East Bay suburbs labeled as areas of high resources. Similarly, we see the trend play out in the Los Angeles Region (Malibu, Santa Monica, Laguna Beach), and the other regions of California. While those areas do have wonderful amenities, thinking from a housing policy perspective, are these areas the place for housing?
It depends; and this is where the TCAC Opportunity map could be improved. Instead of trying to boil down this opportunity map into high resource areas and low resource areas; the map should try and provide more granularity. I have three recommendations to achieve this. First, retool the economic domain to drop home value and instead replace it with an access to secondary education and training programs. Second, add in a mobility domain which includes access to forms of public transit, walkability, and distance to employment centers. Finally, a map should instead reflect clusters of opportunity as opposed to a simple high opportunity/low opportunity binary.
Changes to Economic Domain
The first change would be to swap median home value with distance to secondary education institutions and training programs. First, median home value is not particularly useful from a policy perspective in getting affordable housing. Higher median home values, while an indicator of wealth building, would make these places difficult to provide homeowner assistance give their high cost. Furthermore, high home values would not have any relevance for rental housing.
Instead, the metric that could be used instead could be access to job related programs. These would be job training centers, community college apprenticeship programs, and special training programs. This fits into the economic domain because these programs are targeted at adults as opposed to children. From a housing perspective, rental and multifamily properties can be placed close to these programs because the individuals utilizing these programs are most likely young adults do not have large households.
Creating a Mobility Domain
The development of a mobility domain is important in thinking about access. Research has noted that increased mobility increases the likelihood of finding a job and allows individuals who cannot drive or do not have a car to move around the region[5]. Furthermore, mobility also connects to a reduction in greenhouse gases, which would reduce airborne pollutants, reducing the risk of respiratory disease.
Changing the Map to Show Opportunity Clusters
This change is perhaps the most important. Given that state law requires an analysis of opportunity, adding clusters of opportunity can help define housing policy. For example, in areas of high educational opportunity, it would make sense to work to provide affordable family housing (3-4 bedroom units) in those areas. Conversely, an area with high economic or mobility opportunity should have more multifamily units. A cluster map can drive housing policy more effectively.
Opportunity maps can be a useful tool and California’s opportunity map is a step in a positive direction in helping municipalities begin to drive granular conversations about housing policy. With some adjustments, I believe the map can be a more powerful tool for municipalities; providing context for what types of housing can work in various areas.
[1] “Bill Text – AB-686 Housing Discrimination: Affirmatively Further Fair Housing.,” October 1, 2018, https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB686.
[2] California Tax Credit Allocation Committee, “TCAC/HCD Opportunity Area Maps,” California State Treasurer, 2020, https://www.treasurer.ca.gov/ctcac/opportunity.asp.
[3] California Fair Housing Task Force, “Methodology for the 2020 TCAC/HCD Opportunity Map,” June 2020, https://www.treasurer.ca.gov/ctcac/opportunity/2020-tcac-hcd-methodology.pdf.
[4] Edward G. Goetz, “Your ‘Opportunity’ Map Is Broken. Here Are Some Fixes,” Shelterforce (blog), November 16, 2017, https://shelterforce.org/2017/11/16/your-opportunity-map-is-broken-here-are-some-fixes/.
[5] Lei Ding, Jackelyn Hwang, and Eileen Divringi, “Gentrification and Residential Mobility in Philadelphia,” Regional Science and Urban Economics 61 (November 2016): 38–51, https://doi.org/10.1016/j.regsciurbeco.2016.09.004; Paul Ong and Evelyn Blumenberg, “Job Access, Commute and Travel Burden among Welfare Recipients,” Urban Studies 35, no. 1 (January 1998): 77–93.