EXECUTIVE SUMMARY of an Analysis of
Impediments to Housing Choice in North Shore Communities
prepared by Neighborhood Legal Services,
The North Shore HOME Consortium
commissioned the following Analysis of Impediments to Fair
Housing in North Shore HOME Consortium member communities.
The analysis was conducted and the report written by Neighborhood
Legal Services, Inc., a provider of free legal assistance,
including fair housing enforcement services, to residents of
Northeastern Massachusetts. The study is required by the U.S.
Department of Housing and Urban Development as part of the
Consortium's obligation to affirmatively further fair housing
in its activities as a recipient of federal HOME funds.
The analysis explores and identifies
conditions in the region that have the effect of restricting
housing choice for persons protected by state and federal fair
housing laws. Legal protection is afforded by these laws when
housing choice is restricted on the basis of race, color,
national origin, sex, religion, handicap and receipt of public
assistance. Both intentional discrimination and actions and
conditions that have the effect of limiting choice are prohibited
and so this analysis looks at all conditions in the region that
may effect housing choice whether or not the condition results
from any act or omission, intentional or otherwise. The analysis
includes both a summary of the demographic situation in the
region based on census and other data, a report on community
meetings held throughout the Consortium region to gather further
input for this report, and a section identifying potential
impediments and, for each, a range of possible responses to the
impediment identified. This draft report will be presented for
public comment and revised before final submission to the
Department of Housing and Urban Development.
DEMOGRAPHICS AND OTHER OBSERVATIONS
There does not seem to be any
significant disparity between member communities in terms
of their ability to house elders. This may result from
the creation of significant elder subsidized housing
opportunities in many smaller Consortium communities.
There is some disparity in the
relative concentrations of single parent households and
female headed households in Consortium communities with
smaller and wealthier communities housing smaller
percentages of these households but all Consortium
communities have some significant number of households of
There are very significant
distinctions between Consortium communities in terms of
minority concentration and these differences correlate
very closely with the size of the community and its
relative economic position in the region (as measured by
median household income and housing values in the
community). Some Consortium communities have virtually no
minority residents, more than half the communities in the
Consortium have minority populations of less than 3% of
their total population while neighboring non-consortium
communities have minority populations as high as 45%. As
a general matter, smaller and wealthier Consortium
communities have significantly smaller minority
concentrations (1-3% of total population) than do larger
more urbanized communities (3-7%) but even these
communities have minority populations significantly
smaller as a percentage of total population than do the
non-Consortium urban centers of Lynn and Lawrence (with
minority populations of 19% and 45% respectively). This
data suggests there are very strong barriers to minority
access to most Consortium communities.
The differences in relative
economic position of different racial and ethnic groups
in the region are very pronounced. More than 60% of
Hispanics, 46% of Native Americans and 38% of blacks have
household incomes that would qualify them as very low
income under HUD definitions. In contrast, only 24% of
whites and 25% of Asians have incomes that would place
them in this category.
For each racial group, nearly 80%
of all members of the groups are either very low income
of high income households. Depending on the race of the
group, the vast majority of this 80% is either high
(White and Asian households) or very low income (Black,
Hispanic and Native American households). There is a very
small middle income group in the region and so the income
disparities identified are very deep and very dramatic.
Income distribution patterns from
community to community show a relatively smooth
distribution from a low household median income of
$33,000 to a high of $53,000 with one notable exception,
Boxford, having a much higher income standard than any
other consortium community. Even $33,000 is much higher
however, than the median household income for Black,
Hispanics and Native American households in the region
and these figures suggest that mobility for racial
minorities will be difficult without economic support and
Subsidized housing patterns in the
region show that in many of the smaller consortium
communities there has been a significant commitment to
the creation of elder housing opportunities but a very
limited effort to create family public housing
opportunities. In the smaller Consortium communities,
less than one quarter of the subsidized housing
opportunities created have been designed to housing
families while, in the larger Consortium communities an
average of two thirds of all available units are family
units. These patterns contribute to the inability of
minority households to gain access to smaller Consortium
Three large MHFA housing
developments in the region have minority occupancy rates
that are significantly lower than the norm in the region.
The availability of subsidized
housing certificates and vouchers is very inconsistent
throughout the region. Smaller communities (those with
very limited minority populations) generally have access
to more certificates and vouchers on a per capita basis
than do larger communities. This fact could aid in
mobility efforts but for the fact that virtually all
these communities impose a resident preference for access
to these subsidies. With a resident preference imposed,
these unequal patterns of subsidy availability mean that
minorities have very limited access to the region's
pool of subsidy opportunities.
Median home values in the region
range from slightly less than $150,000 to more than
$300,000. Even at the low end of this range, home
ownership opportunities are largely beyond the economic
reach of most minority and single parent households and
these household will continue to rely on rental housing
opportunities to gain access to new communities.
The percentage of rental housing
varies dramatically in member communities with smaller
Consortium communities having much smaller percentages of
rental housing than larger communities in the region.
Distribution of disabled persons in
the region follows a pattern similar to race but not
quite as dramatic. Generally there are larger
concentrations of disabled individuals in larger
communities with lower housing costs and lower median
Minority and disabled households
are far more likely to rely on public transportation.
Approximately 40% of Black, Native American and Hispanic
Households do not have automobiles. Thus, public
transportation resources are critical to effective access
to member communities by minority and disabled
There are three basic
transportation systems in the region, one serving Cape
Ann, one serving the Merrimack Valley and one serving the
southern tier of the Consortium region and Greater
Boston. These systems serve isolated parts of the region
and do not create a regional system. The current
structure of the system fails to provide transportation
effectively to the communities in the region where job
and employment opportunities are growing - Danvers,
Peabody and Middleton.
Employment is the region is growing
very slowly and the region is experiencing a massive loss
of higher paying manufacturing jobs with these jobs
replaced by lower paying service positions. The vast
majority of new jobs are being created in the Middleton,
Peabody, Danvers area.
Home mortgage lending rates for
local banks serving Consortium communities should very
few applications by minorities and lower approvals rates
both for loan applications by minorities and loan
applications for properties in areas of minority
concentration. While the numbers were so small that these
findings are not statistically valid, lending practices
in the region should be carefully studied and there is a
clear need for affirmative marketing of lending
opportunities in minority communities.
Several large housing developments
in the region appear to place quotas on the number of
voucher or certificate holders they will accept. This
practice almost certainly violates Massachusetts law.
Many minority households that move
to smaller Consortium communities leave shortly after.
This may result from some level of hostility or
harassment experienced in the community, from lack of
access to needed services, friends and families because
of inadequate public transportation resources in the
community. There seems to be inadequate effort made by
housing search programs and other organizations placing
individuals in Consortium communities to help families
make a successful transition and anticipate and overcome
the barriers to a successful transition that they will
There is a general sense that while
specialized housing for the disabled has encountered some
opposition it has been sited throughout the region
without significant difficulty and has been relatively
well received when sited.
Recent changes in Massachusetts law
restricted access to some elder housing for the disabled,
creating a massive housing gap for disabled individuals.
The state's efforts to remedy this situation by the
distribution of vouchers to disabled individuals have
been hampered in the region by the failure of many
communities to accept the vouchers offered and the low
ceiling rent included in the voucher program legislation.
IMPEDIMENTS IDENTIFIED AND RESPONSES
Several Major housing developments
in the region seem to be imposing illegal quotas on
housing certificate holders.
- Consortium should
undertake a paired testing program to determine
the prevalence of this practice and notify fair
housing enforcement officials of this finding.
Racial steering seems to have
occurred in some Consortium areas.
- Consortium should
undertake a paired testing program to determine
how widespread this practice is.
The use of local preferences for
public and subsidized housing opportunities disadvantage
minorities and may be illegal when imposed in communities
with small minority populations.
- Local communities should
consider eliminating local preferences.
- Local communities should
consider creating additional needs based
preferences that limit the exclusionary effect of
- Consideration should be
given to regionalizing the public and subsidized
housing waiting list system for Consortium
The use of working family
preferences for subsidized housing eligibility
disadvantage disabled individuals and their families.
- Communities should
consider eliminating working family preferences,
or include a special exception for families with
Lack of public transportation
renders it difficult or impossible for some minority
families to access smaller Consortium communities and to
access jobs, social services, and maintain contact with
family and friends from within many Consortium
- Transportation systems in
the region should coordinate their operations and
create a true regional system
- Small communities within
the Consortium should join their regional system.
Too many have opted out of systems available to
- New route structures
should be developed to link residential areas
with employment centers in the region on a
regional basis. Current systems largely ignore
the regional employment centers and do not
adequately serve them.
Minority families that move to
smaller Consortium communities are inadequately prepared
by housing search and shelter programs to make the move
- Shelters and housing
search programs should offer more information to
consumers about the communities where they are
applying for housing
- Housing counseling
services should be provided to help families
develop an awareness of the challenges they will
face in smaller, more isolated communities and
develop strategies to make the transition
- Local communities should
develop a more proactive approach to welcoming
newcomers and assist them to transition
Minorities moving to smaller
Consortium communities do experience some level of
hostility or, at best, benign neglect and are not
- Communities can create
Diversity and Fair Housing Committees to address
these issues directly.
- Public officials should
take a leadership role in modeling openness to
new residents through fair housing proclamations,
public statements and other demonstrations of
support for open housing.
- Consumers should receive
information about fair housing rights and
obligations so that they can identify
discrimination and report it to appropriate
Housing opportunities frequently
pass in smaller communities by word of mouth and are
never made available to a larger regional population.
- Housing locator services
can be established to search out housing
opportunities in Consortium communities and then
match them with consumers interesting in moving
to areas of lower minority concentration. These
services can include incentives to landlords and
sellers to list properties with the services and
formal affiliations with lenders to facilitate
Housing costs in many Consortium
communities are prohibitive for most minority households
and prevent mobility.
- Communities in the
Consortium region should work together to expand
affordable housing opportunities, particularly in
areas with small minority populations. To this
end, local communities may wish to consider
developing a regional compact in which all area
communities work together to establish and meet
regional and community by community housing
- Communities can use a
variety of means to promote affordable housing
development including land use policy changes,
donations of public property, support for
non-equity or limited equity ownership structures
and acceptance of subsidy opportunities that are
presented to the community.
Some evidence exists that mortgage
lending patterns disadvantage minorities and housing in
areas of minority concentration.
- The Consortium should
continue to monitor lending practices and seek
commitments by local and regional banks to
improve their current marketing efforts in
minority neighborhoods and communities.
Disabled individuals have lost
access to many of the housing opportunities available to
them through changes in Massachusetts law capping
disabled access to subsidized elderly housing.
- Communities should accept
the Alternative Housing Vouchers offered by the
state to offset the loss of this housing
opportunity for the disabled.
- The Consortium should ask
legislators to reconsider the rent structure used
in the Alternative Housing Voucher program that
caps unit rents at levels well below the norm for
Lead paint in local housing units
creates a major access barrier for families with
- Provide consumer
education about the illegality of failing to rent
to families with children even when to rent to
them will require deleading a unit.
- Prevail upon policy
makers to extend financing programs for lead
abatement to include larger properties and
investor owned properties not currently eligible
for most financing programs.
Current administrative systems used
in the region to take applications for public and
subsidized housing in member communities frequently
disadvantage disabled individuals and non-residents.
- Advertise all application
processes well in advance and on a region wide
- Accept applications by
mail as well as in person.
- Avoid first come, first
served systems in favor of lottery systems.
- Keep applications open
for at least several weeks whenever they are
- Regionalize the system as
FUTURE ACTIONS - The report recommends the
following as priority actions:
1. Convening a regional conference on fair
housing and affordable housing to have communities meet and
jointly develop goals and timetables for development of
affordable housing opportunities and elimination of open housing
2. Conducting testing of real estate
practices in the region to explore the prevalence of racial
steering and public assistance discrimination and race
discrimination identified during this study.
3. Developing a regional housing mobility
program to provide housing locator, housing counseling, consumer
education and loan origination services to area minority and
lower income families.
4. Convening a regional transportation
conference to consider the matters raised in this report and to
foster better cooperation and coordination among the region's
5. Regionalizing public and subsidized
housing waiting lists and admissions decisions and eliminate
local preferences for public and subsidized housing eligibility.
NOTE: a copy of the full report (90pp.) is available for a
donation of $25.00 to Neighborhood Legal Services. Send request
for a report copy and a check payable to Neighborhood Legal
Services, to Diana Mazola, Neighborhood Legal Services, Inc., 37
Friend Street, Lynn, MA 01902.