Comprehensive Housing Policy Racial Equity Audit Report – Part I: City’s audit reveals systemic racism in housing system

Councilman Casey Thomas, Housing and Homelessness Solutions Committee chairman, leads the meeting to discuss housing policies and practices, Dec. 14. – The Dallas Examiner screenshot/City of Dallas video



The Dallas Examiner


The Housing and Homelessness Solutions Committee met in the City of Dallas Council Chambers, Dec. 14 to discuss the Housing Policy Equity Analysis as a result of the Comprehensive Housing Policy Racial Equity Audit.

Councilman Casey Thomas, the committee chairman, led the meeting. He opened with an initial statement, which offered a bit of history behind the audit.

“I was appointed Jan. 1 by the mayor to serve as chair of the Housing Homeless Solutions Committee,” he stated. “At our first meeting in January, I requested this Racial Equity Audit of our Comprehensive Housing Policy after having consultation with our housing director, Dr. Johnson, our chief of Housing and Neighborhood Revitalization.”

He said he was informed about a month or two ago, that the report was ready. He then stated that the Dec. 14 meeting on the audit was historic.

“Today, here in the city of Dallas, we are taking a close look at how we do housing from a racial equity standpoint,” he emphasized. “And so I’m very excited and looking forward to this. I want to commend TDA Consulting. They did a thorough job in terms of not only their analysis, but also the recommendations. Before we have them to do the presentation. I want to go on record say I’m in support of all the recommendations.”

He then laid out a timeline for how the committee would move forward, beginning with the briefing for the committee that day. The committee will also host:

  • The week of Jan. 17 through Jan. 21 – Four citywide community town hall meetings where the consultants will present the report.
  • On March 2 – A full briefing of the Racial Equity Audit Report and the recommendations will be presented to the Dallas City Council members.
  • March 28 – Committee will meet and vote on the recommendations for the City Council.
  • April 11 – Committee plans to present report to the City Council and place on agenda for a vote.

David Noguera, director of Housing and Neighborhood Revitalization, then introduced the consulting company that developed the audit report.

“This morning will be briefing the committee on the comprehensive Housing Policy Equity audit report. The policy, called Public Comprehensive Housing Policy, was adopted roughly three and a half years ago, in 2018 by the City Council,” Noguera stated. “Over the past six months or so, the audit team has been reviewing that policy meeting with stakeholders and is prepared to report out on their conclusions today. The consultant team is led by John Gilvar, Christine Campbell and Michelle Williams of TDA Consulting.”

A copy of the complete report was included as an attachment to the briefing. Campbell took over the presentation, offering a bit of history regarding the audit, findings and recommendations.

“As you know, your Comprehensive Housing Policy was developed at a time the city had many fines from HUD, they had some political and issues that they were dealing with,” she said. “And what you did was you developed a housing policy that really addressed those concerns, made sure that we were in compliance with HUD’s regulations and that we were level setting the work that was being done – improving the quality of what that was being done. So you have a Comprehensive Housing Policy designed to really ensure that you doing things right. It was a bit of a defensive plan. To use a football analogy; we were on defense. We were trying to fix what was broken and you did that, and you did that well.

She described the time used to analyze the data as a timeout while the group reviewed the last three years. The group compared what it observed to what needed to be done in order to have a more racially equitable city.

“As we moved forward through this work together, we had some real key questions we were trying to answer, as we looked at the housing policy – keeping in mind that it was a start and that it was a foundational piece – how did the city of Dallas really want to move forward?” she continued. “So we wanted to look as how the Comprehensive Housing Policy worked in the city. Did it do what we wanted it to do? Did it empower leaders to address some of the root causes of affordable housing – some of equity or inequity in Dallas? And did it really address that North/South divide?”

In meeting with several residents across the city, Campbell said that the North/South divide stood out as an example of where equity work was needed most. That would mean examining the city’s current policies – many of which are historical policies and practices that have been in place for generations and still impact the system today. Many of the policies and/or how they’re carried out have created barriers to safe, affordable, quality housing, especially for Black and Latin communities across the country, according to Campbell.

“So in order to do that we really needed to look at some of the historical legacy, some of the policies and practices that have been in place – not just in Dallas but in cities across the country – that stemmed back to the Civil War era, where Black and Brown people were prevented from owning land, where Black and Brown people were held back from being able to build generational wealth,” she stated. “This is not something that is unique to Dallas. It’s the culture in which we lived. And we now have an opportunity to undo some of those historical practices that have prevented Black and Brown people, specifically, from being able to actively participate in the American dream.

“It is admirable that a city like Dallas would want to take a look at the policies and say ‘How can we make sure that we are developing systems that allow for people to have ownership and increase median home values across our city?’ ‘How can we decrease the rent burden on specific parts of our population?’ ‘How can we change the current landscape so that affordable housing continues will reflect the needs of the community – so that it will eliminate some of the historical forces that have prevented Black and Brown people from being to excel and to really thrive?’ When we talk about equity, we talk about everyone having the opportunity to thrive within their communities.”

She said TDA thoroughly analyzed each component of the Comprehensive Housing Policy and then compared it to the Race, Equity Impact Assessment Tool by Race Forward. They then used the information as a guide to evaluate the Comprehensive Housing Policy.

The group also reviewed the city’s existing housing data and housing department data to review how it works, how it’s being developed, how are people working together, etc. The group reviewed the city’s Neighborhood Plus Plan and consolidated plan. Additionally, they met with the city’s equity office to see how all of plans and efforts were working together and connected in advancing the goals of equity and affordable housing

“We took a tour of Dallas,” she reflected. “That was so eye opening, being able to meet with someone who was actually developing a property in part of Southern Dallas, and to be able to really see what’s going on. And then most importantly, we talked to you. We spent time speaking with Council members. We spent time meeting with community stake holders, large developers, small developers, members of the LGBTQ community, the Black community, the Latino community, different neighborhoods, people who are invested in making sure that Dallas is the city that we know and want it to be. And that’s a really large part of doing equity work.

“As we’ve shared with a lot of you during this process, race equity is not just outcome, it’s also a process. So being able to engage the community in its assessment from the very beginning was key for us to be able to have a successful review.


Note: Part II will cover details of the group’s discoveries and recommendations. It will be published in the Jan. 6 issue, due to the holidays.



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