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Allocating lower-income housing

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Title:
Allocating lower-income housing an analysis of fair-share housing allocation planning
Alternate title:
Fair-share housing allocation planning
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Young, Louise Monroe
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English
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223 leaves : charts, maps ; 28 cm

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Subjects / Keywords:
Public housing -- United States ( lcsh )
Housing policy -- United States ( lcsh )
Housing policy ( fast )
Public housing ( fast )
United States ( fast )
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bibliography ( marcgt )
theses ( marcgt )
non-fiction ( marcgt )

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Bibliography:
Includes bibliographical references.
General Note:
Submitted in partial fulfillment of the requirements for a Master's degree in Planning and Community Development, College of Design and Planning.
Statement of Responsibility:
by Louise Monroe Young.

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University of Colorado Denver
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Auraria Library
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All applicable rights reserved by the source institution and holding location.
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09860458 ( OCLC )
ocm09860458
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LD1190 .Y75 ( lcc )

Full Text
ALLOCATING LOWER INCOME HOUSING: AN ANALYSIS OF FAIR-SHARE HOUSING ALLOCATION PLANNING


ALLOCATING LOWER-INCOME HOUSING:
AN ANALYSIS OF FAIR-SHARE HOUSING ALLOCATION PLANNING by
Louise Monroe Young B.A., Whitworth College, 1972
A thesis submitted to the Faculty of the Graduate School of the University of Colorado in partial fulfillment of the requirements for the degree of Master in Planning and Community Development The College of Design and Planning
1983
. ***<
i All :


CONTENTS
CHAPTER PAGE
I. INTRODUCTION ................................. 1
II. BACKGROUND AND DESCRIPTION OF HOUSING
ALLOCATION PLANS .......................... 10
Regionalism in Land Use and Housing 12
III. ELEMENTS OF THE HOUSING ALLOCATION PLAN 26
Allocation Criteria and Factors ... 44
Allocation Strategies ..................... 55
Implementation Strategy and Allocation
Refinement .............................. 59
IV. CASE STUDY DESCRIPTIONS AND IMPACTS 68
Miami Valley Region, Dayton, Ohio
Numerical Approach ...................... 68
Impact of the Dayton Plan........... 7 8
Twin Cities Region, Minneapolis-St. Paul
MinnesotaPriority Approach .... 82
Impact of the Twin Cities Plan ... 85
San Bernardino County, California
Combined Approach ....................... 92
Impact of the San Bernardino County
Plan.................................. 103
V. BASIC STANDARDS FOR HOUSING ALLOCATION
PLANS..................................... 110
Allocation Criteria of Housing Allocation Plans..................................... 110
Distribution Criteria .................. Ill
Equal Share Criteria.................... 113


Suitability Criteria..................... 116?
Need Criteria............................. 117
Practical Standards .................... 120
Political Feasibility .................... 120
Economic Feasibility ..................... 123
VI. THE DAYTON PLAN............................... 127
Evaluation According to Allocation
Criteria.................................. 127
Evaluation According to Political and
Economic Feasibility ..................... 135
Analysis of the Impact of the Dayton Plan 139
VII. THE MINNEAPOLIS-ST. PAUL PLAN............. 145
Evaluation According to Allocation Criteria ...................................... 145
Evaluation According to Political and
Economic Feasibility ..................... 156
Analysis of the Impact of the Twin Cities
Plan...................................... 161
VIII. THE SAN BERNARDINO COUNTY PLAN................ 170
Evaluation According to Allocation Criteria ...................................... 170
Evaluation According to Political and
Economic Feasibility ..................... 179
Analysis of the Impact of the San Bernardino Plan................................... 182
IX. THE FUTURE OF FAIR SHARE AND RECOMMENDATIONS ............................................. 189
SELECTED BIBLIOGRAPHY ................................ 220


LIST OF TABLES
TABLE PAGE
1. ANATOMY OF FAIR SHARE..................... 27
2. SELECTED CHARACTERISTICS OF ALLOCATION PLANS ...................................
3. TYPES OF HOUSING DISTRIBUTED BY FAIR
SHARE PLANS................................ 39
4. EXAMPLE OF ALLOCATION CRITERIA AND
FACTORS.................................... 45
5. MIAMI VALLEY HOUSING NEEDS BY COUNTY 1970 72
6. LOCATION OF DAYTON REGION SUBSIDIZED
UNITS: 1970 and 1982 .................... 81
7. CUMULATIVE TOTALS OF SUBSIDIZED HOUSING
1971-1981, MINNEAPOLIS-ST. PAUL, MINNESOTA 87
8. CRITERIA OF THE MINI-MODEL, SAN BERNARDINO
COUNTY, CALIFORNIA........................... 99
9. NUMBER OF SUBSIDIZED UNITS PER 1,000 POPULATION IN 1970 AND 1980, DAYTON,
MINNEAPOLIS-ST. PAUL, AND SAN BERNARDINO COUNTY ..................................... 212


LIST OF FIGURES
FIGURE PAGE
1. HOUSING DISTRIBUTION CONSIDERATIONS ... 46
2. PLANNING UNIT BOUNDARIES FOR THE MVRPC
HOUSING PLAN 1973 ......................... 71
3. SUBSIDIZED HOUSING ALLOCATION PLAN:
PRIORITY AREAS, TWIN CITIES METROPOLITAN AREA................................... 8 3
4. DISTRIBUTION OF NEW HOUSING UNITS,
1977-1987, TWIN CITIES METROPOLITAN
AREA....................................... 86
5. COMMUNITIES WITH SUBSIDIZED HOUSING IN
1971, TWIN CITIES METROPOLITAN AREA 89
6. COMMUNITIES WITH SUBSIDIZED HOUSING IN
1981, TWIN CITIES METROPOLITAN AREA 90
7. VALLEY PLANNING DISTRICT, SAN BERNARDINO
COUNTY, CALIFORNIA ........................ 95
8. THEORETICAL PLANNING DISTRICT, SAN BERNARDINO
COUNTY, CALIFORNIA ........................ 98
9. FAIR SHARE HOUSING ALLOCATION .............. 209


CHAPTER I
INTRODUCTION
Almost all countries, rich and poor, have a housing problem. The United States is no exception. The nation initially failed to fulfill the much quoted pledge of the Housing Act of 1949 to provide a decent home and suitable living environment to all Americans. Millions continued to live in housing units officially classified as dilapidated, deteriorating or overcrowded; many others were adequately housed only because they spent a burdensome portion of family income on shelter. America has suffered from and continues to suffer from what has been called a "bad housing" and a "too little housing" problem.
There is a great lack of affordable housing and decent, suitable living units for low-income persons in the United States. Anthony Downs, in his book,
Urban Problems and Prospects, suggests that the quantity of new housing built should be greatly increased. Downs states that the first key objective in solving the housing problem is "building much more new housing each year than in the recent past and subsidizing much of it so as to improve housing conditions among the poorest and most ill-housed citizens."'*'


2
Large numbers of housing units for such groups of people cannot be built within central cities because there is not enough vacant land. Housing choice can be widened by opening the suburbs to low-income housing. The majority of new job opportunities are being offered in suburban areas. Transportation is too costly for low-income persons to commute to the suburbs. Therefore, it makes sense to build housing for low- and moderate income households in suburban areas.
If white and black population growth continues in the next twenty years the way it has, two separate societies will be created. A low-income, largely minority population will exist who perceive that a significant gap remains between themselves and others in society who are no more deserving than they. This could become a powerful source of tension that might lead to violence.
The housing situation of low-income households has become worse in the past few years because of a drop in the number of total new housing units started in .the United States. This reduction in new housing starts occurred because of high interest rates in the economy, rather than any reduction in the demand for new housing.
In fact, the demand for housing has been stimulated by high-level prosperity. The resulting combination of rising demand and restricted additions to supply


3
has created a very tight housing market in most metropolitan areas. This has caused declining vacancy and an upward pressure on rents at all levels of the market. Consequently, the filtering process has recently become a less efficient method of making new housing units available to low-income households.2
Anthony Downs, in his book Urban Problems and Prospects, estimates that "in 1970, there were ten to twelve million households that were considered inadequate or about one out of every six or seven households in the United States were considered inadequate."^ To solve the housing problems, Downs states that "the nation must not only replace all inadequate housing but must also provide enough new or rehabilitated units to accommodate future population growth and to replace units that will be demolished."^
There are numerous problems associated with opening up the suburbs. Any influx of low-income households with children tends to add a net burden to local property taxes. Second, Americans who have "made it" into the middle class have traditionally sought to demonstrate their success by segregating themselves from those less affluent. The third exclusionary motive is anti-black sentiment which is still strong among many whites. Prosperous households have strong arguments against opening up their neighborhoods to unrestricted entry by low-income households. They have observed the destructive environments in


4
concentrated poverty areas and they do not want such conditions where they live.
Allocation plans have arisen out of court decisions to provide low-income housing in suburban areas. However, many suburbanites are fighting against public policy they describe as an effort to rid the cities' ghettos at their expense. The lack of housing opportunities for low- and moderate income households in suburban areas and the adverse racial, social and economic effects of the overconcentration of lower-income housing in the cities provided the impetus behind the notion that providing lower-income housing should be the responsibility of all communities.^ However, it has not been the need for housing alone that has produced an interest in housing allocation plans. Many lower-income households began to demand greater housing opportunities. These households wanted the choice of living in an environment of their own choosing, even if that location be a suburb presently without suitable housing. Also, the shift of lower-income jobs from the cities to suburban areas placed the burden of commuting on lower-income workers.
The "Fair Share" Plan was a new idea in regional planning that made its debut in the United States in 1970 with the filing of the Miami Valley (Ohio) Regional Planning Commission Report. By definition, a fair share


5
plan distributes housing, usually low- and moderate-income housing needs, to governmental jurisdictions within a region in a manner such that all areas share in the responsibility of providing decent housing for the region's residents.
Around the mid-1970s, "fair-share" plans were renamed "housing allocation" models. Economic Consultants Organization, Inc., a private planning firm that has produced a technical report on housing allocation, speculates that the change in nomenclature may be due to the difference in the impact between the two terms. "Fair share" implies that the model is attempting to make fair a situation which has been "unfair." This negative connotation would tend to immediately put the supposed perpetrators of unfairness on the defensive and, thus, create friction from the beginning. On the other hand, the term "housing allocation" seems a relatively neutral one.^ Yet, whether the model is "fair share" or housing allocation, the concept is similar.
The effort is to distribute a given range and type of housing in some manner in accordance with certain goals.
The primary objective of housing allocation plans is usually to broaden the opportunity for low-income and minority persons to live in suburban areas and to reduce the concentration of subsidized housing in the center cities. The plans typically allocate to


6
a community its share of subsidized housing within a region or state based on a formula that incorporates factors such as number of low-income families in need; employment; present and expected growth; fiscal capacity; vacant land; available services; and, existing subsidized or low-cost housing.
While the concept of fair-share planning is relatively simple, the political process of adopting and implementing such plans is not. Many states and regional planning agencies have been reluctant to deal with the sensitive issue of low-income housing in the suburbs, even in a general way. This study will analyze housing allocation planning or fair-share planning the concept, methodologies and the effectiveness of various allocation plans. In doing this, it shall determine to what extent housing allocation plans are a successful tool in distributing low- and moderate income housing. Chapter I will provide an outline for the thesis.
The objectives of this report are:
To explain the need and reasons for developing housing allocation plans. Chapter I will discuss the problem of lack of housing opportunities for low- and moderate-income persons, introduce the concept of housing allocation planning and outline the objectives and scope of the report.


7
To describe what housing allocation plans are, their background and how they work. Chapter II will include a description of housing allocation plans. Chapter III will explain methodologies, what allocation plans are and what they try to do and describe elements of
a housing allocation plan.
To report the impacts of various housing allocation plans. Chapter IV will use the case study approach to describe the fair-share experience in various regions.
To establish criteria for evaluating housing allocation plans. Chapter V will determine standards to assess the effectiveness of housing allocation plans.
To evaluate the effectiveness of housing allocation plans as a tool for distributing low-and moderate income housing. The criteria established in Chapter V shall be used in Chapters VI, VII, and VIII to assess the effectiveness of allocation plans.
To discuss the future of fair share and propose recommendations.
The scope of this report is to analyze housing allocation plans and evaluate the effectiveness of these plans. A housing allocation plan is one method or


8
strategy for addressing the problem of lack of adequate housing for low-income persons.
The patterns of metropolitan economic segregation are deeply entrenched in America. Many factors contribute to economic segregation. Among these are poverty and racism. This report will discuss problems such as poverty and racism which are related to the provision of low-income housing in America, but the intent of the study is to analyze housing allocation plans and their effectiveness as a tool to provide and disperse low-income housing. Fair-share topics such as definitions of a region and methods of projecting housing need will be presented in an overview rather than a detailed explanation, which is beyond the scope of this report.


9
NOTESCHAPTER I
^Anthony Downs, Urban Problems and Prospects (Chicago: Markham Publishing Co., 1970), p. 17.
Ibid., P- 206.
Ibid., P- 118.
lb id.
Economic Consultants Organization, Inc., for the Southern Tier Central Regional Planning and Development Board, Housing Allocation: Criteria and Strategies (Buffalo, New York, September 1974), p. T.
^Ibid. p. 1.


CHAPTER II
BACKGROUND AND DESCRIPTION OF HOUSING ALLOCATION PLANS
Fair-share plans have been defined in many ways.
A leading authority, Mary Brooks, defined the allocation plan as "a means for outlining the dispersal policies for the future development of low-income units.Leonard Rubinowitz has written extensively on housing choice for low- and moderate-income people and racial minorities within metropolitan areas. Rubinowitz sees fair share as
a strategy to provide for distribution of lower-income housing within an entire metropolitan region in a way that is equitable to the recipient communities while providing potential occupants with wide geographical choice, as well as access to the full range of community services and facilities.
David Listokin, another important author on housing policy in the United States, defines fair share as
a plan which typically determines where housing, especially low- and moderate income units, should be built within a region according to such criteria as placing housing where it will expand housing opportunity, where it is most needed, and where it is most suitable.3
Although housing allocation plans differ significantly, they have certain features in common. They seek to facilitate development of housing on a rational


11
basis throughout an area rather than continuing concentration in the central city. They usually identify criteria for locating the new housing. The criteria generally attempt to increase the housing choices of potential occupants and consider the needs and capacities of local commnities involved. The plans either quantify the amount of housing desired for specific localities or designate priority areas to receive the needed housing. Generally, allocation plans propose a distribution of housing development within fairly large sub-areas of the region but do not identify specific sites for lower-income housing. This avoids encountering any political problems involved in selecting sites at early planning stages.
The lower-income housing allocation plan outlines priorities or responsibilities for certain jurisdictions regarding the development of lower-income housing. It is based on the assumption that if lower-income housing development is left to the market place it will not develop in very desirable ways (as history indicates), and thus its favorable development depends upon conscious planning efforts.
Fair-share plans distribute housing shares to allocation sub-areas, usually communities, located within a designated region. They specify a new allocation, whereas a regional housing plan may project the continuation of the present status quo for housing


12
activity. Implicit in most fair-share efforts is a dissatisfaction with the current housing distribution; fair-share strategy is an attempt to improve this allocation. Fair-share strategies usually have a number of objectives, but a primary emphasis of fair share is expanding housing opportunity, usually, but not exclusively for low- and moderate income families. Fair-share plans are usually but not always adopted by a public agency or a group associated with a public entity such as a citizens' advisory group to a regional planning body.
Regionalism in Land Use and Housing
According to David Listokin,
fair shares roots are in planning theory and outlook, especially the advocacy for regionalism. The strategy has been stimulated by the movement to open up the suburbs. It is part of a larger movement to reform land use controls. Regional allocation is viewed by its advocates as a rational-equitable strategy of distributing housing production within a region. It is especially for the benefit of low- and moderate-income families and considers a number of factors and criteria such as local need and suitability, and the local obligation to provide housing.4
As a rational equitable approach, it is designed to achieve social change (open the suburbs), and it personifies planning which has been defined variously as "a general strategy for urban social change," "a slightly rational managing of social change," and "an attempt at rationally calculated action to achieve a plan or goal.


13
The fair-share strategy is closely tied to regional planning. A regional approach to housing and land use dates from the origins of modern planning. Early planners, such as Lewis Mumford, describe the benefits of regionalism as follows:
Regional planning asks not how wide an area can be brought under the aegis of the metropolis, but how the population and civic facilities can be distributed so as to promote and stimulate a vivid, creative life throughout the whole region, a region being any geographic area that possesses a certain unity of climate, soil, vegetation, industry, and culture.
The regionalist attempts to plan such an area so that all its sites and resources, from forest to city, from highland to water level, may be soundly developed, and so that the population will be distributed so as to utilize, rather than to nullify or destroy its natural advantages. It sees people, industry, and the land as a single unit.6
Although regional planning has long been advocated by planners and land-use experts, serious interest in it has only occurred in the last decade. Since 1970, Councils of Governments (COGs) have been established out of the growing popularity of regional planning.
In most states, however, local planning still predominates. Because COGs are voluntary intergovernmental bodies, they often lack any real power and do not succeed in altering the status quo. The Denver Metropolitan region saw the need to form a COG to deal with common problems that were multijurisdictional, such as housing. One of the accomplishments of the Denver Regional Council of Governments (DRCOG) was producing a housing allocation plan for the Denver-metro region.


14
The concept of fair-share housing allocation was developed in the early 1970s. During the mid-1970s, there was a renewed emphasis on regional housing allocation planning from the courts, from Congress and from the U.S. Department of Housing and Urban Development (HUD). New mandates for regional housing plans have emerged from several key court decisions. Decisions such as Hartford, Connecticut, Mount Laurel and Middlesex, New Jersey and Chicago have started a legal foundation for regional approaches to housing. These decisions have supported the idea that low-income housing is a regional responsibility and should not be the burden of a single community.
Trudy McFall writes in an article entitled "Housing Allocation Plans," published in the Journal of Housing, that
The legal decisions appear to have provided the stimulus for a federal policy of increased support for regional housing plans and programs. In 1976,
HUD began a program of providing "bonus" housing subsidy, planning, and community development funds to regions with allocation plans. This program is known as the "housing opportunities plan." In a national competition, plans were submitted and HUD selected seven areas for bonus funds. This program provided, for the first time, some clearly positive incentives for regions to tackle the political rigors of fair share planning.'
Other actions have provided additional support for regional housing planning. In 1974, Congress stipulated that to receive continued Section 701 comprehensive
planning assistance funds after August 1977, all state,


15
metropolitan, and local grantees must have a plan for the distribution of subsidized housing funds. The HUD requirements were aimed, among other things, at the adoption of plans and programs that broaden housing choice for the disadvantaged outside the existing areas of concentration.
In late 1968, the President directed the Office of Management and Budget (OMB) to establish review
g
procedures, and in 1969, OMB issued Circular A-95 in an effort to guide the review required by Section 204 of the Demonstration Cities Act, Title IV of the Intergovernmental Cooperation Act, and other legislation. The Circular called for the designation of multijurisdic-tional bodies called "clearinghouses." State, regional and metropolitan clearinghouses were to be established.
These multijurisdictional bodies were to consider and comment on how local applications for federal aid related to and harmonized with statewide or areawide comprehensive plans submitted to executive agencies.
The clearinghouses were also to consider such matters as the extent to which proposals duplicated or ran counter to other projects or other activities, and the environmental impact of the proposal. A negative comment by a clearinghouse did not automatically invalidate the grant proposal; however, it usually hindered its acceptance.


16
The A-95 review process has had numerous difficulties. The criteria for reviewing applications have been vague and some clearinghouses have only gone through the motions of the review and comment procedure. Moreover, some federal agencies were ambiguous concerning their incorporation of clearinghouse comments or failed to accord these comments proper consideration.9
Despite A-95's drawbacks, it has an influence on regional allocation. David Listokin states that
it institutionalized the regional planning orientation which is a basic theme underlying fair shares' intellectual perspective. Additionally, under A-95 guidelines, the clearinghouses which often formulated the fair share plans gained the power to put their allocation strategy in force.
To summarize, several developments pushed the fair-share plan beyond a paper concept. One was the growth of regional planning. During the '60s, the rapid spread and increased sophistication of metropolitan regional planning facilitated the emergence of housing allocation planning. Regional planners were more concerned than local planners with projecting population and planning for its distribution and the rational incorporation of growth areas into the overall metropolitan area. Experience had prepared regional planners to respond to the challenge of applying planning methodology to housing unit allocation because it centered on achieving a balance between central city and outer communities.
A second factor behind the spread of fair-share plans was federal government involvement. During the 1960s, the nation was confronted with its historic and


17
unsolved problems of race and poverty. The Federal Government declared a "war on poverty" and adopted far-reaching civil rights laws affecting employment, education and housing. The U.S. Secretary of the Department of Housing and Urban Development was directed by Title VIII of the Civil Rights Act of 1968 to take affirmative action to end discrimination in housing, later to be interpreted by federal courts as a ban upon use of federal funds to build housing where it extends or perpetuates racial concentration. Shannon v. HUD,
436 F.2d 809 (3rd Cir. 1970). In addition to HUD backing of allocation models, court decisions ordered the development of a housing plan.
Although growing support for regional planning strengthened the fair-share approach, it was the movement to open up the suburbs to low- and moderate income families that provided the major impetus for housing allocation strategies. Ernest Erber, in his article "Metropolitan Housing Allocation Planning, describes in detail the sharp contrast between the inner city and the affluent suburb:
By the end of the 1950s, large developments of tract houses for average income families typified by Levittown, were rapidly becoming the exception.
By the end of the 1960s, zoning had made them all but impossible. Builders found the market for one-family homes shrinking to those in the upper levels of the income pyramid. Those prices out of the one-family market stimulated demand for rental units. However, since sururban towns of major


18
metropolitan areas resisted rezoning for apartments, housing starts declined to historic lows.
The slack was taken up in 1970-72 with a spectacular increase in subsidized construction, mainly pursuant to Section 236 of the 1968 Housing Act. These units were concentrated in central cities because suburban jurisdictions resisted rezoning land to accommodate households of low- or moderate-income. Meanwhile, studies by the National Committee Against Discrimination in Housing, Inc. (NCDH) and others had documented the incomparable, greater growth of job opportunities in the suburbs compared to the central city, especially jobs that matched the predominant skills of the social groups for whom subsidized housing was intended. The growing separation of population by income, reflected in concentration by race, and the consequent distortion of home/job relationships gave impetus in 1970 to studies of possible solutions designed to allocate subsidized housing to suburban locations.
The metropolitan transformation during the fifties and sixties which replaced the traditional symbiotic relationship of central cities to their suburban peripheries with a new type of human settlement pattern, was characterized by low-density spread of residential, commercial, and industrial uses sustained by highway-borne, motorized transportation. The new outer city (mislabeled suburbia) acted as a magnet upon the central city's middle- and higher-income households, and upon much of its economic base, leaving behind poverty, blight, and fiscal debility, all accentuated by growing minority racial concentration. The location of subsidized housing for low- and moderate income families mainly in the inner city had the effect of hastening and perpetuating the socio-economic cleavage between the central city and the new urbanization beyond its borders. The racial consequences were unmistakable. It became increasingly clear that the trend was toward central cities that would be poor, black, and bankrupt, surrounded by new forms of urban settlement that would be relatively affluent, white, and fiscally viable.
Planning which sought to reverse this trend had to overcome the resistance for outlying communities, whose citizens were intent upon protecting their perceived advantages against dilution expected to ensue from an influx of households of lower incomes and different ethnicity. This resistance was to be mollified by "sharing the burden;" each suburban municipality would accept its "fair share" of the poor--an ostensibly, the black.1!


19
Many fair-share plans stress the need to expand suburban housing opportunities to those poor and minority families currently confined to central cities. The Denver Regional Council of Governments (DRCOG), for example, stated that
the objective of the housing allocation model is to provide maximum opportunities for each resident in the region, particularly those of low- and moderate income in obtaining adequate and appropriate housing in a location of their choice.I"
Similar statements concerning the need to expand minority
and low- and moderate-income housing opportunities can
be found in almost all of the fair-share plans. To
understand fair-share allocation, one has to understand
the controversy surrounding exclusionary zoning and the
court's reaction to such land use.
Norman Williams describes exclusionary zoning
as those land use controls "which appear to interfere
seriously with the availability of low and moderate cost
13
housing where it is needed." Laurence Sager defines exclusionary zoning as "zoning that raises the price of residential access to a particular area and thereby
14
denies this access to members of low-income groups."
There are many types of exclusionary land use controls,'*'0 including such restrictive devices as minimum lot size requirements, minimum building size requirements, prohibition of multifamily dwellings and various building
code provisions.1^ Floating zoning is another exclu-
17
sionary zoning strategy.


20
The courts have proved a significant force in the movement to open up the suburbs and they have also played a major role in supporting allocation strategies. Numerous courts have prohibited the use of federal subsidies for expenditures and housing that increases or perpetuates racial concentration. The Gatreaux v.
Chicago Housing Authority decision, for example, condemned
18
public housing policies fostering high minority occupany.
The court directed the Chicago Housing Authority to construct integrated housing projects according to a prescribed ratio and timetable. This decision led the Chicago Housing Authority to consider allocation strategies.
New Jersey's Mount Laurel decision provides one of the clearest examples of court condemnation of exclusionary zoning coupled with a call for municipalities to provide their share of a region's needed housing.
One zoning expert has termed the case the most significant 19
since Euclid, while another described it as one of
the "most significant state court decisions regarding
2 0
exclusionary land use litigation."
Mount Laurel is a large, rapidly developing township located near booming Cherry Hill, New Jersey, approximately twenty miles from the cities of Camden and Philadelphia. Mount Laurel's population doubled from 1950 to 1960 and doubled again from 1960 to 1970.
The community's growth has been spurred by the construction of nearby highways such as the New Jersey Turnpike


21
and 1-295, and population migration from Camden and other southern New Jersey urban areas.
Like many other communities experiencing rapid growth, Mount Laurel revised its zoning ordinances, increasing minimum lot sizes and designating large portions of its undeveloped acreage for industrial use. The changes were, in part, motivated by a desire to stabilize property taxes. The newly-restrictive zoning was challenged by a group of plaintiffs who charged that the township limited housing construction for low- and moderate income families. The trial court agreed with these charges, declared Mount Laurel's zoning unconstitutional, and ordered the township to meet its obligation for providing low- and moderate-income housing. The State Supreme Court reviewed this lower court's decision and also declared Mount Laurel's restrictive zoning unconstitutional, reasoning that zoning as an exercise of the police power must be directed to satisfying the general welfare, not only the local general welfare but the regional welfare
i i 21
as well.
Mount Laurel has a significant relationship to fair share strategies on both an implicit and explicit level. That decision echoes the fair share perspective; it stresses the regional aspect of housing allocation, affirming that zoning should no longer have solely a local orientation but must consider broader needs and forces.22
In addition, Mount Laurel explicitly argued that communities must provide their appropriate or fair


22
share of the regional housing need determined by applying the techniques and projections of the fair-share approach:
We conclude that every municipality must by its land use regulations, presumptively make realistically possible an appropriate variety and choice of housing. More specifically, presumptively, it cannot foreclose the opportunity of the classes of people mentioned for low- and moderate income housing and in its regulations must affirmatively afford that opportunity at least to the extent of the municipality's fair share of the present and prospective need therefor.23
The concept of fair share is coming into more general use through the expertise of the municipal planning advisor, the county planning boards and the state planning agency, a reasonable figure for Mount Laurel can be determined, which can then be translated into the allocation of sufficient land therefor on the zoning map.24
To summarize, there were four developments that facilitated the emergence and spread of fair-share plans.
One important element was the rapid growth and increased sophistication of metropolitan regional planning, a basic theme underlying fair share. A second factor behind the spread of fair share plans was federal government involvement. Title VIII of the Civil Rights Act of 1968 directed HUD to take affirmative action to end discrimination in housing, later to be interpreted by federal courts as a ban upon use of federal funds to build housing where it extends or perpetuates racial concentration. In addition to HUD backing of allocation models, court decisions ordered the development of a housing plan. Numerous court cases have prohibited the use of federal


23
subsidies for expenditures and housing that increases or perpetuates racial concentration.
The above-mentioned developments strengthened the fair share approach but it was the movement to open up the suburbs to low- and moderate-income families that provided the major impetus for housing allocation strategies. Planners and local interest groups have sought to remove the sharp contrast between housing opportunities in the inner city and the affluent suburb by using fair share housing strategy. The courts have proved a significant force in the movement to open up the suburbs and it has been this force that has played a major role in supporting housing allocation strategies.


24
NOTESCHAPTER II
^Mary E. Brooks, Lower Income Housing: The Planner's Response (Chicago"! American Society of Plan-ning Officials, Planning Advisory Service, 1972), p. 11.
2
Leonard E. Rubinowitz, Low Income Housing: Suburban Strategies (Cambridge, Mass.: Ballinger Publishing Co. 1974), p. 66.
"^David Listokin, Fair Share Housing Allocation (New Brunswick, New Jersey! The Center for Urban Policy Research, Rutgers University, 1976), p. 1.
^lb id., p. 3.
^H. Wentworth Eldredge, "Planning and Development as Process," in Taming Megalopolis, ed. H. Wentworth Eldredge (Garden City, New York: Anchor Books, 1967), p. 764; Robert Dahl and Charles Lindbloom, Politics, Economics and Welfare (New York: Harper and Row, 1953),
p. 20.
^Mel Scott, American City Planning since 1890 (Berkeley: University of California Press, 1969) p. 221 (from an article by Lewis Mumford published in Survey Graphic, May 1, 1925).
7
Trudy Parisa McFall, "Housing Allocation Plans have Positive Implications for Local Housing Authorities," Journal of Housing (February 1978), p. 76.
g
Housing and Development Reporter, Bureau of National Affairs, Reference File, Vol. 1, p. 09:0021.
q
Melvin Mogulof, "Regional Planning Clearance and Evaluation: A Look at the A-95 Process," Journal of the American Institute of Planners, 37, no. 6 (1971): 418-22.
10
p. 11.
David Listokan, Fair Share Housing Allocation,


25
^Ernest Erber, "Metroplitan Housing Allocation Planning," Urban Land (April 1974), p. 8.
12
A Regional Housing Plan: Policies and their Implementat ion (Denver: Denver Regional Council of Governments, 1972), p. 29.
13
Norman Williams and Thomas Norman, Exclusionary Land Use Controls: The Case of Northeastern New Jersey, p. 475.
14
Lawrence Sager, "Tight Little Islands: Exclusionary Zoning, Equal Protection, and the Indigent," Stanford Law Review, 21 (1970): p. 767.
^Richard Babcock and Fred Bosselman, "Suburban Zoning and the Apartment Boom," University of Pennsylvania Law Review, 111 (1963): p. 1040.
^Aloi and Goldberg, Racial and Economic Exclusionary Zoning: The Beginning of the End?, p~ 9"!
^Babcock and Bosselman, "Suburban Zoning and the Apartment Boom," p. 1040.
18503 F.2d 930 (7th Circ. 1974).
19 . .
Norman Williams, "Mt. Laurel: A Major Transition
in American Planning Law," Land Use Law and Zoning Digest,
27, No. 6 (1975): p. 33.
2 0
Donald Priest, "A View from the Mount: Laurel and Criticisms for a Major Judicial Advance," Environmental Comment, 23 (July 1974), p. 1.
2167 N.J. at 177.
2 2
David Listokan, Fair Share Housing Allocation,
p. 21.
2^67 N.J. at 174. 24
Id. at 190.


CHAPTER III
ELEMENTS OF THE HOUSING ALLOCATION PLAN
In discussing regional allocation strategy, an overview will be presented explaining how fair share works. Fair-share topics such as definitions of a region and how housing need can be projected will be presented in an overview rather than a detailed explanation which is beyond the scope of this report.
The allocation strategy for fair-share housing can be divided into three stages: initial steps; the allocation process; and allocation output, implementation, and refinement (see Table 1). The first component consists of three steps: 1) determining who formulates the allocation plans, 2) determining the spatial focus of the strategy, and 3) determining the allocatable housing (the pool of units to be distributed). Deermining the spatial focus of the strategy involves designating the allocation region (the area within which housing is distributed) and the allocation sub-area (the county, community or other entity to which housing is allocated).^
The second stage, the allocation process, also consists of three steps: 1) determining the allocation criteria (the objectives and standards by which housing


TABLE 1
ANATOMY OF FAIR SHARE
INITIAL STEPS
Determining who Formulates the Plan Determining Boundaries of Allocation Region Determining Allocatable Housing
1. States 2. Councils of government 3. Counties 4. Other regional bodies 5. Localities 1. State (or multistate) 2. SMSA 3. Multicounty area 4. County 5. Locality Allocation Subareas 1. County 2. Local unit of government, e.g., municipality 3. Planning-designated area, e.g., census tract 1. Needed low- and moderate-income housing 2. Public housing units 3. Other subsidized low-and moderate-income housing 4. Overall housing needs
Determining Allocation Criteria ALLOCATION PROCESS Determining Allocation Factors Determining Allocation Formulas
1. Equal share 2. Need 3. Suitability 4. Distribution 5. Mixed criteria (Operational Indicators of Allocation CriteriaSome Examples) 1. Substandard, overcrowded housing (need) 2. Residential land availability (suitability) 3. Inverse of existing subsidized housing (distribution) 1. Averaging formula 2. Weighted averaging formula 3. More sophisticated techniques
ALLOCATION Determining the Allocation Output OUTPUT, IMPLEMENTATION, AND REFINEMENT Determining Allocation Implementation Strategy Refining the Allocation Process
1. Numerical 2. Priority 3. Mixed 1. Persuasion 2. Coercion 3. Mixed (Some Examples) 1. Refining the housing need projection
2. Refining the allocation criteria and formula
3. Specifying the allocation output
Source: Listokan, David. Fhir Share Housing Allocation (New Erunswick, New Jersey: The Center for _________Urban Policy Research, Rutgers University, 1976), p. 29.


28
is to be distributed), 2) determining the allocation
factors (the operational indicators of the allocation
criteria), and 3) determining the allocation formula
(the guides for manipulating the allocation factors and 2
criteria).
The final stage of the allocation strategy involves allocation output,implementation, and refinement. The first step consists of determining the output of the allocation process. To illustrate, it should be decided whether fair share will yield a numerical housing share for each subarea or whether it will just assign priority development ratings. The next step is to decide on the allocation implementation procedure and the third is to refine the previous tasks in order to make the fair-share plan maximally equitable and practicable.^
In developing an allocation plan, it must first be determined who formulates the plan. Although the courts have recommended the fair share strategy they have hesitated to formulate the allocation plans leaving that task to the legislative branch of government. The Pennsylvania Court of Common Pleas, for example, declined to allocate housing responsibilities among the constituent communities of Bucks County.^ That court did not want to
assume the awesome task of becoming a super planning agency with no expertise in the field


29
and as such the court would be required to make immediate and basic initial policy determinations of a kind clearly for nonjudicial discretion and to carry out this tremendous responsibility with an entire lack of judicially discoverable and manageable standards for resolving it.5
Various legislative and executive bodies usually formulate and implement fair share strategy. The Massachusetts legislature has adopted one variation of the allocation approach; others including New Jersey's and Pennsylvania's are considering plans of their own.
More often, multicountry regional planning bodies such as Councils of Government (COGs) are active in fair share. The first regional allocation plan was adopted by Miami Valley Regional Planning Commission; many others have followed, including the Metropolitan Washington COG, the Metropolitan Council (Minneapolis-St. Paul), and the Denver Regional COG.
A second consideration in developing an allocation plan is determining boundaries of an allocation region. It should follow political boundaries and the public's definition of the region. The area should be large enough to permit complete fulfillment of the goals of the plan and to demonstrate to each jurisdiction that many others will share in meeting the overall housing responsibility.
Conceptions of the meaning of the word "region" vary widely. Webster's Dictionary includes the following four popular definitions: 1) a major indefinite division of inanimate creation; 2) a particular part


30
of the world or universe; 3) a broad geographical area containing a population whose members possess sufficient historical, cultural, economic and social homogeneity to distinguish them from others; and 4) a major area of the world that is to some degree isolated by climate or physical barriers and that to some degree supports a characteristic found differing both qualitatively and quantitatively from that of other regions.^
Definitions of region appropriate for use in allocation plans also vary widely. Generally, agencies have used their own jurisdictional areas for their housing planning areas. In some cases the county, which has been argued as a suitable regional entity, may be too small, too large, or in other ways inadequate as an allocation region. County boundaries are often delineated on the basis of political and other nontechnical considerations that may or may not be appropriate for fair share.
Another possibility is to use the Standard Metropolitan Statistical Area (SMSA), defined as a county or group of contiguous counties which contain at least one city of at least 50,000 population. The argument for utilizing the SMSA is that it is a commonly-accepted and utilized census region for which data is readily available. Additionally, the Bureau of the Census takes into account social and economic cohesion


31
in designating an SMSA. To illustrate, in addition to the county or counties containing a city of 50,000, contiguous counties may be included within an SMSA if they are socially and economically integrated with the central city.
No one will dispute that an SMSA is an accepted region, but one must question whether it is an appropriate fair-share region. Since regional allocation focuses on housing and often has the objective of placing housing where there are jobs, many lean towards using the regional housing market. The latter has certain interval housing dynamics that differentiate it as a separate housing region; additionally, it is delineated in
7
large part by examining the length of journey to work.
The Federal Housing Administration's (FHA) Techniques of Housing Analysis defines a housing market area as the "geographic area within which all dwelling units are linked ... in a chain of substitution, or, the units are in competition with one another as alternatives
g
for the users of housing." This conception of the regional housing market is another suggestion useful to the definition of an allocation region.
A number of courts have delineated allocation regions based on journey-to-work considerations. In the Mount Laurel decision, New Jersey's Supreme Court
defined the applicable housing demand region as "those


32
portions of Camden, Burlington, and Gloucester Counties
within a semicircle having a radius of 20 miles or so
9
from the heart of Camden City." Presumably, the
court viewed the area within the twenty-mile radius as
the significant commuter distance surrounding Camden.
In another court decision, the New Jersey Superior
Court leaned towards delineating a fair-share region
based on the journey to work combined with county
considerations. However, there are some problems that
are encountered with the commuter-generated approach
to region. Multiple decentralized centers complicate
the delineation of an allocation region based on
employment, rather than a single employment center such
as the traditional urban central business district.
Fair-share allocation may be difficult to explain and
understand if the allocation regions consist of
sprawling entities that appear to lack common cultural,
geographic and economic characteristics. Allocation
regions may not resemble more commonly accepted regions
and may overlap political boundaries such as state
lines, causing practical problems of application.
Data-gathering for commuter-determined regions may
also be more difficult than for more "traditional"
census regions such as counties and Standard Metro-
10
politan Statistical Areas (SMSAs).


David Listokan states that:
Even though perfection cannot be obtained in delineating a fair share region, the housing-market-journey-to-work approach seems to be logical and has had considerable acceptance. It therefore deserves first consideration. However, in addition to commuting distance, other points bear consideration in delineating a fair share allocation region. If possible the allocation region should have geographical cohesion and should be geographically contiguous. The region should contain both sending zones--areas containing concentrations of families (usually low- and moderate income) to be housed by the fair share housing--as well as receiving zones: areas that \vill receive these families. It would not make sense to designate a fair share region containing only affluent communities or vice versa, consisting of only impoverished areas, but rather some balance of rich and poor, good housing stock and poor housing stock, high-need and low-need locations is needed. In addition, if justified by the housing-market-journey-to-work approach, whole counties rather than just portions of counties should be incorporated into the allocation region.
A crucial practical consideration is confining the region to the area over which the body proposing fair share has jurisdiction.H
Regional allocation strategies that have either been proposed or implemented have utilized a variety of types of allocation regions. Their variations are summarized in Table 2. Some regions have covered single communities of varying sizes; for example, Los Angeles, Pueblo, Colorado, and Jacksonville, Florida; others have included one county; for example, Dade County, Florida and Monroe County, New York. Many fair-share plans have encompassed numerous counties.
The Dayton Plan, for example, uses a five-county allocation region surrounding Dayton, Ohio. The


34
TABLE 2
SELECTED CHARACTERISTICS OF ALLOCATION PLANS
Miami Valley Regional Planning Commission San Bernardino County, Calif. Metropolitan Council Minneapolis-St. Paul
Date Adopted July 1970 January 20, 1972 February 25, 1972
Type of Agency Regional Planning Commission County Planning Department Metropolitan Council
Size of Jurisdiction Allocation Region Allocation Subarea Five counties surrounding and including Dayton, Ohio Valley portion of the San Bernardino County Seven-county area
Range of Plan Currently being updated To be updated annually Interim status
Type of Strategy Numerical Combined Priority
Base of Allocation Need Federal units to be authorized
Type of Units Subsidized Subsidized and Low- and moderate-
Allocated and public housing units public housing units income housing units
Number of subareas 53 15 191
Basis for subareas Townships Census tracts Municipal boundaries
Need Allocation Criteria (1) Share of households less than $10,000 annual income ($7,000 in rural areas) (the greater the number of households, the greater the share of new units) (1) Deficient housing units within income group level appropriate (the greater the number of units, the greater the share of new units) (2) Number of jobs (the greater the number of jobs, the greater the share of new units)
(3) Number of households with annual gross income less than $10,000 (the greater the population in this category, the greater the share of new units)


35
TABLE 2 (Continued)
Miami Valley Metropolitan Council
Regional San Bernardino Minneapolis-
Planning Commission County, Calif._______________St. Paul_____
Distributive Alloca- (2) Equal (4) Equal share
tion Criteria share
(3) Proportion ( 5) Number of to the popula- households (share tion is in proportion
to the population)
(1) Percentage of existing low- and moderate-income housing (the higher priority is given to lowest percent)
Suitability Allocation Criteria
(4) Inverse of (1) (the greater the number of households, the smaller the share of new units)
(5) Assessed (6) Assessed valu-valuation per ation of pupil pupil (the average daily higher the val-attendance (the uation, the higher the value, greater the the greater the share of new share of new units) units)
(6) Overcrowding in schools (the greater the overcrowding, the smaller the share of new units)
(7) Existing additional school capacity (the less the capacity, the less the share of new units)
(2) Amount of land currently developed (the higher priority is given to areas with more development)
(8) Vacant residential land valued at $10,000 per acre or less (the more acres in vacant land, the greater the share of new units)


36
TABLE 2
(Continued)
Miami Valley Metropolitan Council
Regional San Bernardino Minneapolis-
Planning Commission County, Calif.________St. Paul
Location Criteria No Yes No
A-95 Review Powers Yes No Yes
Sources: Miami Valley Regional Planning Commission, A Housing Plan for
the Miami Valley Region; San Bernardino County Planning Department, Government Subsidized Housing Plan; and Metropolitan Council of the Twin Cities Area, Interim Housing Allocation Proposal.


37
Metropolitan Washington COG allocation also includes a five-county area. The Metropolitan Council (Minneapolis -St. Paul allocation strategy encompasses a seven-county region surrounding the Twin Cities and the Denver COG's allocation strategy encompasses the Denver SMSA.
Some plans utilize statewide regions. Massachusetts uses a statewide approach determining housing need regionally within the state, using either newly-drawn or previously established planning districts.
The fundamental reason for this variety of allocation regions is political and administrative; allocation regions are drawn coterminous with the area over which the body implementing or considering the fair-share plan has jurisdiction, or over which it normally focuses as part of its coordination or research activities. The Dayton Plan allocation strategy encompasses a five-county area because it was formulated by the five-county Miami Valley Regional Planning Commission. The Denver COG Plan encompasses the Denver SMSA because its constituent members are found throughout this SMSA.12
Housing allocation plans or fair-share strategies differ in the types of housing they allocate. One methodology proposed by Rahenkamp, Sachs, Wells and Associates distributes all housing that will have to be built in the future to overcome a regional housing


38
gap, not just low- and moderate income units. The Delaware Valley Regional Planning Commission's Plan proposes to distribute housing of all income categories. Almost all of the allocation plans focus on housing for families at the lower end of the housing spectrum. Most distribute the total number of low- and moderate income housing units needed in the region. This approach characterizes the Dayton, Puget Sound, Southeastern Wisconsin and Monroe County strategies. Numerous plans, such as the Metropolitan Washington, and the San Bernardino allocate only those units that will be subsidized by the federal, state, or local governments.
A few allocate only public housing units (see Table 3).
There are advantages and disadvantages to each methodology. In most suburban areas, low- and moderate-income families can afford only subsidized housing. Hence, in a fair-share housing formula it may be more realistic to allocate only aided units. It is also simpler to distribute aided units than to calculate regional low- and moderate income housing need.
Distributing only subsidized units has certain drawbacks, however. In areas with few aided units, fair share plans will barely disturb the status quo of limited suburban housing opportunity. In contrast, the strategies considering the total need for low- and moderate-income housing can help dramatize the need for such units, especially in suburban areas. Additionally, the latter plan can be said to more truly indicate a locality's "fair share" of the regional housing need, a crucial determination for evaluating local zoning ordinances, especially interpreted by numerous courts.10


39
TABLE 3
TYPES OF HOUSING DISTRIBUTED BY FAIR SHARE PLANS
Housing Types Planning Agencies with Models
Public Housing Cleveland City Planning Commis-
Units sion
San Francisco City Planning Commission
Cuyahoga Metropolitan Housing
_________________________________Authority_____________________________
Federally Subsidized Washington Council of Governments
Housing Units Metropolitan Council of the Twin Cities
San Bernardino County Planning Commission
Pueblo (Colo.) Regional Planning Commission
Ventura County Human Relations Commission
Sacramento Regional Planning Commission__________________________________
Miami Valley Regional Planning Commission
Genesee/Finger Lakes Regional Planning Commission
Monroe County Planning Department Northeastern Illinois Housing Coalition Dade County (Fla.) Planning Board Jacksonville Community Renewal Program
Capital District (N.Y.) Planning Com-
_____mission_______________________________
Total Housing Need Delaware Valley (Pa.) Regional Plan-
ning Commission
West Piedmont (Va.) District Planning Commission New Jersey proposal Rahenkamp, Sachs, Wells and Associ-_________________________________ates (proposed Pennsylvania Plan)
Source: Housing Allocation: Criteria and Strategies, prepared by the Economic Consultants Organization for the Southern Tier __________Regional Planning Board (Buffalo, 1974), p. 6._____________
Total Low- and Moderate-Income Housing Need


40
David Listokan, an expert on fair share, says that the decision for choosing to allocate subsidized units or for deciding to distribute low- and moderate-income housing need may very well hinge on how fair share is viewed: as a corporate planning tool for distributing publicly-aided units, or as a more general strategy for publicizing and pinpointing the need for expanding the suburban housing mix. The former view dictates allocating a subsidized housing pool, while the latter calls for distributing the low- and moderate-income housing need. According to Listokan, adopting the total low- and moderate income need approach raises three questions:
1. Should low- and moderate-income housing need be differentiated?
2. How should low- and moderate income categories be defined?
14
3. How should housing need be projected?
An argument can be made for combining both income categories and for differentiating between them. The argument for considering them together is that the deprivation and needs of families at the lower end of the income spectrum are generally similar. Combining both income categories simplifies the process of projecting their housing needs. However, it is important to consider the low- and moderate-income groups separately because their housing needs


41
differ. Almost by definition, there is a distinction in the relative degree of difficulty encountered by the two groups in securing housing, with lower-income households encountering greater hardship than the comparatively more affluent moderate-income families. Low-income families are often priced out of the market. Another consideration is that the type of housing and supporting services needed may differ. Lower-income families may or may not require units with more bedrooms than their moderate income counterparts. Also, the impact of low-income housing on municipal and school services may vary as compared to the effect of the moderate income units.
Some fair-share plans, in considering regional housing need, differentiate between low- and moderate-income families. These plans establish annual income limits for low- income and moderate-income families. There is some precedent among fair-share plans for distinguishing housing need on the basis of income categories but doing so may compound the problems of projecting housing need.
There are two approaches to defining low- and moderate income groups. The first involves surveying which income group(s) cannot afford nonsubsidized basic housing. A second, faster technique involves operationally defining low- and moderate income as


42
those with certain percentages of the areas norm or average income.
The first approach utilizes survey techniques to determine 1) the cost of decent, privately-built housing in a designated region, and 2) who can or cannot afford such housing without public assistance without spending a burdensome share of income for shelter. Those who cannot or who can barely afford such units, given the conditions mentioned above, are considered to have low- and moderate-incomes respectively.
Operationally, the survey approach consists of the following steps:
(1) Delineate the area designated for study.
(2) Define basic or decent housing.
(3) Calculate the private market (unsubsidized) cost of such housing.
(4) Determine the maximum percentage of income that should be spent for housing without causing financial hardship (housing expenditure/income ratio) .
(5) Calculate who can or cannot afford the basic decent housing (determined above) given the decided-upon housing expenditure income percentages (described in 4). Those who are priced out or who are almost priced out comprise the low- and moderate income groups, respectively. ^
The survey approach is very time-consuming and for this reason the ratio approach is often used. The ratio or percentage methodology defines low- and moderate-income categories as certain percentages of local average income.
The ratio approach entails the following steps:
(1) Delineate the area designated.
(2) Calculate the average income of the designated area.
(3) Determine low- and moderate income percentages of average income.
The ratio approach is not as accurate or sensitive as the survey method; however, it is much simpler and yields results much more quickly than the survey approach. 16


43
Along with the difficulty of defining low- and moderate-income groups is the problem of projecting housing need, a necessary factor in developing a fair share plan. Many fair share plans project housing need in a simple manner. Generally, they define moderate-income limits and then calculate the gross housing need of households falling within these income limitations.
The available supply of low- and moderate income housing units, taking into account such factors as housing cost and deterioration, is then estimated. Subtracting need from available supply yields the net low- and moderatehousing need.
The fact that most fair-share plans use simplified housing projection in many cases reduces the credibility of the allocation and its effectiveness for addressing true housing need. For this reason, some fair-share agencies have attempted to refine their housing projections. Some plans have expanded their focus by including rehabilitation volume (rather than only new construction activity) when calculating the low- and moderate income housing supply. Housing need has also been broken down into different categories such as elderly and non-elderly, and new construction versus rehabilitation. Another frequently employed change makes the projection more dynamic by estimating long-term future need rather than need for just one period (such


44
as need at
the time the projection is made). Allocation Criteria and Factors
David Listokan suggests four basic distribution considerations:
Allocation criteria, allocation factors, allocation formulas and allocation strategies. Allocation criteria are the basic standards or guidelines for distribution, i.e., placing housing where it is needed most. Each criterion can consist of a number of operation allocation factors [see Table 4], The need criterion, for example, can consist of such factors as the number of low- and moderate income families in a subarea, as well as the number of its deteriorating housing units. Allocation formulas determine how the allocation criteria and factors are to be manipulated to calculate a subarea's fair share distribution. Allocation strategies determine the nature of the output from the allocation formulas.
One strategy, a numerical approach, distributes numbers or percentages of units to each subarea, while another less exact strategy assigns various levels of development priorities. s
The difference between the allocation criteria and the allocating factors, formulas, and strategies can be illustrated by Figure 1. The basic criteria of fair-share housing allocation are equal share, need, distribution, and suitability. The first criteria that shall be discussed is equal share. The rationale of the equal share approach is to distribute equal shares of low- and moderate-income housing to all communities in that all areas within a region have the same obligation to meet the region's housing needs.


45
TABLE 4
EXAMPLE OF ALLOCATION CRITERIA AND FACTORS
ALLOCATION CRITERIA ALLOCATION FACTORS (Allocation Subarea Characteristics)
Need 1. Job availability 2. Substandard housing 3. Overcrowded housing 4. Low- and moderate-income families 5. Minority families 6. Households paying more than 25 percent of income for housing
Suitability 1. Transportation facilities 2. Physical environment 3. Local fiscal resources 4. Land availability 5. Land cost and environmental suitability 6. Public and private utility and service infrastructure
Distribution 1. Existing subsidized housing (inverse relationship)* 2. Existing low- and moderate-income families (inverse relationship) 3. Existing minority population (inverse relationship) 4. Comparatively wealthy families 5. Equal share
*
As the magnitude of the allocation factor increases, the amount of allocated housing decreases.
Source: Fair share plans


46
Allocation Criteria and Factors
Allocation
Formulas
Allocation
Strategies
Standards and guidelines for distribution, i.e., placing housing where it is needed most. Each criterion can consist of a number of operational allocation factors (see Table 4).
Determine how allocation criteria and factors are manipulated to calculate a subarea's fair share distrib ution.
Determine the nature of the output from the allocation formulas. Defines output from the fair share approach.
FIGURE 1
HOUSING DISTRIBUTION CONSIDERATIONS


There are three variations of the equal share criteria; they can be described as equal distribution equal achievement and equal production. The first calculates the total amount of needed low- and moderate-income housing (or subsidized housing) and then equally distributes such housing to all subareas in the allocation region. This method is often used in conjunction with other fair-share criteria.
The second variation of equal share, the equal achievement approach sets equal standards of low- and moderate-income housing availability which, when met, presumably indicate that a subarea is meeting its obligation to provide such housing. The best example of the equal achievement approach can be found in Massachusetts. A 1969 statute (Chapter 744) established
19
boards of review both on a local and state level.
Under this plan, sponsors of low- and moderate-income
housing file a single comprehensive permit request with
20
the local board. Should the latter reject the proposal, the developer can appeal to the state board, the Housing Appeals Committee of the Department of Community Affairs. The committee reviews the proposal and comes to a decision by balancing certain valid local planning objectives against regional need for low- and moderate income housing. The Massachusetts statute requires the Committee to uphold a local board's rejection of a permit if


48
the locality has met certain statutory low- and moderate-income housing minimums. The equal achievement standards for individual towns indicating that the regional housing obligation was met were:
a) 10 percent of a town's housing units are subsidized for low- or moderate-income persons, or
b) such housing exists in the community on sites constituting 1.5 percent of the total land area, excluding public land.
The lesser of these quotas rules. And a local
board need not approve a permit for construction of
housing on sites comprising .3 percent of the town's
land area, or 10 acres, whichever is larger, in any one 21
year.
The third variation of the equal share approach, the equal production methodology, establishes the minimum share of low- and moderate income housing that builders of new housing projects must provide. A number of jurisdictions have opted for such an approach.
Fairfax County (Virginia) in 1971 passed an amendment stipulating that applicants for rezoning in its Planned Development Housing District must provide, or cause others to provide, at least 6 percent of the total housing units initiated for low-income families; an
additional 9 percent must be allotted to moderate income 22
units. Developers of fifty-unit or larger tracts in the county's residential Garden Court district must provide the same percentages of low- and moderate
income units.


49
Equal share has some drawbacks that will be discussed later in evaluating criteria of housing allocation, however, it is appealing in its simplicity and its underlying and incontestable philosophy that all communities must bear a share of needed housing production. Equal share can be considered a separate criteria or it can be a factor of the criteria of distribution.
A distribution strategy attempts to allocate low- and moderate-income units to areas lacking such housing in order to achieve a greater income mixture (and implicitly greater social and racial mixture) in those communities. Distribution entials the allocation of housing units equally to all areas or in proportion to some demographic aspect of the area. These demographic aspects may consist of assigning housing units to an area in proportion to its share of any one or a combination of the following: regional total population, households, low- and moderate-income households, low- and moderate-income housing units, ethnic minority population or projected population increase. If the goal of an allocation plan is to increase housing opportunities for low- and moderate-income households, the distributive criteria might assign needed housing units to areas inversely to their share of the regional total of any one or a combination of the following: low- and moderate-income households, low- and moderate-income housing units, or ethnic minority population.


50
As a result, areas with the fewest opportunities for
lower-income houeholds would receive the largest number
23
of needed housing units.
The distribution criterion is popular because one of fair share's major motivating forces is the expansion of suburban housing opportunity for low- and moderate income families. Incorporating a distribution objective is one of the features differentiating the fair-share approach from more general regional housing planning.
A third criteria of fair-share strategies is indicators of housing need. Almost all fair-share efforts consider housing need as one allocation criterion and have allocated units to subareas displaying such need. For example, areas would receive housing units in proportion to their share of the regional total of substandard units, overcrowded units, doubling in units, low- and moderate income families desiring to move into the area or low- and moderate income families paying more than 25 percent of their income for rent.
A fourth criteria is suitability. The suitability goal attempts to allocate units to those areas best able to absorb additional housing or possessing desirable qualities for housing construction. Table 2 shows that many fair share plans--for example, the Dayton and San Bernardino efforts--have incorporated numerous suitability measures indicative of a subarea's


51
fiscal, service infrastructure, and environmental suitability for new housing, especially low- and moderate income units. Examples of fiscal suitability factors include an area's assessed valuation per pupil, or per capita, additional school capacity, available land, fiscal resources, taxing capacity, employment opportunities, recreational facilities, health services, water and sewer capacity, level of development availability of mass transit, physical environment and 24
zoning. The greater the local wealth, the greater the ability to absorb new growth and therefore the higher the fair-share allocation. Service infrastructure suitability factors include the above-mentioned examples such as the presence of excess school capacity, recreational facilities and public transportation. As an area's surplus service and infrastructure capacity increases, its ability to handle new construction rises; therefore it is assigned a relatively higher fair-share quota. Environmental indicators include areas of prime agricultural land and areas subject to flooding, landslide, or other hazards (construction is not encouraged in such areas). Other suitability measures
2 5
include the amount and cost of vacant land.
Equal share, distribution, need and suitability are the major fair-share allocation criteria, but they are not the only ones used. Some fair-share plans take into consideration past subarea performance


52
and allocate more housing units to those subareas with poor past records. The 1973 Dayton Plan considers the number of public and subsidized housing units in each subarea in calculating local fair share, and the Southeastern Wisconsin Regional Planning Commission also adjusts its allocation in accordance with past performance.
The different allocation criteria have been discussed separately in this study but the criteria are sometimes interdependent. For example, in allocating housing to areas where there are jobs, one may well achieve the additional goal of distributing housing since expanding job opportunities are largely in the suburbs. Similarly, if the most suitable housing sites--those with a well-developed infrastructure--are in urban areas, then the allocation of housing to urban sites may well result in the assignment of housing to areas of greatest need. While the allocation criteria can be interdependent the need factor can sometimes work counter to the distributive factor and suitability may sometimes conflict with need or distribution. Listokan summarizes by saying that "these internal conflicts do not mean that fair share does not make sense; rather they reflect a strategy with numerous goals.""


55
Many fair-share plans utilize an allocation formula that manipulates the allocation criteria and factors as follows:
1) Express the allocation factors for each subarea as a percentage of the regional total.
2) Add these subarea factor percentages and divide by the number of factors (this calculation is a simple averaging technique). The derived average equals the subarea's fair share of the housing
to be allocation.^7
The Pueblo, Colorado allocation formula uses
a simple application of the averaging approach. The
distribution model used by the Denver COG is similar to
Pueblo's simple averaging methodology but considers
additional allocation factors, breaks down the
allocated housing into low- and moderate-income groupings
and adjusts this pool of distributed housing by
considering subarea past performance in building such 28
units.
The simple averaging methodology incorporates all of the allocation factors and criteria equally.
Some fair-share plans have weighted certain allocation criteria more heavily than others to reflect their belief that certain objectives and indices are more important than others. There is tremendous diversity in the formulas employed by various fair share agencies. Some plans add and multiply and in other ways manipulate the allocation criteria and factors. The Washington COG plan calculates a subarea's allocations
as follows:


54
Fair Share = (demand + supply) x modifier Where:
Demand = low- and moderate income commuters + overcrowding and deficient units
Supply = vacant residential land + vacant housing units
Modifier
___________Fiscal Resources___________
Low and Moderate Housing Concentration
x Accessibility
Fiscal Real Estate Value x Personal Income Resources Population
This formula is used to calculate a fair-share index number for each subarea. All of these index numbers are added and each subarea's index number is expressed as a percentage of the total. This percentage is the subarea's fair share of the total subsidized housing to be distributed. For example, the allocation index number for the District of Columbia in the Washington COG plan is 14,166,525 or 20.3 percent of the region's total 69,693,809 allocation index number. The District of Columbia, therefore, is assigned 20.3 percent of the region's federally-subsidized housing units.
In most allocation models, allocation factors have been converted into percentages of the regional total, however, this approach is not universally followed. The Washington COG plan uses some of the absolute values of allocation factors in its fair


55
share calculation. Another approach converts the allocation factors into a point rating system. A range of allocation criteria and factors are considered and each--depending on its magnitude--is given a point designation that can range anywhere from minus 40 points to plus 100 points. Summing these points yields a total score indicating where housing should be distributed.
The point spread and assignment are based on its
planner's opinion of the importance of the different
r 29
factors.
Allocation Strategies
In translating allocation criteria into some system for determining desired housing location, two types of strategies have emerged. One is the "numerical" method, the other is the "priority" design. The numerical method allocates either specific numbers of needed housing units or a share of the regional need to given areas. In this case, the allocation formulation is by means of inputting various numbers into an equation which yields a community's share of the total low- and moderate income housing requirement.
The priority method isolates various areas which are designated as the most desirable communities for locating low- and moderate income housing units, but does not assign each community a specific number of units. Consequently, while the numercial method gives upper


56
limits on the number of units to be provided by a
30
community, the priority method establishes no limits.
Reasons for choosing one allocation strategy over the other are not obvious. Moreover, they do not seem to be mutually exclusive strategies. The San Bernardino County Plan essentially allocates a number of units for each planning subarea and then further establishes priority areas within the subareas for the location of the subsidized units. The following will describe and explain the differences between the numerical models and priority approach and Chapter Four will describe allocation plans that use numerical models, priority design and a combined approach.
There are at least four distinctions between the two strategies. First, the priority plan is less rigid and hence easier to sell. A drawback lies in the fact that some areas have been designated to develop units before others. The numerical strategy has been palatable because each jurisdiction assumes a responsibility to take its share. The apparent fairness of this has been a strong selling point. However, if the priority-based plan were to set limits indicating that after the first priority area had built so many units the priority would be shifted to the second area
i
and so on, then the distinction between the two plans would be less apparent. The numerical strategy by


57
definition places an upper limit on the number of units that have to be built before the plan is revised.
The second distinction has to do with development characteristics. The priority plan is best suited for areas where development is rapid and builders may be competing for federal funds. The priority method works well in areas where proposals for housing are so numerous as to necessitate some method of ranking the proposals. The numerical plan is best suited for areas where need is widespread and dispersal is critical.
The third factor concerns where the plan is directed. The priority strategy places more responsibility on the developer to comply with the allocation plan and to build in the priority areas. It has been noted that encouraging developers to choose areas where housing is needed most is a difficult aspect of allocation plans. The priority strategy appears to consider the developer its audience, while perhaps the numerical plan would choose communities as its major focus.
Although all areas should agree with or adopt the plan, there is no definite measurement in a priority plan to determine how each area is complying with the plan. While this is not to suggest that the priority strategy does not establish some standards for the development of lower-income housing, it is not so apparent as those plans based on a numerical strategy.


58
At the same time, while the numerical plan still places some responsibility on the developer, the jurisdictions assume more responsibility because they have agreed to a certain number of low-income housing units. With a numerical strategy, each planning area can be held more closely responsible for its performance. The priority strategy does not place such clear responsibility on each planning area.
Finally, the two different strategies appear to affect the development of future lower-income housing in slightly different ways. The priority strategy will place the new lower-income housing in areas where it is most needed. The numerical strategy, however, can have the effect of filling the softer more receptive areas first, because the units can be built in any area where the need still exists. That is, those areas that may have some lower-income housing already located within the subarea, yet still need additional lower-income housing, may be the first to fill their quota, because they are more likely to be receptive. Those areas with few or no existing units for lower-income families will be slow to accept any at all. This phenomenon occurred in the Miami Valley Region in the earlier phases of its plan. Choosing one strategy over the other or developing a combined approach would depend on the characteristics of the need and the development pattern for that area.0'*'


59
Implementation Strategy and Allocation Refinement
Once it has been decided whether the allocation output will be a numerical, priority or mixed approach, it must then be determined how the regional body formulating the allocation plan can help ensure local compliance. Fair share agencies have employed persuasive and coercive strategies in attempting to implement their allocation plans. The regional agency can persuasively argue the merits of a fair share plan: the strategy's objective of placing housing where it is most suitable from a fiscal, service-infrastructure and environmental perspective. Additionally, it can argue that the alternatives to fair share such as piecemeal antiexclusionary zoning litigation are far less preferable than regional allocation. Another persuasive strategy is for the fair share body to explain that the low- and moderate-income housing to be constructed will house some local poor in addition to nonlocal residents. This "house your own" theme is often used in association with proposals for elderly housing where fair share is touted as a means for a community to provide shelter for its local
residents who are retired and can no longer afford un-
32
subsidized units.
In situations where the opposition is deeply-rooted a persuasive strategy may prove ineffective.
Under these circumstances, many agencies resort to


60
coercive methods to assure compliance. The most powerful instrument used by regional agencies is their A-95 review power. This sanction required that municipal proposals for federal assistance for public facilities--sewer and water facilities, new towns, airports--be first evaluated by regional planning bodies for their necessity and regional impact. Some fair share bodies, such as DRCOG incorporated the fair share plan directly into the A-95 review process.
The Dayton Plan termed the A-95 process "the most important tool for implementation" but in practice, A-95's impact has sometimes been muted. Some federal assistance programs did not require clearinghouse comments and some clearinghouses only went through the motions of reviewing applications; rarely would they submit a negative comment. This approach resulted, in part, from hazy review standards and the clearinghouses which often consisted of voluntary regional bodies' disinclination to antagonize local communities. Another major deficiency was that some executive agencies which received the A-95 comments paid little heed to these recommendations and funded projects that had received negative comments. In sum, the A-95 process offered potential as a strong fair share implementing tool, but its effectiveness depended on such factors as the aggressiveness and courage of the


61
clearinghouses and the attitude of different executive 33
agencies.
The situation has changed today. Federal funds for Comprehensive Planning (HUD 701 program) were discontinued about two years ago. Since the A-95 review process was a part of the HUD Comprehensive Planning program, the A-95 review process was eliminated. Currently, federal and state grant applicants do not have to submit grant applications to any clearinghouse for review and compliance with existing housing allocation plans.
Many fair share bodies incorporated the fair share plan directly into the A-95 review process.
Under A-95 review, agencies were required to submit grant applications to a clearinghouse for review and compliance with regional housing allocation plans. If a local government was not making a "good faith" effort to comply with fair share, it was reported to the federal funding agency. Without A-95 review powers, no authority exists to monitor and influence the implementation of fair share plans.
Fair share plans implemented to date must be viewed as first generation efforts and they have technical imperfections which are not surprising in view of the complex, multi-stage distribution process they require. Most fair-share bodies recognize these


62
problems and are attempting to rectify them. The Dayton Plan was revised in 1973 and the Metropolitan Council Strategy, introduced in 1972, was revised in 1974 and again in 1975.
David Listokan, a fair share expert, states
that
Refinements can be expected along the broad spectrum of allocation steps, but major attention is likely to be paid in a number of areas. To summarize:
1. Projecting Housing Need.
Approaches thus far have sometimes been perfunctory. They are likely to be improved to take advantage of new data (such as the annual housing survey) and to improve past procedures. Instead of a gross housing need, there are likely to be projections of need over time as well as be type of housing and class of consumer. (The housing assistance plan provision of the 1974 Housing Act is also likely to spur more housing need studies.
2. Allocation Factors and Formulas.
Refinements can be expected in the allocation factor used. Possibly more will be utilized and there will be a search for more sensitive indicators. Formulas can also be expected to become more sophisticated, especially in converting different factors to common combinable units and in the manipulation of the factors. (There is also a possible counter-trend to simplify the allocation.)
3. Allocation Output.
There is likely to be a move towards a more specific allocation output. More numerical or combined strategies are likely along with a pinpointing of the type of housing to be built, the clientele to be served, and the grace period for compliance.
4. Allocation Implementation.
Having succeeded in getting the allocation idea across, fair share bodies will spend more time attempting to realize their plans by carrying out extensive public educational programs, and formally integrating the allocation with the A-95 process. There is also likely to be a


63
growing interface between fair share and the preparation and review of housing assistance plans which are required before receipt of new community development subsidies.34
Chapter III of this report has focused on explaining how fair share works. It can best be summarized by following Table 1 (p. 27). The allocation strategy for fair share housing can be divided into three stages: initial steps; the allocation process; and allocation output, implementation and refinement.
The first component consists of three steps: (1) determining who formulates the allocation plans; (2) determining the spatial focus of the strategy; and (3) determining the allocatable housing (the pool of units to be distributed). Determining the spatial focus of the strategy involves designating the allocation region (the area within which housing is distributed) and the allocation subarea (the county, community or other entity to which housing is allocated).
The second stage, the allocation process, also consists of three steps: (1) determining the allocation criteria (the objectives and standards by which housing is to be distributed); (2) determining the allocation factors (the operational indicators of the allocation criteria); and (3) determining the allocation formula (the guides for manipulating the allocation factors and criteria).


64
The final stage of the allocation strategy involves allocation output, implementation, and refinement. The first step consists of determining the output of the allocation process. To illustrate, it should be decided whether fair share will yield a numerical housing share for each subarea or whether it will just assign priority development ratings. The next step is to decide on the allocation implementation procedure, and the final step is to refine the previous tasks in order to make the fair share plan maximally equitable and practicable.


65
NOTESCHAPTER III
'David Listokan, Fair Share Housing Allocation,
p. 27.
2Ib id.
^Ibid.
4
Commonwealth of Pennsylvania v. County of Bucks, 22 Bucks Co. Rep. 179 (Court of Common Pleas 1972). Appeal dismissed 8 Pa. Cmwlth. 295, 302 A.2d 897 (Com. Ct. 1973) Cert, den., 414 U.S. 1130, 94 S. Ct. 869, 38 L.Ed. 2d 754 (1974).
^8 Pa. Cmwlth at 297, 302 A.2d at 899.
^Webster's New International Dictionary, 34d Ed.
S.V. "region."
7
David Listokan, Fair Share Housing Allocation,
p. 33.
g
U.S. Department of Housing and Urban Development, FHA Economic and Market Analyses Division,
FHA Techniques of Housing Market Analysis (Washington, D.C.: GPO, 1970).
967 N.J. at 190.
"^David Listokan, Fair Share Housing Allocation,
p. 39.
Ibid.
Ibid., p. 40.
Ibid., p. 43.
14
Ibid., p. 44.


66
^ ^Ibid., p. 46.
^Ibid. p. 47.
^Ibid. p 51.
18Ibid., p. 52.
^Mass Gen. Laws Ann. Ch. 40B secs. 20-23 (Supp. 1973 inserted by State 1969, Ch. 774).
20
"Massachusetts Zoning Appeals Law," Boston University Law Review, 54 (January 1974): 47-51.
21
David Listokan, Fair Share Housing Allocation,
p. 54.
22
Amendment 156, June 20, 1971 County of Fairfax, Va. Code, Ch. 30 (1961) as amended.
23 .
Economic Consultants Organization, Inc.,
Housing Allocation: Criteria and Strategies p. 7.
24 T, ,
Ibid.
25
Listokan, Fair Share Housing Allocation, p. 58. ^Ibid. p. 59.
27.,.,
Ibid.
2 8
A Regional Housing Plan--Policies and their Implementation (Denver: Denver Regional Council of Governments, 1972), p. 56.
29
David Listokan, Fair Share Hous ing A1 locat ion p. 67.
^Economic Consultants Organization, Inc., Housing Allocation: Criteria and Strategies p. 7.
31Mary E. Brooks, Lower-Income Housing: The Planner's Response, pp. 19-20.


67
32
p. 84
David Listokan, Fair Share Housing Allocation,
33
Ibid.
34
Ibid. p. 86.


CHAPTER IV
CASE STUDY DESCRIPTIONS AND IMPACTS
This chapter will discuss examples of housing allocation plans. Three different approaches will be described in the following section: the numerical model, the priority design and a combined approach.
Miami Valley Region, Dayton, Ohio
Numerical Approach
The Miami Valley (Ohio) Regional Planning Commission (MVRPC) proposed the first fair-share model in its July 1970 report. The Miami Valley Region in southwest Ohio has a population of about 900,000.
Three counties are predominantly rural in character, while the Dayton metropolitan area is contained within the other two largely urbanized counties. Dayton City has a population of 243,000, or a little more than one-quarter of the region's people. About 11 percent of the area's total population is Black, and most of these people live in a concentrated area of Dayton's west side. Blacks make up more than 30 percent of the Dayton City population.
The development of the model was influenced by the increasing visibility of blighted areas and the


69
growing recognition that the supply of housing for low-and moderate income persons trailed far behind the demand ("social" demand) for such housing. Consequently, the goals established by MVRPC included: 1) the adequate housing of all the region's people by increasing supply, and 2) the creation and maintenance of sound and viable neighborhoods by expanding the geographic range of housing choice.^
Being the first plan of its kind, there were no examples to follow. So, MVRPC took the responsibility of setting forth a Dispersal Plan for scattering the needed housing. In addressing the problem of quantifying housing need, which was the first step, no one single source offered the end-all, be-all answer. And on the question of how to numerically distribute the units to subareas of the region, no one had touched that with a ten-foot pole.
The MVRPC staff sought a mathematical way of distributing units so as to avoid contention which might be generated over arbitrary assignments. First, housing need was quantified using a straightforward need vs. supply technique. Need was defined as a social concept, separate and apart from the economic concept of demand. The results of this analysis showed that in 1970, the five-country region was suffering a deficit of--and therefore needed--about 16,000 additional


70
housing units. 0£ these, more than 14,000 were estimated to be needed for the low-moderate income market. The need figures did not take into account all of the dwelling units in need of rehabilitation; it dealt only with new units required to eliminate dilapidation and overcrowding and provide a comfortable vacancy rate.
Also, the need figures were broken down by county so that each of the five-member counties could see its own need as part of the total regional need.
Care was taken to do the best possible job on the need figures, as these were to be the quantities distributed throughout each county. The numbers of units arrived at indicated the seriousness of the situation on the one hand, but they were conservative enough to seem reasonable and not overwhelming on the other. This is perhaps the first application of a lesson that pervades the entire housing plan story--enough to illustrate the point, but tempered^ to discourage reaction from going off the deep end.
Once the county-by-county need figures were computed, the larger task of distributing them had to be faced. The five-county region was divided into 53 "planning units," determined to a large extent by the intensity of development within those subareas. The City of Dayton is one subarea which was further divided into 10 planning units (see Figure 2). The MVRPC determined the need for additional low- and moderate-income units in each of the five counties. The "need" in each country was distributed only to those planning units within that county.^


FIGURE 2
PLANNING UNIT BOUNDARIES
for the
MVRPC HOUSING PLAN 1973
cr~
I
I
I 7
r: ,v .. L J


72
Total housing needs were computed for each county and are indicated in the table below:
TABLE 5
MIAMI VALLEY HOUSING NEEDS BY COUNTY
1970

County Net Units Needed Low and Moderate
Montgomery 70,248 8,811 86%
Greene 2,326 2,159 93%
Miami 1,632 1,553 95%
Preble 938 868 93%
Darke 769 734 95%
Total (Region) 15,913 14,125 89%
Source: Miami Valley Regional Planning Commission . A
Housing Plan for the ] viiami Valley Region- -A
Summary )Dayt on, Ohio , July 1970).
The regional commission then developed a formula to distribute dwelling units. The low- and moderate-income housing needs include both FHA-assisted and public housing units. The final distribution of units represents the number of units to be received by each jurisdiction under the composite distribution method.
The plan emphasizes that these figures are not intended to be taken precisely at their face value, but are to be used as guidelines for scattering the needed units.


73
For each planning area within each county, the formula developed averaged the measurements of the following six factors:
(1) equal share (assign the total need equally among the planning units);
(2) proportionate share of the county's households (assign the total need in proportion to each unit's share of the total population--distributing units
in the same ratio as total population is distributed);
(3) proportionate share of the county's households making less than $10,000 annually (or less than $7,000 in the three more rural counties) (assign the total need according to the number of low- and moderate income households in each unit--the greater the share of lower-income households, the greater the number of units assigned);
(4) the inverse of number 3 (assign units inversely
to the proportion of low- and moderate income households --the greater the proportion, the smaller the number of units assigned);
(5) a share based on the assessed valuation per pupil of the school districts covering the planning units (the higher the assessed valuation per pupil, the greater the number of dwelling units assigned; and
(6) a share based on the relative overcrowding of the school districts involved (the most overcrowded districts receiving the fewest dwelling units).4
The final result was an allocation of each county's low and moderate income housing need to every planning unit of the county. Obviously, any number of methods could be devised to accomplish the distribution, employing any combination of factors. In making its analysis of pertinent factors and ways of combining them, the staff considered three groups of elements. One was population, and included such things as number of people, number of households, household income distribution, number of persons over age 65 and number of welfare cases in each


74
planning unit. Another category was housing itself and within this were number of dwelling units by type, age of dwelling units, the condition of housing in each planning unit, percentage of home ownership, average house value, and number of dwelling units by type, age of dweeling units, the condition of housing in each planning unit, percentage of home ownership, average house value, and number of building permits issued during the last several years. The third category was facilities, and this included the availability of sewer and water, transporation, shopping facilities, recreational areas, schools, and proximity to employment and job centers.^
All of these things were compiled into a huge matrix with the planning units forming the vertical axis, and the thirty factors forming the horizontal axis. Thus, all of the planning unit profiles could be viewed in relationship to one another and their characteristics compared easily.
The six factors of the MVRPC plan (refer to page 63 of this report), represent the three broad criteria discussed in Chapter III: need, distribution and suitability. The MVRPC revised its formula in the Spring of 1973 and expanded the number of factors considered to twelve. The revised formula equated a planning unit's fair share to the average of "equal share," "need adjustment," "ability adjustment," and


75
"performance adjustment." "Need adjustment" averaged:
(1) the number of low- and moderate income families
(2) the number of low- and moderate-income households paying more than 25 percent of their income for rent;
(3) the number of units lacking some or all plumbing facilities;
(4) occupied units with roomers, boarders and/or lodgers; and
(5) occupied units with more than 1.5 persons per room.6
The ability adjustment component averaged the following
relative values for each area in the county:
(1) assessed valuation per pupil;
(2) pupils in excess of normal capacity;
(3) the number of households with incomes below the poverty level; and
(4) the number of acres of suitable vacant land within the planning unit.
"Relative performance" averaged:
(1) the number of public units available for occupancy; and
(2) the number of assisted units available for occupancy.
"Equal share" expressed the number of needed units
which would be received by each planning unit if the
7
need were divided equally.
Being the first agency to develop a model, the MVRPC could not draw upon earlier designs, making it very likely that their formulation would have problems. Probably the most obvious pitfall of the original formula was that the availability of land was not considered.


76
This led to the allocation of a number of units to an area clearly unable to absorb them. This problem was dealt with in the revised formula. The advantage of the original formula was that it considered just six variables, the revised formula is much more difficult to work with. Nonetheless, the staff of the MVRPC considered that the expanded number of factors made the formula more sensitive to local needs. In addition, both formulations seemed to consider factors which would cancel each other out. For example, each planning area was assigned housing units proportionately to its share of low- and moderate income households and inverse-
O
ly to its share of low- and moderate-income households.
The original MVRPC allocation plan with fifty-three planning units and six equally weighted allocation criteria was formally presented to the commission in July 1970; public meetings which often saw heated debate were held during the summer, and in September
the commission unanimously accepted the fair-share
i 9 plan.
The plan's adoption can be attributed to numerous factors. The strategy was supported by the Housing Advisory Group, a coalition of public and private groups such as Dayton's Community Action Agencies, the League of Women Voters, the Urban League, and the Dayton Area Chamber of Commerce.^ Members of this coalition were informed of progress and consulted during the


formulation of the allocation strategy. Other groups supporting the allocation strategy included developers, nonprofit groups, public housing authorities and the press. Over the years the commission had developed a rapport with these groups by offering technical advice and even some financial assistance, such as seed money loans. This aid was rewarded by the support given to the fair-share plan. Also, the commission staff developed positive relationships with local public officials by providing assistance in housing matters and by being willing to freely discuss and examine planning and housing issues that arose.'*''*' In turn, the local officials who served on the commission were favorably disposed to vote for the dispersal strategy.
A last factor in winning support for the fair-share strategy was the modification of the original plan. Originally, the staff asked for preemptive power over local zoning authority as a means of implementing the allocation strategy. This clause was vociferously opposed by some local officials and the override power was dropped. A fair-share plan without preemptive zoning power was more palatable to
12
local officials, who ultimately voted for the strategy.
Nonetheless, the unanimous vote for the commission stragegy was not followed by unanimous support in implementation. Resistance to the Dayton Plan was often


78
vociferous. Some of its supporters were roundly criticized in the November 1971 election. Two counties and ten municipalities threatened to secede from the MVRPC, and when the MVRPC proposed a 166-unit project for Miamisburg, a blue-collar suburb of Dayton, a local ad hoc committee was formed to oppose it. The committee's persuasive arguments that the proposed housing would increase local taxes and overburden schools, sewers
and transportation facilities resulted in an over-
14
whelming defeat for the Miamisburg housing plan.
Impact of the Dayton Plan
Today, such opposition has cooled due to mitigating factors such as the MVRPC's established reputation and the fact that some communities began to view the plan not as a strategy to house the poor of Dayton, but rather as a means to help them house their local low- and moderate income families.
The decline in opposition was reflected in the fact that no county or municipality carried out its threats to withdraw from the MVRPC. Furthermore, there was a substantial rise in the pace of construction under the Dayton Plan. A 1972 report1^ revealed that eight hundred units had been built since the plan's inception; as of mid-1974 almost 4,400 multi-family units had been built or were under construction and 1,000 multi-family units were proposed.^ Approximately 1,000 additional


79
single-family subsidized units were either built or proposed.
This low- and moderate income housing production is far in excess of the housing volume of previous years. Prior to 1970 low- and moderate income housing volume averaged about one hundred units annually; from 1970 to 1974 housing production jumpted to considerably over 1,000 annually. The units were subsidized under such programs as public housing and Section 221 (d)(3). About two-thirds of the constructed or proposed housing units were for families; the remainder were for the elderly.
From 1970 to 1977 the total number of subsidized
units increased from 3,000 to 12,145 (see Table 6).
In 1970, 95 percent of all subsdized units were
located in Dayton and 5 percent outside of Dayton.
By 1979, the distribution had changed to the following:
55 percent of the total subsidzed units occurred in
Dayton and 45 percent of all subsidized units were
17
outside of Dayton. It should be noted that during 1973-75, a three-year period, there was a federal housing moratorium as described in earlier chapters of this report.
In 1970, the Dayton Plan showed a total county need of 14,000 low- and moderate-income units by 1975. At the end of 1975, all subsidized units built totalled


80
approximately 11,000 units. In the five-year period
from 1970-1975, Dayton met 79 percent of the total
low- and moderate income housing need projected for
18
the Miami Valley region. Revised goals for the three-
year period of 1978-1980 indicated a need for 4,530
19
new units of low- and moderate-income housing.
Three years later, the MVRPC had built 2,030 units
of low- and moderate income housing, or 40 percent
20
of the proposed goal for 1978-1980.
From 1978 to 1982 (specifically 1978-1980 under a new presidential administration), the pace of subsidized housing production skyrocketed compared to what existed in 1970. In 1970, there were only 3,000 subsidized units in the Dayton area, 95 percent of which were located in the City of Dayton. By the end of 1982, the total number of subsidized housing units in the Dayton area had risen to 26,077. Thirty-three percent of all subsidized housing was located in Dayton City and 67 percent of all subsidized housing was located outside the City of Dayton in 1982.^
In 1970, almost all lower-income housing was concentrated in Dayton City; only one other area,
Greene County, had any public housing. By the end of 1982, Dayton's share of low-income housing dropped considerably (from 95 percent to 33 percent). Of the 17,000 units that were dispersed in the suburbs


81
(see Table 6), about 80 percent were for families. By changing the dispersal of subsidized housing in the suburbs from 5 percent to 67 percent, the MVRPC substantially broadened suburban housing opportunities for low- and moderate-income persons in the Miami Valley region.
TABLE 6
LOCATION OF DAYTON REGION SUBSIDIZED UNITS:
1970 and 1982
Location of Subsidized Units Cumulative As of 1970 Cumulative As of 1977 Cumulative As of 1982
Subsidized Units in Dayton 2,850 6,672 8,702
Subsidized Units Outside of Dayton 150 5,473 17,375
TOTAL 3,000 12,145 26,077
Percent in Dayton 95 55 33
Percent Outside Dayton 5 45 67
TOTAL 100 100 100
Note: Figures are rounded to indicate rough allocations.
Source: Ann Shafor, former Deputy Director of Housing and Human Resources, Miami Valley Regional Planning Commission, April 1983.


82
Twin Cities Region, Minneapolis-St. Paul,
MinnesotaPriority Approach
In contrast to the above numerical models which quantify some aspect (s) of need, distribution and/or suitability, the priority models identify desirable areas for the building of low- and moderate-income housing units. The "prototype" priority model is the plan developed by the Metropolitan Council of the Twin Cities Area (Minneapolis and St. Paul, Minnesota) The plan was developed to provide guidelines for the Council's A-95 authority and to provide direction to developers and local housing authorities as to where to locate subsidized housing, with an eye to the dispersal of housing opportunities. When the Council began work on their plan, only the Miami Valley Regional Planning Commission had a model open to public inspection. The Council decided against using the numerical approach and opted for a plan based on each area's "level of development."
Each area in the Twin Cities area has been classified according to whether it is: Priority One--mostly developed (35% or less undeveloped land);
Priority Two--developed/developing (361 to 601 undeveloped); Priority Three--rural/developing (between 61% to 89% undeveloped); or Priority Four--rural (90% or more undeveloped) (see Figure 3). The extent of


83
FIGURE 3
SUBSIDIZED HOUSING ALLOCATION PLAN: PRIORITY AREAS
1st Priority
'?^2nd Priority
3rd Priority
Freestanding Communities
ioac tt
I ND(R(NO(NC(
____ ACNO
Miaar 'niTt
| M toung
r-.
j nobnoOdC"3 1 _
COiMkL
, -lee. | SSM3N j
I So I
Lh_!^____j_____________
LrJ
TWIN CITIES METROPOLITAN AREA
i '
2 oacao
3 N'A*fTONKA St AC M
4 TOR!a SAT
3 lictitioa catiavoo
7 VOOfKANO l A I
9 Victoria
10 aoasiatOALt
11 SABIN LAKC BASK
12 U I GOVT
13 Hill T Of
14 COLUMBIA HtlCMTt
15 ST ANTHONY IS LAUOtaOAli
17 f AlCON M|I6HT| IS MtNDOTA
19 III YD All
20 GRI* ClOUO
21 lANOBALi
22 OtllNOOO
23 aiNt rins
24 I
23 AIM IAKI
26 BiaCHMOOO
27 *MiTC hear 7S SATBOBT
29 MIIUBNIC
30 OAa BARK HCIOMTS
31 lAKtLAND SHOilS
32 ST MART S BOIST
-A**2-* County Boundary
***-----Municipal Boundary
----Township Boundary


84
development was considered the best indicator of the presence of services and facilities desirable for residential development. Presumably, those areas with the least amount of undeveloped land were considered to have the greatest possibility of possessing needed services and facilities. After determining the priorities of the areas development proposals in Priority One areas would receive funding before proposals in lower priority areas. Competing proposals from similar rated priority areas would be judged in terms of increasing housing opportunities for low- and moderate-income households. A project scheduled for an area with a low concentration of lower-income households would receive funding before one in an area with a higher concentration of lower-income households.^
Two exceptions were made to the above procedure. The central cities, Minneapolis and St. Paul, were classified as conditional first priority areas.
These cities were allocated a portion of all funds received so that they would be able to meet their renewal commitments. The second exception is in the case of planned unit development (PUD) proposals to be located in low-priority areas. Since these types of developments usually include the provision of services and facilities, PUD proposals would be judged on their own merit without reference to the model.


85
In addition to a priority rating of areas the Council divided the metropolitan area into seven subsectors and two cities. Each of these nine areas is assigned a quantitative goal in the provision of low-and moderate-income housing in relation to its 1) share of the present population, 2) share of expected new residential growth, 3) share of present jobs, and 4) share of expected new jobs (see Figure 4). These quantitative goals would be referred to only in order to evaluate whether dispersal was taking place. The priority method would be the mechanism for determining the worth of a given project; the quantitative goals
would be used to monitor the effectiveness of the . 23
priority system.
Impact of the Twin Cities Plan
In 1971, there were approximately 19,000 approved subsidized housing units in the Twin Cities
region which were distributed among fifty-one
24
municipalities. Nineteen communities had housing and redevelopment authorities; however, approximately 90 percent of the aided housing was located in the two inner cities of Minneapolis and St. Paul, a pattern characteristic of many other metropolitan regions (see Table 7).
Along \vith 90 percent of all the subsidized housing located in the center cities, only about 1,900


86
FIGURE 4
Ramsey County
-Northern *-Washington County
5,082
WASHINGTON CO
3i CO#CO*a* *4*1.1 60VI V
Northwest Hennepin County3 j


Southern
Washington
County
3,610
IMVO ctovc rtCIGMM
DAKOTA CO
Southern Hennepin and Scott Counties
Dakota County
DISTRIBUTION OF NEW HOUSING UNITS, 1977-1987
: ^Outlying Area Developing Ring Inner Ring |Minneapolis-St. Paul
... . \ j i
Northern Anoka County j
-5,625
* QlOttTTO
NOcrruofMCC "toima
22,521
______^^/tMpie.ac d-r__________
5,739 aamh
S* k.*TD*N H
CC*IA
Western Hennepin j and Carver Counties
M TOuiC a*c*ica
o**oooC3
| COtOOMtj
*Ca I 3s*;s
I
! ...<> 37 V- OKMOUMT woi*9'/s+'~' -V Ws,.2.715J -A.*/,S I
J* j L, ^ i
>**TTo
TWIN CITIES METROPOLITAN AREA
t }< r*K 9 VICTOHA t7 7AICO* HI6MT| n 6(H 14RI
2 0*0*0 o iomimioali 4 mDor i*cm*ooo
J M1**(T0NKA MACH It ir*l* LAKI r**K 19 UtTOAlI 27 H>'F!1CA
4 r OM%A IA T 12 U s SQVT iO CLOwO .1 ATPO*T
5 UCtltlOl ij H'LITO* 21 l A MO# ACL .9 0'LIII*K
4 illlltiXM 14 COtJMIIA MIlCMTt 22 OIU.IOOO 30 OAK PAIR Mf'&MTI
OKAM 13 sr A* T HOB V 23 IH( ir*INS 31 lACILAMO I HO III
tKIU LA(| 1 LAuMIDAlI 24 MAXTOHOI !2 IT HAIT l*Oi*T
---County Boundary
--------Municipal Boundary
----Township Boundary


87
TABLE 7
CUMULATIVE TOTALS OF SUBSIDIZED HOUSING 1971-1981, MINNEAPQLIS-ST. PAUL, MINNESOTA

Total Units Central Cities Units Percent Suburbs Units Percent
July 1971 18,736 16,858 90% 1,878 10'
July 1973 24,202 19,877 82 4,325 18
July 1974 25,013 20,414 82 4,599 18
Dec. 1976 27,986 20,118 72 7,868 28
Dec. 1977 31,851 21,060 66 10,791 34
Dec. 1978 34,650 21,891 63 12,759 37
Dec. 1979 37,268 22,556 61 14,712 39
Dec. 1980 33,309 23,182 59 16,127 41
Dec. 1981 40,067 23,507 59 16,560 41
Source: Metropolitan Council of the Twin Cities Area (St. Paul, February 1983) 1981 Subsidized Housing Activity in the Metropolitan Area.
units or 10 percent were located in the suburbs These were
primarily for the elderly. Ten years later, about 17,000
25
units or 41 percent of all subsidized housing units were located in the suburbs. The total number of subsidized housing units more than doubled in ten years (see Table 7).


88
A particular program objective of the Metropolitan Council was to increase the number of low-income family units. In 1971, approximately 59 percent of the region's total subsidized units were for elderly and 42 percent were for families. By the end of 1980, this trend had changed--56 percent of the suburban units
served families and 44 percent of the suburban units
2 6
served elderly persons.
Since 1971, the number of communities providing subsidized housing increased substantially. (See Figures 5 and 6.) Only 54 communities had some subsidized housing units in proposed or approved status in 1971. And only 16 of those offered subsidized rental units for low- and moderate income people.
The remaining communities had only a few units each, and those were HUD Section 235 houses for sale only to moderate-income families. By the end of 1981, 91
communities, or 48 percent of the Region's 189
2 7
communities, offered subsidized housing. Of
these, 77 communities offered rental housing, and
the rest had only moderate-income homeownership 28
units.
Overall, the total number of subsidized housing units more than doubled in the ten-year period from 1971 to 1981 (see Table 7). In 1971, there were about 19,000 subsidized units in the Twin Cities area. Of


iVIet
89
FIGURE 5 COMMUNITIES WITH
SUBSIDIZED HOUSING / TWIN CITIES METROPOLITAN AREA IN 1971
: ipkimg n ) moumo
2 0>ONO .5 OMiatOAlC
2 ac*CM :: ;a*img *c aa*b
:: r*LC3N -ciumts 25 *cm L*e
1 TOMKA M
* (xcr.sio*
4 ittCMwOOO 7 OOBUKO 3 -COIC:m .
.2 j :avr .3 -MU.ro*
1* COLU Mil A -KIGMTJ
15 IT *r*OMT
16 IAUOOOALC
.3 MCN00T4
13 wiwTOAtl
:o
2: .AofAtu
22 3CL.MOOO
23
;a mamtomcoi
26 IIICHKQOO
27 * T* j£ia
:a iAT*nar
29
20 3AK AUK -EIGHT!
31 kAKCLAMO iHOMS
32 IT Ain A01MT
^2-*----County Bouncar/
-----Municioal Boundary
-------Tcwnsmc 3ouncary


Figure 6
COMMUNITIES WITH SUBSIDIZED HOUSING IN 1981
TWIN CITIES METROPOLITAN AREA
1 SPRING PARK
2 ORONO
3 MINNETONKA REACH
4 TONKA RAY
5 EXCELSIOR
6 GREENWOOD
7 WOODLAND
8 MEDICINE LAKE
9 MOUND
10 RORRINSDALE
11 SPRING LAKE PARK
12 U. S. GOVT
13 HILLTOP
14 COLUMRIA HEIGHTS
15 ST ANTHONY
16 LAUDERDALE
17 PALCON HEIGHTS
18 MENDOTA
19 ULYDALE
20 GREY CLOUD
21 LANDFALL
22 OELLWOOD
23 PINE SPRINGS
24 MAHTOMEOI
25 GEM LAKE
26 RIRCHWOOO
27 WHITE BEAR
28 BAYPORT
29 WILLERNIE
30 OAK PARK HEIGHTS
31 LAKELAND SHORES
32 ST. MARY S POINT
---County Boundary
-2*2112--Municipal Boundary
-----Township Boundary


91
these 90 percent were concentrated in Minneapolis-St.
29
Paul and 10 percent were located in the suburbs. Production increased slowly during the years 1973-1975; again, this can probably be attributed to the moratorium on federal housing production that occurred during those years. In 1976, production began to increase and as can be seen in Table 7 the most dramatic increase occurred from 1976 to 1981. The end result of the ten-year period (1971-1981) was a total production of 40,067 subsidized units. ^ In terms of geographical distribution, the number of units concentrated in central cities dropped from 90 percent in 1971 to 59 percent in 1981. The number of units that were built in the suburbs increased from 10 percent in 1971 to 41 percent in 1981. By the end of 1981,
Twin Cities' fair share efforts had considerably broadened suburban housing opportunities for low-and moderate-income persons in the Miami Valley region.
The Twin Cities Plan set a goal in 1975 to construct 9,985 units each year for a ten-year period. Another goal set in 1977 established a need of 53,939 low-income units in the region for the years 1977-1987.^ The five-year goal or half of the above ten-year goal, establishes a need of 23,182 (924,634 units per year) low-income units for the period of 1977-1981.


92
However, none of the above yearly or five-year goals were met as 9,250 low-income units were produced in the five-year period of 1971-1976; and, 12,081 low-income units were built in the five-year period of 1977-1981. At the end of 1981, the Twin Cities plan had met about 52 percent of its numerical goals.
San Bernardino County, California
Combined Approach
Many planning boards have utilized a combination of the numerical and priority methods. Usually, the numerical method is used to identify goals for each area in a study region. The priority system is used to study subunits within a given area in order to determine a site's suitability for development.
The San Bernardino County California Planning
Department is credited with the development of the
combined approach. In a report dated January 1972,
the County Planning Department presented a government-
subsidized housing distribution model developed in
conjunction with three Councils of Governments repre-
32
senting the entire county. The impetus behind the development of the model centered on a growing awareness that over-concentration of subsidized developments and poorly planned projects generated local problems. Thus, the use of sound planning principles was viewed as a means of eliminating the potentially adverse


93
impact of subsidized units. Before a model was even developed, size and spacing requirements for projects were established.
San Bernardino County is a member of the Southern California Association of Governments (SCAG), the regional council of governments, as are thirteen of its fourteen cities. The County shares common boundaries with three other SCAG-member Counties.
The Valley part of the County has about 577,000 residents or 64 percent of the County's total population of about 895,000. The County's total area is about
20.000 square miles greater than the combined land mass of Rhode Island, New Jersey, Delaware, and Massachusetts. The Valley portion is only 2.4 percent of this land mass, whereas the balance of the County is 93.3 percent desert and 4.3 percent timbered alpine slopes.
The Valley area has ten of the fourteen incorporated cities and is typical of many other urban regions where "bedroom" communities cluster around the central cities. The Valley portion is viewed as an extension of the Los Angeles Metropolitan area and in fact functions as part of the urban coastal basin and the greater Los Angeles megaolopolis. The City of San Bernardino, the County seat and the County's largest city, is about 50 miles east of downtown Los Angeles, with a population of approximately
117.000 residents.


94
San Bernardino County has grown rapidly over the past twenty years. Although the County's rate of growth declined during the 1960s from its rate of the previous decade, the County continued to experience a permanent population gain of more than 35 percent.
This represents a growth rate nearly three times the national average. As a result of rapid growth impact, there was a growing official and public concern due to an over-concentration of federally-subsidized housing units within limited geographica areas.
Schools and other community services were adversely impacted as a result of the concentration of large numbers of subsidized lower-income housing units in certain areas of the Valley portion of the County.
The San Bernardino County Plan consisted of two models. The Inter-Planning District Model used the numerical approach, assigning a specific percentage of the total need for subsidized units to be accepted by each planning area. The County was divided into 23 planning areas, drawn along census tract lines to permit the use of readily available data. The Inter-Planning District Model finally considered 15 of these planning areas, eliminating 8 planning areas due to their rural nature (see Figure 7). The model focuses on those factors which appear to be the most significant in determining where